for the greatest good

United States Department of Agriculture

Ashland Trails Project

Draft Decision Notice and Finding of No Signifi cant 

Impact - Siskiyou Mountains Ranger District

Jackson County, Oregon

for the greatest good

September

2015

Ashland Trails Project Draft DN and FONSI 

ii 

TABLE OF CONTENTS 

Introduction and Background ....................................................................................... 1 

Decision ........................................................................................................................ 1 

Description of Selected Alternative .............................................................................. 1 

Construction Specifics .................................................................................................. 9 

Rationale for the Decision ............................................................................................ 9 

Modified Alternative 3 Responding to the Purpose and Need .................................... 10 

Modified Alternative 3 Responding to the Relevant Issues ........................................ 12 

Other Issues Considered ............................................................................................. 15 

Resource Protection Measures, Monitoring, and Enforcement .................................. 16 

Other Alternatives Considered .................................................................................... 21 

Public Involvement ..................................................................................................... 22 

Finding of No Significant Impact ............................................................................... 22 

Legal Requirements and Policy .................................................................................. 25 

Pre-decisional Administrative Review Process .......................................................... 26 

Implementation ........................................................................................................... 28 

Contact and Additional Information ........................................................................... 28 

Responsible Official .................................................................................................... 28 

LIST OF TABLES 

Table 1- Trail Managed Uses- Modified Alternative 3 ................................................. 1 

Table 2- Trail Network- Modified Alternative 3 .......................................................... 2 

Table 3- Decommissioned Trails .................................................................................. 3 

Table 4- Project Design Criteria and Mitigation Measures ........................................ 17 

LIST OF FIGURES 

Figure 1- Ashland Trails Project Modified Alternative 3 Trail Network map ............. 4 

Figure 2- Trail Detail Modified Alternative 3 Lower Eastside map ............................. 5 
Ashland Trails Project Draft DN and FONSI 

iii 

Figure 3- Trail Detail Modified Alternative 3 Upper Eastside map ............................. 6 

Figure 4- Trail Detail Modified Alternative 3 Lower Westside map............................ 7 

Figure 5- Trail Detail Modified Alternative 3 Upper Westside map............................ 8 

ATTACHMENTS 

Attachment A- Response to Comments 

Attachment B- Draft Environmental Assessment Errata
Ashland Trails Project Draft DN and FONSI 

1 

INTRODUCTION AND BACKGROUND 

This Decision Notice documents my decision and rationale for the selection and modification of 

Alternative 3 of the Ashland Trails Project Environmental Assessment (EA). The Modified 

Alternative 3 of the Ashland Trails Project will provide approximately 24.9 miles of non-motorized 

trails in the vicinity of Ashland, Oregon and will close and rehabilitate 9.9 miles of existing 

unapproved trails to minimize impacts to natural resources. 

Opportunity to comment on the EA was provided December 29, 2014 through February 6, 2015. All 

comments submitted during the comment period for the EA and throughout the planning process 

have been considered and evaluated. 

The Ashland Trails Project is located on the Siskiyou Mountains Ranger District on the Rogue RiverSiskiyou National Forest south of the City of Ashland. The action area is generally bound on the 

north by the City of Ashland; on the east and south by the Forest boundary, with the majority of the 

trail system proposed to the west and downslope of Forest Service Road 2080; and on the west by the 

Ashland Municipal Watershed boundary. About 1,200 feet of the 3.2 mile Split Rock trail is located 

within the Klamath National Forest boundary. 

DECISION 

It is my decision to implement a modified version of Alternative 3 as described below. I believe this 

decision best addresses the purpose and need for the proposed action in consideration of the 

comments received on the EA. This alternative will reduce user conflict through trail design, use 

designation, and management. Modified Alternative 3 will also provide an adequate and sustainable 

trail system that minimizes impacts to soil, water, cultural, vegetation, and wildlife resources and 

discourages unauthorized trail proliferation. The reasons for this decision are specifically provided in 

the section below Rationale for the Decision. 

DESCRIPTION OF SELECTED ALTERNATIVE 

Table 1 summarizes the modifications to the Managed Uses in Alternative 3 that are reflected in this 

decision. These changes to the Managed Uses were based on public comments and input gathered 

from the public meeting held in Ashland on January 8, 2015 and are implemented to further reduce 

user conflict by separating user groups. 

Table 1- Trail Managed Uses - Modified Alternative 3 

Trail Name Length 

(miles) Managed Use Under Alternative 3

Managed Use Under

Modified Alternative 3

Wagner Glade 2.2 Hiker/Pedestrian, Bicycle, Equestrian Hiker/Pedestrian

Split Rock 3.2 Hiker/Pedestrian, Bicycle, Equestrian Trail will remain available for dispersed 

Hiker/ Pedestrian use but will be managed 

as a Class 1 Trail.

Caterpillar 0.5 Hiker/Pedestrian, Bicycle, Equestrian Hiker/Pedestrian, Equestrian
Ashland Trails Project Draft DN and FONSI 

2 

Trail Name Length 

(miles) Managed Use Under Alternative 3

Managed Use Under

Modified Alternative 3

Alice in Wonderland 0.2 Bicycle Hiker/Pedestrian, Bicycle, Equestrian

Jabberwocky 1.7 Hiker/Pedestrian, Bicycle Bicycle

Wonder 1.3 Hiker/Pedestrian, Bicycle Hiker/Pedestrian, Bicycle, Equestrian

Not Stirred 0.3 Hiker/Pedestrian, Bicycle Hiker/Pedestrian, Bicycle, Equestrian

Upper Missing Link 1.2 Hiker/Pedestrian, Bicycle Bicycle

Lower Missing Link 1.0 Hiker/Pedestrian, Bicycle Bicycle

1

See Construction Specifics below for discussion of how various trail classes are developed and maintained.

Table 2 summarizes the trail network and the Managed Uses associated with each trail in Modified 

Alternative 3. 

Table 2- Trail Network- Modified Alternative 3 

Trail Name Length (miles) Managed Use

Alice in Wonderland 0.2 Hiker/Pedestrian, Bicycle, Equestrian

Upper Time Warp 3.4 Bicycle

Wagner Glade 2.2 Hiker/Pedestrian

Split Rock 3.2 Hiker/Pedestrian

Lower Marty's 0.5 Hiker/Pedestrian, Bicycle

Jabberwocky 1.7 Bicycle

Fell on Knee 1.0 Hiker/Pedestrian, Bicycle

Upper Missing Link 1.2 Bicycle

Lower Missing Link 1.0 Bicycle

No Candies 2.5 Hiker/Pedestrian, Bicycle

Upper Eastview 1.3 Hiker/Pedestrian, Bicycle, Equestrian

Ric’s 1.3 Hiker/Pedestrian, Equestrian

Wonder 1.3 Hiker/Pedestrian, Bicycle, Equestrian

Red Queen 1.2 Hiker/Pedestrian, Equestrian

Lewis Loop 1.1 Hiker/Pedestrian, Equestrian

Shaken 0.7 Hiker/Pedestrian, Bicycle, Equestrian

Not Stirred 0.3 Hiker/Pedestrian, Bicycle, Equestrian

Lizard 0.4 Bicycle
Ashland Trails Project Draft DN and FONSI 

3 

Trail Name Length (miles) Managed Use

Bandersnatch 0.4 Hiker/Pedestrian, Equestrian

TOTAL 24.9

Under Modified Alternative 3, the Rogue River-Siskiyou National Forest will incorporate 

approximately 24.9 miles of trails into the approved trail network in the action area, including 17.5 

miles of existing historic and unapproved trails and 7.4 of new trails. These trails, along with the 

current System Trails, will be clearly marked to reflect what uses are permitted on each trail. In the 

eastside of the action area where use is highest and where conflict is greatest, effort was made to 

separate user groups as much as possible. On the westside of the action area and on trails that are 

further from the City of Ashland where use is much lower, multi-use trails will be developed to 

disperse use over a greater geographic area, thereby lessening trail use density and contact with other 

users. 

In addition, approximately 9.9 miles of existing unapproved trails that were identified by the 

interdisciplinary team as not sustainable (i.e., use is resulting in unacceptable adverse impacts to soil, 

water, cultural, vegetation, and wildlife resources) will be decommissioned. 

Table 3- Decommissioned Trails 

Trail Name Length (miles)

Alice in Wonderland 0.2

Upper Time Warp 1.0

Winburn Trap 3.7

Lower Marty's 0.4

Jabberwocky 1.2

Chain Saw 0.2

Epstein Cut-Off 0.3

Insane Drop 0.1

Offshoot 0.3

Pete’s Punisher 1.3

Poison Oak 0.3

Reservoir (East Fork) 0.9

TOTAL 9.9

Modified Alternative 3 (Figure 1) best meets the need to provide a sustainable non-motorized trail 

system in the vicinity of Ashland; commensurate with current public demand, and consistent with 

natural resource management responsibilities and Forest Service capabilities. 
k

Upper Time

Warp

Wagner Glade

Insane Drop

Offshoot

Upper

Missing

Link

Upper East

View

Lower Missing

Link

Windburn

Trap

No Candies

Chainsaw

Reservoir

Lower Marty's

Epstein Cutoff

Fell On Knee

Poison Oak

Jabberwocky

Bandersnatch

Red Queen Shaken

Lewis Loop

Lizard

Ric's

Wonder

Not Stirred

Pete's Punisher

Split

Rock

Way

5§ ̈¦

2060

200

20

a UPPER BULL

GAP/ MT ASHLAND

BULL GAP

-LOWER

EASTVIEW

- UPPER

EASTVIEW

- LOWER

4 CORNERS

WHITE RABBIT

A S H L A N D

2060

500

2080

2080

Mt Ashland

22

a

99

¬«

66

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Lak

Reeder

Reservoir

McDonald

Peak

Wagner

Butte

KLAMATH

NATIONAL

FOREST

0 1 0.5

Figure 1. A

Modified Alter

Rogue River-S

Siskiyou Mou
á

Ç Ç

á

Ç Ç

WHITE 

RABBIT

2060

Alice In Wonderland

Alice In Wonderland Reroute

Bandersnatch

White Rabbit

Lizard

Red Queen

Lewis

Loop

Caterpillar Epstein Cutoff

Jabberwocky

Reroute

2080

G u l c h

2060

Reeder 

Reservoir

Wonder

100

2060

Reservoir

Caterpillar

Queen of Hearts

Pete's

Pun isher

Jabberwocky

Siskiyou

Mountain 

Park

Lamb Saddle

Lamb Mine

Lower Marty's

550

500

500

600

200

200

270

4 15

Upper

Missing

Link

Lower

Missing

Link

Lower

Missing

Link Lower

Bull

Gap

Upper

Eastview

700

700

2060

2080

Toothpick

Catwalk

Catwalk

Marty's

Ric's

Ric's

4 CORNERS

W i n d b u r n R i d g e

§ ̈¦5

Winburn Trap

Eastview

AREA

ENLARGED

Ashland

§ ̈¦5

¬«66

á

Ç Ç

Gate

Trailhead

Forest Service System Trails

New System Trails

Proposed For Decommision

Siskiyou Mountains Ranger District

Other Land, Including Private

Figure 2. Trail Detail

Modified Alternative 3

Lower Eastside

1 0 1,000 2,000 3,000 4,000 5,000

Feet

Project

Action

Area

á

Ç Ç WHITE 

RABBIT

Alice In Wonderland

Alice In Wonderland 

Reroute

White Rabbit

Lizard

Red Queen

Caterpillar

Epstein Cutoff

100

2060

Queen of 

Hearts

Pete's

Punishe r

Jabberwocky

Lewis

Loop

Ca et rpil al r

Jabberwocky

Reroute

Red

Queen

Bandersnatch

White Rabbit Trailhead Area Trails
500

200

270

4 15

Lower

Missing

Link Lower

Bull

Gap

700

Insane

Drop

Offshoot

Bull Gap

Lower

Bull

Gap

Corp

Camp

2060

2080

2080

200

Upper 400

Time

Warp

UPPER

BULL

GAP

Mt. Ash al nd

Road

Mt. Ashland

Road

Winburn

Trap

M o u n t 

A s h l a n d

Mt. Ashland 

Lodge

!

<

AREA

ENLARGED

Ashland

§ ̈¦5

¬«66

Trailhead

Forest Service System Trails

New System Trails

Proposed For Decommision

Siskiyou Mountains Ranger District

Other Land, Including Private

Figure 3. Trail Detail

Modified Alternative 3

Upper Eastside

1 0 1,000 2,000 3,000 4,000 5,000

Feet

Project

Action

Area
á

Ç Ç

á

Ç Ç

WHITE 

RABBIT

2060

Lewis

Loop

Caterpillar

Jabberwocky

Reroute

H

o r n

G

u l c h

Panther Peak

Wallow

R e e d e r G u l c h

No Candies

Horn Gap

Horn Gap

Shaken

Fell on 

Knee

2060

2060

Reeder 

Reservoir

Winburn Trap

200

400

400

405

404

3 00

Wonder

Wonder

Not Stirred

Poison Oak 100

200

2060

Reservoir

Pete's

Pun isher

Jabberwocky

Lamb Saddle

Lamb Mine

500

4 CORNE

W i n d b u r n R i d g e

AREA

ENLARGED

Ashland

§ ̈¦5

¬«66

á

Ç Ç

Gate

Trailhead

Forest Service System Trails

New System Trails

Proposed For Decommision

Siskiyou Mountains Ranger District

Other Land, Including Private

Figure 4. Trail Detail

Modified Alternative 3

Lower Westside

1 0 1,000 2,000 3,000 4,000 5,000

Feet

Project

Action

Area
2060

Wagner Butte

Upper Horn Gap

200

550

500

500

W i n d b u r n R i d g e

Bull Gap

Upper

Time

Warp

UPPER

BULL

GAP

Winburn

Trap

Upper

Time

Warp

Reroute

Upper Time

Warp

2060

Split Rock

Way

McDonald

Peak M o u n t aa A s h l a n d 20

Wagner

Glade

Mt. Ashland 

Lodge

!<

AREA

ENLARGED

Ashland

§ ̈¦5

¬«66

Trailhead

Forest Service System Trails

New System Trails

Proposed For Decommision

Siskiyou Mountains Ranger District

Other Land, Including Private

Figure 5. Trail Detail

Modified Alternative 3

Upper Westside

1 0 1,000 2,000 3,000 4,000 5,000

Feet

Project

Action

Area
Ashland Trails Project Draft DN and FONSI 

9 

CONSTRUCTION SPECIFICS 

The Split Rock trail will essentially remain in its current condition and it will be designated as a 

Class 1 Trail. Any maintenance that occurs on the Split Rock trail will follow the specifications for a 

Class 1 Trail in the Trails Management Handbook, Forest Service Handbook (FSH) 2309.18. All the 

other trails in the Ashland Trails Project, including new trails and reroutes, will be constructed and 

maintained in accordance with specifications for Class 2 Trails: 

 Tread Width. Class 1 Trail tread width is 0 to 12 inches. For Class 2 Trails, recommended 

design tread widths for single-width trails range from 6 to 60 inches, depending on designed 

use and site specific conditions (e.g., slopes, proximity of precipices). The maximum width 

for the majority of trails is not predicted to be over 24 inches, but depending on sight, 

distances and terrain up to 48 inches may be needed. 

 Clearing Limit. Class 1 Trail clearing height is 6 feet and clearing width is 24 inches, though 

some vegetation may encroach into the clearing area. For Class 2 Trails, recommended 

clearing heights range from 6 to 10 feet and clearing widths range from 24 to 72 inches, 

depending on designed use (larger widths and heights are generally provided to accommodate 

pack animals). The maximum clearing height and width will be 10 feet and 72 inches (6 feet), 

respectively. 

 Trail Target Grade. Class 1 Trail target grade ranges from 5% to 25%. For Class 2 Trails, 

recommended target grades range from 5% to 20%, and the short pitch maximum ranges 

from 25% to 30%, depending on designed use. The trail target grade is assumed to be 10% 

and the short pitch maximum is assumed to be 25%. 

 Surface Material. All proposed trails in the action area will be constructed of native surface 

materials (e.g., soil, rock, other naturally occurring materials). 

 Trail Slope Alignment. Trail slope alignments less than 45 degrees will be avoided to the 

extent practicable. Additional erosion control structures (e.g., waterbars or check dams) may 

be required where trail slope alignment angles are less than 45 degrees. 

RATIONALE FOR THE DECISION 

I have decided to implement a modified version of Alternative 3 in this decision because the 

incorporated changes better meet the project’s purpose and need. This decision is based on my 

review of the analysis presented in the Ashland Trails Project EA, comments received during 

scoping, comments received during the comment period that lasted from December 29, 2014 to 

February 6, 2015, and from input that was gathered at a public meeting held in Ashland on January 8, 

2015. 

Changes to managed uses in Modified Alternative 3 were made for a variety of reasons specific to 

each trail segment as described below: 
Ashland Trails Project Draft DN and FONSI 

10

Wagner Glade trail - because the Wagner Butte trail and the Split Rock trail are not open to bicycles 

or equestrians, the Wagner Glade trail will only be open to hikers/pedestrians. 

Split Rock trail - will be managed as a Class 1 Trail and will be open to hikers and pedestrians, and 

closed to equestrians and bicycles. For the most part, the Split Rock trail will remain in its current 

state being indistinct, unimproved, with fallen logs and other obstacles, and generally difficult to 

follow. Two short segments (measuring approximately 100 yards and 300 yards) will be clearly 

routed and improved to avoid Howell’s tauschia, a globally rare plant that is vulnerable to recreation 

impacts along the ridge. As a Class 1 Trail, the Split Rock trail will resemble more of a “route” or a 

“way” than an actual trail, providing a semi-cross-country rugged experience for those seeking a 

more natural environment than is likely to be found on other system trails. 

Caterpillar trail - bicycle use is eliminated on the Caterpillar trail from the junction with the Lizard 

trail, to the junction with Forest Road 2060. This modification will provide equestrian users a route 

void of bicycles, as was requested in the comments to the draft EA and from comments received 

during the public meeting. 

Alice in Wonderland trail - the 0.2 mile reroute will remain open to all non-motorized uses 

(hiker/pedestrian, equestrian and bicycles), consistent with use on the rest of the Alice in Wonderland 

trail. 

Jabberwocky, Upper and Lower Missing Links trails - will be managed for bicycle use and not 

recommended for hiker/pedestrian users due to limited site distances, and in order to reduce potential 

user conflicts. 

Wonder trail - will be designated as a one-way directional trail (uphill), open to all non-motorized 

uses (hiker/pedestrian, equestrian and bicycles) to the junction with the Not Stirred and Fell on Knee 

trails to reduce the potential for user conflict from downhill use. 

Lastly, the Not Stirred trail will be open to equestrians to provide a connecting route for equestrians 

from the Wonder trail to Road 2060-300. 

In selecting and modifying Alternative 3, I have carefully reviewed disclosures in Chapter 3 of the 

EA. The analysis discloses predicted environmental consequences of the actions, including effects to 

water resources, wildlife and wildlife habitat, soils and geology, aquatic species, botanical resources, 

non-native invasive plants, Inventoried Roadless Areas, cultural resources and fire risk. My 

conclusions are based on a review of the entire project record. 

MODIFIED ALTERNATIVE 3 RESPONSE TO THE PURPOSE AND NEED 

The need for this project is to provide a sustainable non-motorized trail system in the vicinity of 

Ashland commensurate with current public demand, and consistent with natural resource 

management responsibilities and Forest Service capabilities, that reduces user conflict through trail 

design, use designation, and management. The purpose of the action is to provide an adequate and 

sustainable trail system that minimizes impacts to soil, water, cultural, vegetation, and wildlife 

resources and discourages unauthorized trail proliferation. 
Ashland Trails Project Draft DN and FONSI 

11

The following considers how well Modified Alternative 3 addresses each of the following four 

recreation-related elements of the purpose and need statement for the proposed action. 

 To provide a sustainable non-motorized trail system. This relates to the proposed design and 

maintenance of the trail system. 

 To provide a trail system commensurate with public demand. This relates to current use 

levels and locations. 

 To reduce user conflict. This relates to user conflict and how conflicts may change under 

Modified Alternative 3. 

 To reduce unapproved trail proliferation. This relates to the past, ongoing, and anticipated 

future proliferation of unapproved trail construction in the action area under Modified 

Alternative 3. 

Provide a Sustainable Non-Motorized Trail System 

Modified Alternative 3 will address this element of the purpose and need statement through 

decommissioning 9.9 miles of existing historic and existing unapproved, poorly designed and 

unmaintained trails; incorporating existing historic and existing unapproved trails into the approved 

Forest Service trail system to allow for additional authorized trails and needed maintenance; and by 

designing all newly proposed and existing trails to standards that allow them to be sustainably 

managed over time. 

Provide a Trail System Commensurate with Current Public Demand 

One measure of the ability of a trail system to meet public demand is total trail miles. Currently, 

there is 15.8 miles of System Trails in the action area. Modified Alternative 3 will add an additional 

24.9 miles of trails, for a total of 40.7 miles of System Trails in the action area. This more than 

doubles the current trail system and will meet the estimated ongoing and future public demand. 

Reduce User Conflict 

Modified Alternative 3 will spread users over a greater geographic area than the current System 

Trails, thereby lessening trail use density and contact with other users, and will limit allowed uses on 

some trails to reduce the potential for user conflict. Trails will also be signed with uses that are 

excluded, and all multi-use trails will be signed with trail etiquette guidelines to reduce user conflict. 

Reduce Unapproved Trail Proliferation 

Proper trail design and use designation will lessen the likelihood of new construction and will 

simplify enforcement efforts within the action area. The addition of 24.9 miles of new System Trails 

under Modified Alternative 3, and the separation of managed uses in high use areas, will better meet 

public demand and improve recreational experiences, which will also lessen the probability of trail 

proliferation. Although none of the alternatives would eliminate the potential for unapproved trail 

construction, modified Alternative 3 addresses the root causes - over use and user conflicts – that 

drive the creation of many non-System trails. 
Ashland Trails Project Draft DN and FONSI 

12

MODIFIED ALTERNATVE 3 RESPONDING TO THE RELEVANT ISSUES 

Issues and concerns were raised by the public and Interdisciplinary Team members during the 

development of this project. In response, the EA (Section 1.8.1, page 1-17) identified four relevant 

issues: 1) potential effects on water quality due to erosion and sediment delivery, 2) potential effects 

on late-successional reserves (LSR), 3) potential effects to northern spotted owls and their habitat, 

and 4) potential effects on Pacific fisher and their habitat. 

The following further describes my rationale for selecting Modified Alternative 3, and the response 

of my decision to these issues, based on my weighing of the pros and cons of each alternative 

considered in detail. My decision is based on components that were analyzed in the EA, primarily 

those associated with Alternative 3. My decision modifies the extent of consequences predicted for 

Alternative 3. The overall effect of my decision to select and implement a Modified Alternative 3 

will result in effects that are equal to or less than those described for Alternative 3 in the EA. 

Relevant Issue 1: Potential effects on water quality due to erosion and sediment delivery 

Detailed discussions about this relevant issue can be found in EA Section 3.3.1, pages 3-16 to 3-38. 

New trail construction under Modified Alternative 3 will require eight new stream crossings (5 fewer 

than the Alternative 2 and the same as Alternative 3), all of which will occur over intermittent 

streams. Trail decommissioning under this modified alternative will remove 12 crossings (including 

four on perennial streams), which will be seven more than Alternative 2 and the same as Alternative 

3 and will result in a net decrease of four stream crossings in the action area. All new and previously 

unapproved stream crossings added to the system under Modified Alternative 3 will be designed to 

reduce sediment discharge potential, which could reduce load allocations to streams compared to 

Alternative 1. 

The results of the Water Erosion Prediction Project (WEPP) model predicted a net decrease in annual 

sediment delivery of 12% under Modified Alternative 3 compared to Alternative 1. This decrease 

will move the Ashland watershed towards meeting the total maximum daily load (TMDL) target for 

reduced sediment loading, and will represent an improvement compared to both Alternative 1 and 

Alternative 2. 

Similar to Alternative 3, Modified Alternative 3 will have only minor effects on water quality in the 

analysis area, including impacts to the City’s domestic water source. In areas where previously 

unapproved trails cross streams, water quality conditions may improve slightly because these 

crossing will be designed and maintained in accordance with Forest Service guidelines. As a result, 

the effects of Modified Alternative 3 on the quality of the City’s domestic water source will be 

minimal, and may be slightly reduced compared to Alternatives 1 and 2 (because the number of 

perennial stream crossings will be reduced). 

Relevant Issue 2: Potential effects on late-successional reserves (LSR) 

Detailed discussions about this relevant issue can be found in EA Section 3.3.2, pages 3-39 to 3-52. 
Ashland Trails Project Draft DN and FONSI 

13

Modified Alternative 3 will result in authorization of 24.9 miles of new System Trails, including 9.2 

miles of existing unapproved trails, 8.3 miles of existing historic trails, and 7.4 miles of newly 

constructed trails, and will decommission 9.9 miles of existing unsustainable or undesirable trails in 

the action area. Many of the existing unapproved trails and portions of those proposed for new 

construction (e.g., Shaken) exist as old logging roads or fire lines. These trails account for 

approximately 12.5 acres (6 foot trail clearance) of existing habitat already modified within the LSR 

to some degree. New trail construction, in large part intended to re-route existing unapproved or 

historic trails to minimize resource damage (e.g., Upper Time Warp, Red Queen, Jabberwocky, Alice 

in Wonderland), will impact approximately 5.4 acres. Trail decommissioning will impact 7.2 acres. 

In total, Modified Alternative 3 will result in a net decrease of 1.8 acres of long-term habitat 

modification. 

Trail densities under Modified Alternative 3 will be range from 0.04 to 1.5 miles per square mile 

within the five affected watersheds. 

Minimal vegetation removal will be required for new trail construction (limited to 6 foot clearance 

width), and large down wood greater than 6 inches diameter-at-breast height (dbh) will be avoided 

during trail layout and construction where possible (although, over time, trail maintenance may 

require that sections of fallen trees be removed from the width of the trail tread and placed to the side 

of the trail). The impact of habitats modified by trail construction will most directly affect latesuccessional habitat-related small mammals, birds, and invertebrates associated with understory 

vegetation and the forest floor. As described in the analysis of effects for Alternative 3, the total 

amount of trail clearance under Modified Alternative 3 will occur within less than 0.1% of the entire 

northern portion of the LSR. 

Modified Alternative 3 will include the existing 543 acres of disturbance associated with exiting 

unapproved and historic trails in the action area. New trail construction will result in an additional 76 

acres of disturbance, although the effects of this disturbance will be reduced during trail 

decommissioning activities (which will affect 235 acres). In total, Modified Alternative 3 will result 

in 384 acres of long-term disturbance (or approximately 7% of late-successional and large midsuccessional habitat within the Rogue River-Siskiyou National Forest portion of the LSR and less 

than 4% of the late-successional habitat in the entire LSR). This disturbance will be less than the 711 

acres of disturbance associate with Alternative 1, 784 acres of disturbance under Alternative 2 and 

552 acres of disturbance under Alternative 3. 

Modified Alternative 3 addresses existing resource damage and disturbance to late-successional 

species by re-routing trails to locations with less or no impact, and rehabilitating or closing problem 

trail segments. The mileage of trails that will be decommissioned under this alternative will reduce 

the overall amount of disturbance within the LSR when compared to Alternatives 1, 2 and 3. For 

these reasons, the effects of Modified Alternative 3 are expected to be neutral to LSR values. 

Relevant Issue 3: Potential effects on northern spotted owls and their habitat 

Detailed discussions about this relevant issue can be found in EA Section 3.3.3, pages 3-52 to 3-69. 
Ashland Trails Project Draft DN and FONSI 

14

Modified Alternative 3 will result in minimal direct impacts to northern spotted owl habitat. The 

Winburn Trap trail will not be authorized for recreational use under this alternative, which will 

remove ongoing disturbance to known owl nest sites in the vicinity and reduce impacts to spotted 

owls compared to Alternatives 1 and 2. 

As with Alternative 3, considering trail decommissioning, there will be no net increase in trail 

mileage from new construction or authorization of existing trails within any owl home ranges under 

Modified Alternative 3. Decommissioning of the Winburn Trap trail will occur within the Lightning 

Strike and Ski core areas. Authorization of the historic Wagner Glade trail will include 0.3 miles in 

the Lightning Strike core area. The 0.5 mile of new construction in the Ski core area will be 

associated with the proposed reroute of a 0.4 mile portion of the historic Upper Time Warp trail to be 

decommissioned in the Ski nest patch. Existing nesting, roosting, and foraging (NRF) and dispersal 

habitat that overlaps new trail construction will be maintained. 

Modified Alternative 3 will remove potential disturbance within the nest patches of all known owl 

sites and result in no net increase in disturbance within core areas, except for a very small amount 

within the Lightning Strike core area. At the home range scale, the mileage and acreage of trails to be 

decommissioned under Modified Alternative 3 will result in a reduction in disturbance for all 

affected owl sites. As a result, the direct and indirect effects of Modified Alternative 3 on spotted 

owls and their prey will be neutral and potentially beneficial, with an overall reduction in the amount 

of habitat disturbance from recreational use. 

Because the effects of Modified Alternative 3 are similar or slightly less than Alternative 3 through 

the reduction of overall trail mileage, it is anticipated that Modified Alternative 3 “may affect and is 

not likely to adversely affect” northern spotted owls because habitat will be maintained by new trail 

construction and there will be no net gain (and in some cases a reduction in disturbance acres) for all 

spotted owl home ranges, core areas and nest patches. This finding is consistent with the Letter of 

Concurrence (LOC) provided by the U.S. Fish and Wildlife Service (USFWS) for the proposed 

action. 

Relevant Issue 4: Potential effects on Pacific fisher and their habitat 

Detailed discussions about this relevant issue can be found in EA Section 3.3.4, pages 3-69 to 3-78. 

Trail clearance under Modified Alternative 3 will involve approximately 4.1 acres of denning/resting 

habitat and 8.1 acres of foraging/dispersal habitat for fishers within the action area. New trail 

construction and the incorporation of existing historic and unapproved trails as System Trails under 

this alternative will require very little vegetation change and large snags, large woody debris or trees 

with large mistletoe brooms will not be removed. New trail construction will affect less 

denning/resting habitat and 1.5 acres more foraging/dispersal habitat than will be recovered by trail 

decommissioning. This will represent less than 0.1% of these habitats available in the LSR. 

Approximately 383 acres of denning/resting habitat and 239 acres of foraging/dispersal habitat are 

within the 100 meter disturbance buffer of existing historic and unapproved trails that will be 

authorized as System Trails under this alternative. In fact, decommissioning will reduce the overall 

amount of disturbance from existing historic and unapproved trails to 318 acres. However, there will 
Ashland Trails Project Draft DN and FONSI 

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be a 67 acre net gain in disturbance of foraging and dispersal habitat due to new trail construction, 

which may result in avoidance of this habitat by fishers when recreational use is high. This increase 

represents approximately 0.1% of foraging/dispersal habitat within the LSR. 

Some trails proposed for construction under Alternative 2 that would be located within known fisher 

home ranges were removed from Alternative 3 and Modified Alternative 3. This and the additional 

trails to be decommissioned will result in a reduction in the amount of denning/resting habitat 

disturbed. Overall, when compared to Alternatives 1, 2 and 3, Modified Alternative 3 will result in a 

considerable reduction in disturbance acres to Pacific fisher habitats. 

The additional 67 acres of disturbance in foraging/dispersal habitat from new trail construction may 

result in localized effects on fishers, although, overall, Modified Alternative 3 will result in a 

reduction in habitat disturbance compared to Alternatives 1, 2 and 3. Therefore, as with Alternative 

3, Modified Alternative 3 “may impact individuals or habitat, but will not likely contribute to a trend 

towards Federal listing or cause a loss of viability to the local population (Siskiyou Mountains) or 

species” for Pacific fisher. 

OTHER ISSUES CONSIDERED

Other issues not described in detail in this decision but which were considered in my analysis 

included: 

 Potential effects on Forest Service sensitive species, management indicator species, 

Northwest Forest Plan (NWFP) survey and manage species, migratory birds, and other 

sensitive terrestrial species. 

 Potential effects on soils 

 Potential effects on geologic slope stability 

 Potential effects on streams and wetlands 

 Attainment of Aquatic Conservation Strategy Objectives 

 Potential effects on aquatic species and habitats 

 Potential effects on public recreational fishery access 

 Potential effects on the McDonald Peak Botanical Area 

 Potential effects on federally-listed, Forest Service sensitive, NWFP Survey and Manage 

Species, or locally rare species of vascular plants, bryophytes, lichens, or fungi 

 Introduction of non-native invasive plant species 

 Potential effects on the McDonald Peak IRA or potential wilderness areas 

 Potential effects on cultural resources and/or American Indian access and use 

 Increased risk of fire 

Detailed discussions about these other issues can be found in the EA, Section 3.4, pages 3-79 to 3-

177. The overall effect of my decision to select and implement a Modified Alternative 3 will result in 

effects that are equal to or less than those described for Alternative 3 in the EA. 
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RESOURCE PROTECTION MEASURES, MONITORING, AND ENFORCEMENT 

In order to minimize potential resource impacts from project activities, project design criteria (PDC) 

have been incorporated into the selected alternative. Project design criteria are devised in the preanalysis and analysis phases to reduce environmental impacts and comply with applicable laws and 

regulations. They include, but are not limited to; best management practices (BMPs), standards and 

guidelines (S&Gs) and standard operating procedures (SOPs). 

Use of the trails will be monitored to determine if they are meeting the objectives of Modified 

Alternative 3. Monitoring activities will include annual field visits by Forest Service recreation 

specialists and resource specialists to determine if user conflicts are occurring or if resource impacts 

are occurring to soils, water resources, vegetation, wildlife, or other sensitive resources, and to 

determine if new unauthorized trails are being constructed. If necessary, administrative changes may 

be made to the trail system or designated managed uses on trails to reduce user conflict or to improve 

the recreational experience. 

Under all alternatives, the Forest Service will continue to enforce managed uses within the action 

area consistent with the Rogue River Land and Resource Management Plan (LRMP), implementing 

regulations, and other guidance. The following Closure Orders specifically apply to recreation uses 

within the action area. The enforcement of these closure orders is generally reflected as PDC GEN12 in Table 4 below. 

 Order No. RSF-101 – Use of Vehicles Off National Forest System Roads – Rogue RiverSiskiyou National Forest. This order prohibits use of vehicles, including non-motorized 

vehicles, off Forest Development Roads within the Ashland Watershed, as well as use of 

motorized vehicles on Forest Development Roads and segments within the Ashland 

Watershed when the road or segment is posted closed to such vehicles. This order includes an 

exemption to allow bicycle use on Forest Service trails posted open to bicycle use. 

 Order No. RRF-002 – Fire and Occupancy and Use. This order prohibits building, 

maintaining, attending or using a fire, campfire, or stove fire in the Ashland watershed and 

general vicinity. It also prohibits camping in the Ashland watershed and general vicinity. 

Table 4 illustrates the PDC and mitigation measures that are incorporated into Modified Alternative 

3. 
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Table 4- Project Design Criteria and Mitigation Measures 

No. Project Design Criteria and Mitigation Measures

General

GEN-1 The exact location of the trail may be refined in the field to accommodate topography, soils, available materials, degree of trail difficulty, and to 

avoid sensitive areas, such as seeps, springs, and sensitive plant and wildlife species.

GEN-2 All trails will be constructed to minimize erosion, avoid natural water courses, and avoid sensitive riparian areas and plants to the extent possible.

GEN-3 All trails will be designed to minimize sustained steep pitches, grade reversals, and to reduce the chance for water to gain enough speed to recruit 

and encourage erosion. Rock needed for trail stabilization, sediment traps, and erosion control will be from on-site sources.

GEN-4 Forest clearing in the proposed trail corridors will be reduced to the extent practical through careful trail design and layout.

GEN-5 All trails will be laid out to avoid removal of trees with a diameter-at-breast height (dbh) greater than 6 inches. Coarse woody debris greater than 

6 inches dbh will not be moved, but will have the portion on the trail tread cut to the width of the tread and placed to the side of the trail.

GEN-6 Trail tread will be cleared of all organic material down to mineral soil. When practical, all removed vegetation will be used to revegetate off-trail 

disturbed areas.

GEN-7 Perennial waters will be avoided or spanned by bridges or similar man-made features, where necessary, based on the width of the crossing, use 

level, type of use, and stream flow. Bridges, if necessary, will be built using a combination of treated and untreated wood or steel and composite

materials. Any use of treated wood will be in accordance with Western Wood Preserves Institute Best Management Practices for the Use of 

Treated Wood in Aquatic and Wetland Environments (WWPI 2011).

GEN-8 Intermittent waters will be crossed by hard fords as necessary.

GEN-9 Revegetation, where applicable, may include topsoil replacement, planting, and seeding, and will occur in accordance with Forest Service 

botanist prescriptions.

GEN-10 All trails will be signed with uses that are excluded, and all multiuse trails will be signed with trail etiquette guidelines to reduce user conflict.

GEN-11 All trails, with the exception of Split Rock Way, will be designed to Trail Class 2 standards, as provided in as provided in the Trails Management 

Handbook (FSH 2309.18).

GEN-12 Trail use will be monitored to determine if it is consistent with the managed uses identified for each trail. Closure orders, including user 

restrictions, may be issued and enforced by Forest Service law enforcement officers if it is determined managed uses are not being adhered to. 
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No. Project Design Criteria and Mitigation Measures

Water Quality

WQ-1 Stream crossing approaches on both new and reconstructed trails will be designed to minimize sedimentation by reducing diversion potential; 

avoiding deeply incised streams with steep side slopes; using native rock sources to armor approaches on soils with a high erosion rating; and 

avoiding long approaches that allow water to concentrate, erode trail tread and deliver fine sediment.

WQ-2 All trail stream crossings will meet the following to the extent practicable: (1) contain little to no fine fill material; (2) provide for unrestricted 

stream flows; and (2) avoid stream capture. Stream crossings that must use conveyance structures, such as culverts, will be inspected yearly and 

maintained when needed. 

WQ-3 Legacy sediment sources, such as gullies, head cuts, and fill material in stream crossings, that are associated with existing historic or unapproved 

trails in the action area will have stabilization techniques applied during trail reconstruction or decommissioning. If trails are re-routed to avoid 

these areas, stabilization techniques will be applied during the decommissioning process. Example of stabilization techniques include water bars, 

check dams, waddles, fill and culvert removal, and planting and seeding.

WQ-4 Existing historic and unapproved trail segments proposed for decommissioning will be recontoured where needed to eliminate erosion. All fill 

will be removed from channels and stream banks will be recontoured to mimic the upstream and downstream banks to the extent possible. 

Adjacent duff or litter will be moved to cover trail tread and the trail will be obscured by placing branches and small diameter course wood.

WQ-5 During trail maintenance, reconstruction, and decommissioning, all displaced soil or fill materials will be placed in locations where they are 

unlikely to be discharged to streams, to the extent practicable.

WQ-6 Signs will be installed at the White Rabbit and Four Corners trailheads providing guidance to trail users on the proper disposal of pet and human 

waste. The signs will indicate that all waste must either be removed using a disposal waste bag, or buried. In all cases, buried waste must be 

located at least 200 feet from any waterbody and buried at least 6 inches deep.

WQ-7 All gas powered equipment used for trail construction, re-construction, and maintenance will be refueled at least 150 feet from all watercourses 

(intermittent and perennial).

WQ-8 Trail conditions will be monitored in the wet months for excessive rutting, erosion, or sediment delivery to streams. As necessary, additional 

erosion control devices may be employed locally to address these conditions, and/or the trail may be closed seasonally to mitigate short-term 

impacts.

Soils and Slope Stability

GEO-1 Additional consultation by a geologist or soil scientist will be completed during trail design and layout when any of the following landscape 

characteristics are found in the vicinity of a proposed alignment. Field review will be used to inform adjustments to segment locations to avoid 

potentially high risk slope failure areas.

 Slope aspect. Northerly and easterly aspects that tend to hold more water on site longer and have developed deeper soil / decomposed 

granitics layers.
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No. Project Design Criteria and Mitigation Measures

 Slope shape. Concave slopes that concentrate surface and ground water, and/or are characterized by deeper soil / decomposed granitics 

layers.

 Position of trail on the slope. Trail locations at or near obvious changes in slope gradient (which are typically inherently less stable). Trails on 

lower slope positions where there is potential for higher ground water flows.

 Slope gradient. Trails being proposed on slopes of 75% or greater, or trails on slopes between approximately 50% and 75%.

 Slope complexity. Simple slope complexity (smooth linear or curvilinear slopes) that have no complex topography to slow and catch soil 

movement, such that a failure would flow directly to stream channels.

 Stream/draw crossings. Multiple crossings of individual drainages.

 Trail concentration. Multiple trail segments on an individual slope.

Aquatic Resources

AQ-1 A fisheries specialist will be consulted prior to constructing any stream crossings on fish-bearing streams. 

Botanical Resources and Invasive Plants

BOT-2 The Split Rock Trail in the McDonald Peak vicinity will be located to avoid the known population of Howell’s tauschia. 

BOT-5 The Forest Service will periodically monitor the first 1⁄2 mile of the Upper Time Warp trail from its start point on the crest to make sure 

recreational users trying to avoid lingering snowfields on the trail do not create braided routes and/or unduly disturb populations of Henderson’s 

horkelia or Mt. Ashland lupine (Lupinus aridus ssp. ashlandensis). Preventive measures, such as an early season closure or awareness signs, will 

be considered if warranted.

BOT-7 Two clustered ladyslipper orchid occurrences will be flagged for avoidance prior to decommissioning activities along the Reservoir Trail to 

ensure they are not trampled or otherwise damaged by construction activities. 

BOT-8 The patch of three-toothed horkelia (Horkelia tridentate) on the section of the Winburn Trap Trail proposed for decommissioning will be marked 

for avoidance prior to decommissioning activities to ensure it is not trampled or otherwise damaged by construction activities. 

BOT-9 The three-toothed horkelia population occupying the old spur road in the SE 1⁄4 of the NE 1⁄4 of section 28 will be protected to extent practical by 

narrowing and confining the trend width, so that trail edge plants can survive when the old roadbed, currently unused, becomes part of Lower 

Marty’s Trail. 

BOT-10 All proposed new trails not specifically mentioned above and authorized for construction will be surveyed for Forest Service Sensitive and NWFP 

Survey and Manage vascular plants and bryophytes once routes are flagged but before trail construction begins. If Forest Service Sensitive or 

Survey and Manage species, or other species of local concern, are found, trails will be re-flagged/re-routed to the extent necessary to avoid 

impacting the viability of local populations. 
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No. Project Design Criteria and Mitigation Measures

BOT-11 New trails will be re-routed, where practical, prior to construction if invasive plants are found to be in the path of proposed new trails and there is 

concern that trail construction and trail use will lead to spread or expansion of the invasive plant population.

BOT-12 If new trails must be constructed through known invasive plant sites, or if ground-disturbing trail decommissioning or restoration activities must 

occur in infested areas, workers will be required to clean tools, clothing, and equipment, before moving beyond the infested area.

BOT-13 Before beginning construction of any new trails, workers will be required to check tools, clothing, and equipment for soil or seeds of invasive 

plants, and clean these items off-Forest or at roadside if contaminated.

Cultural Resources

CUL-1 A qualified cultural resource specialist will review any changes in the design and location of trail reroutes that may become necessary during 

implementation due to unforeseen circumstances prior to construction.

CUL-2 A qualified cultural resources specialist will monitor construction of all trail segments where significant cultural resources are known to the 

vicinity.

CUL-3 If cultural materials are discovered during ground-disturbing activities, all work in that area will stop and the Forest Archaeologist will be 

contacted to determine the appropriate course of action. The proposed work may not resume in that area until the Forest Archaeologist determines 

that the activity will not cause an adverse effect to significant cultural resources.
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OTHER ALTERNATIVES CONSIDERED

In addition to Alternative 3 – Preferred Alternative, two alternatives (Alternative 1 – No Action and 

Alternative 2 – Proposed Action) were considered in the environmental assessment. Two additional 

alternatives were considered but eliminated from detailed study because they did not meet the 

purpose and need and were not feasible to implement (EA, CH. 2.6 pgs. 2-34 to 2-36). The 

alternatives described below were analyzed in detail. 

Alternative 1- No Action (EA, Ch. 2.3.1 pg. 2-10 to 2-11) 

Alternative 1 (No Action) provides a baseline from which to analyze the effects of the action 

alternatives. Under Alternative 1, the Forest Service would continue to manage System Trails in the 

action area in accordance with current management plans and FSH 2309.18. No new trails would be 

constructed, and existing historic and unapproved trails would not be incorporated as System Trails. 

The Forest Service would also continue to discourage use and proliferation of unapproved trails 

through monitoring and enforcement of managed uses within the action area. However, because it is 

uncertain how many of existing historic or existing unapproved trails could effectively be removed in 

the short term, and in consideration of the numerous unsuccessful attempts by the Forest Service to 

close these trails, the EA conservatively assumed that no trails would be removed or decommissioned 

under Alternative 1, and that impacts associated with their continued use would continue. 

In total, 15.8 miles of System Trails and 25.6 miles of existing historic and unapproved trails would 

remain in the action area under Alternative 1. 

Due to resource impacts associated with soils, water quality, and wildlife, this alternative does not 

meet the purpose of the proposed action to provide an adequate and sustainable trail system that 

minimizes impacts to soil, water, cultural, vegetation, and wildlife resources and discourages 

unauthorized trail proliferation. 

Alternative 2- Proposed Action (EA, Ch. 2.32 pg. 2-11 to 2-12) 

Alternative 2 reflects the trail design proposed by the Forest Service during public scoping. This 

alternative was designed to meet the purpose and need of the proposed action, and reflects many of 

the aspects of the Trails Master Plan submitted by AWTA in 2011. 

Approximately 31.41 miles of trails would be incorporated into the approved trail network in the 

action area under this alternative, including about 22.0 miles of existing historic and unapproved 

trails and 9.4 miles of new proposed trails. A total of 5.2 miles of existing historic and unapproved 

trails would be decommissioned under this alternative. 

I have decided not to select Alternative 2 due to impacts to LSRs (net increase of 73 acres of 

disturbance), northern spotted owls and their habitat (associated with the Windburn Trap and Upper 

Time Warp trails), impacts to Pacific fisher and their habitat (associated with the Rip 1, Freak Went 

 

1

 Mileage total reflects an additional .5 mile of the proposed Jabberwocky reroute which was inadvertently not included in the 

Alternative 2 total mileage in the EA. 
Ashland Trails Project Draft DN and FONSI 

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Flyer, Not Stirred and Shaken trails), and potential water quality concerns (associated with the 

Windburn Trap trail). 

PUBLIC INVOLVEMENT 

In June 2012, the Forest Service published a legal notice notifying the public of the opportunity to 

comment on the Ashland Trails Project. The public scoping period opened on June 13, 2012 and 

closed on July 27, 2012. Letters were sent out to agencies and interested groups and citizens 

explaining the background, purpose and need, and preliminary details and design features of the 

proposed action, and requesting comments, concerns or issues specific to the Ashland Trails Project 

be provided to the Forest Service. 

Thirty-two comment letters were received during the scoping period. A copy of the Scoping Report, 

which summarizes the comments received during the scoping period, is provided as Appendix A of 

the EA. 

Copies of the December 2014 Ashland Trails Project Environmental Assessment (EA) and 

Appendices, along with an invitation to comment, were mailed to those individuals and organizations 

involved with the proposed action or who had requested a copy of the EA. Legal Notices were 

published in the Medford Mail Tribune on December 29, 2014 and January 7, 2015. The notices 

established a comment period under 36 Code of Federal Regulations (CFR) 215. The comment 

period began on December 29, 2014 and ended February 6, 2015, a period of 38 days. During the 

comment period, the Forest Service received 119 comment letters. Comments were provided on 

various topics, some expressed concern while others provided support or recommendations. 

Responses to substantive comments are included as an attachment to this Draft DN and FONSI. All 

comments submitted during the planning process have been considered. 

On January 8, 2015 an open house style meeting was held at the Ashland Public Library with Forest 

Service resource specialists on hand to answer questions about the project from the public. Over 160 

individuals attended the meeting. 

FINDING OF NO SIGNIFICANT IMPACT

I have reviewed the EA and associated documents and believe there is adequate information within 

the project record to provide a reasoned choice of action. Implementing the selected alternative with 

the specified management requirements, constraints, and mitigation measures will cause no 

unacceptable cumulative impacts to any resource. 

After considering the environmental effects described in the EA (EA pg. 3-1 to 3-177), I have 

determined that these actions will not have a significant effect on the quality of the human 

environment considering the context and intensity of impacts (40 CFR 1508.27); therefore, an 

environmental impact statement is not needed. I base my finding on the following: 

1. Impacts that may be both beneficial and adverse are discussed in the EA (EA Ch. 3 pg. 3-1 to 

3-177). These impacts are within the range of the Forest Plan and will not have significant 

impacts on resources identified and described in Chapter 3 of the EA. The selected 
Ashland Trails Project Draft DN and FONSI 

23

alternative (Modified Alternative 3) provides the best combination of physical, biological, 

social and economic benefits. 

2. There will be no significant effects on public health and safety. There may be a need to 

temporarily close a section of an existing trail during new trail construction, but it is not 

anticipated to impact public safety. 

3. There will be no significant impacts to unique characteristics of geographic areas such as 

cultural resources, park lands, prime farmlands, wetlands, old growth forest, range land, 

research natural areas, experimental forests, inventoried roadless areas or other ecologically 

critical areas (EA pg. 1-13, 3-164 to 3-168, 3-177 to 3-183). 

4. Base on public participation and analysis in the EA, the effects on the quality of the human 

environment are not likely to be highly controversial (EA Ch. 3 pg. 3-1 to 3-15). There is no 

known credible scientific controversy over the impacts of the project. Although there are 

sometimes competing interests surrounding recreation, the conclusions of effects were not 

shown to have any scientific controversy. 

5. There are no known effects on the human environment that are highly uncertain or involve 

unique or unknown risks associated with this project. Trail construction is common practice 

and the effects are well known. The EA effectively addresses and analyzes the environmental 

impacts associated with the project and incorporates well-established best management 

practices to minimize negative impacts (EA Ch. 2 pg. 2-30 to 2-33). 

6. These actions pose no disproportionately high or adverse human health or environmental 

effects, including social and economic effects, on minority or low-income populations 

(FONSI Element 2). This project has shared the Federal government’s overall trust 

responsibility to Indian tribes where treaty or other legally defined rights pally to National 

Forest System lands. Consultation with the Confederate Tribes of the Siletz Indians of 

Oregon, the Confederated Tribes of the Grande Ronde Community of Oregon and the Quartz 

Valley Indian Reservation has occurred. Consultation has incorporated opportunities for 

tribal comments and contributions to the proposed project (EA Ch. 3 pg. 3-173). 

7. This action is not likely to establish a precedent for future actions that may be implemented 

to meet the goals and objectives of the Rogue River National Forest Land and Resource 

Management Plan and the Klamath National Forest Land and Resource Management Plan. 

This project is consistent with management direction set forth by the Forest Plans (EA Ch. 1 

pg. 1-11 to 1-13). 

8. There are no known significant adverse, cumulative, or secondary effects between this 

project and other projects (completed, active, or planned). Effects to the basic resource values 

of soil, water, fish, plants, and wildlife are estimated and determined to be localized, limited, 

or small in scale (EA Ch. 3 pg. 3-15 to 3-164). This determination is based on the results of 

cumulative effects analysis discussed in the EA. 

9. Based on the cultural resource inventory and report, there will be no effect on historic 

properties under the terms of the Programmatic Agreement between the Advisory Council on 

Historic Preservation (ACHP), the Oregon State Historic Preservation Officer (SHPO) and 

Region 6 of the Forest Service. All significant and unevaluated archaeological sites will be 

avoided under Alternative 3. PDC CUL-1 through CUL-3 will be implemented to reduce the 
Ashland Trails Project Draft DN and FONSI 

24

potential for impacts to both known resources and any new resources that may be discovered 

during construction. 

10. The biological evaluation for plant species proposed, endangered, threatened or sensitive 

determines that through the implementation of PDC BOT- 5 through BOT-13, impacts to 

these species will be minimized and will not be likely to adversely affect the viability of the 

local or regional populations or the species as a whole (EA Ch. 3 pg. 3-149 to 3- 164, 

Biological Evaluation located in the project record). 

A biological evaluation for wildlife species proposed, endangered, threatened or sensitive has 

been prepared and located in the project record. Analysis of wildlife species indicates that 

this project “may affect and is not likely to adversely affect” northern spotted owls or their 

critical habitat. For or Pacific Fisher, the project “may impact individuals or habitat, but will 

not likely contribute to a trend towards Federal listing or cause a loss of viability to the local 

population (Siskiyou Mountains) or species” (EA Ch. 3 pg. 3-52 to 3-78, Biological 

Evaluation located in the project record). 

The proposed action is consistent with the LRMP, as amended by the 2001 Record of 

Decision for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation 

Measures Standards and Guidelines in Forest Service and Bureau of Land Management 

Planning Documents within the Range of the Northern Spotted Owl (USDA and USDI 

2001b), using the 2001 Survey and Manage species list and survey requirements described in 

the most recent survey protocols for each species (and reflecting modifications resulting from 

a 2011 Settlement Agreement) . Surveys were not triggered for any Survey and Manage 

vertebrate or non-vertebrate animal species by the proposed action, as documented in the 

Wildlife Biological Evaluation and Specialist Report for the proposed action. Management 

recommendations for the known sites of Chace sideband within the action area will be 

implemented to maintain suitable habitat (EA Ch. 3 pg. 3-79 to 3-112). 

11. The actions described for this project in the EA do not threaten a violation of Federal, State, 

or local law or requirements imposed for the protection of the environment. Applicable laws 

and regulations were considered in the EA (EA Ch. 1 pg. 1-4, 1-11 to 1-16) and this project is 

consistent with the Rogue River and Klamath National Forest Land and Resource 

Management Plans as amended. 

There are no commitments of resources that cannot be regained such as the extinction of a species or 

the removal of mined ore. There are no irreversible commitments of resources. Irretrievable 

commitments are those that are lost for a period of time such as the temporary loss of timber 

productivity in forested areas that are kept clear for use as a power line right-of-way or road. The 

development and use of the trails and trailhead are considered irretrievable commitment of land to a 

non-vegetative state until such time that the path is abandoned and the disturbed sites are returned 

back to productive capacity. 

This decision is made with consideration of past, present and reasonably foreseeable future actions 

on National Forest lands and other ownerships within potentially affected areas which could have a 

cumulatively significant effect on the quality of the human and natural environment. 
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LEGAL REQUIREMENTS AND POLICY 

In reviewing the EA and actions associated with the modified version of Alternative 3, I have 

concluded that my decision is consistent with the following laws and requirements. 

The National Environmental Policy Act (NEPA) 

NEPA establishes the format and content requirements of environmental analysis and documentation 

as well as requirements for public involvement and disclosure. The entire process of preparing this 

EA was undertaken to comply with NEPA (EA Ch. 1 pg. 1-1). 

The National Forest Management Act (NFMA) 

I find this decision to be consistent with the long term management objectives as discussed in the 

Rogue River and Klamath National Forest Land and Resource Management Plans as amended. All 

other Forest Plan direction, including from the Northwest Forest Plan and the Recreational 

Opportunity Spectrum has been adhered to and incorporated into the project’s design (EA Ch. 1 Pg. 

1-4, 1-11 to 1-116). 

The Preservation of American Antiquities Act of June 1906 and the National Historic 

Preservation Act: The Oregon State Historic State Historic Preservation Officer (SHPO) 

As noted in FONSI Element 9, a cultural resources inventory has been completed for the project area. 

Under the terms of the Programmatic Agreement between the Advisory Council on Historic 

Preservation (ACHP), the Oregon State Historic Preservation Officer (SHPO) and Region 6 of the 

Forest Service a determination was made of no effect on historic properties (EA Ch. 3 pg. 3-168 to 3-

176). 

The Endangered Species Act of 1973, as amended 

Biological Evaluations were prepared to document the possible effects of the proposed activities to 

threatened and endangered species within the project area. The selected alternative will not be likely 

to adversely affect the viability on proposed, endangered, threatened or sensitive plant species (EA 

Ch. 3 pg. 3-149 to 3- 164, Biological Evaluation and NWFP Survey and Manage Report located in 

the project record). The project “may affect and is not likely to adversely affect” northern spotted 

owls or their critical habitat. For Pacific Fisher, the project “may impact individuals or habitat, but 

will not likely contribute to a trend towards Federal listing or cause a loss of viability to the local 

population (Siskiyou Mountains) or species” (EA Ch. 3 pg. 3-52 to 3-78, Biological Evaluation and 

Specialist Report located in the project record). There will be no effect on listed fish species, fish 

habitat or Region 6 Sensitive species (EA Ch. 3 pg. 3-142 to 3-147). 

A Letter of Concurrence (Reference # 01EOFW00-2014-F-0032) from the U.S. Fish and Wildlife 

Service was received by the Forest on February 18th, 2014 which “reflects the Service’s finding that 

implementation of Alternative 3 of the Ashland Trails Project, as proposed by the Forest, is not likely 

to adversely affect the spotted owl or its critical habitat”. 
Ashland Trails Project Draft DN and FONSI 

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The Clean Water Act, 1982 and 303(d) 

The selected alternative will comply with the Clean Water Act. In compliance with the Clean Water 

Act, the Oregon Department of Environmental Quality lists several streams within in the project area 

as water quality impaired streams (303)(d) list). Table 3-5 in Ch. 3 pg. 3-19 to 3-20 lists the 

waterbodies within or downstream of the analysis area and what pollutant the stream is listed for. 

Management direction regarding 303(d) listed streams is that any project activity should not further 

degrade the parameters for which it is listed (Forest Service and Bureau of Land Management 

Protocol for addressing Clean Water Act Section 303(d) Waters). 

I find that the selected alternative will not compromise the quality of water sources (EA Ch. 3 pg. 3-

16 to 3-39). 

The Clean Air Act 

The selected alternative will comply with the Clean Air Act. The Act prescribes air quality to be 

regulated by each individual state. There are no smoke generating activities associated with the 

project (EA Ch. 3 pg. 3-178). 

Civil Rights and Environmental Justice 

Executive Order 12898 on environmental justice requires federal agencies to identify and address any 

disproportionately high and adverse human health or environmental effects on minority and low 

income populations. The analysis focuses on potential effects from the project to minority 

populations, disable persons, and low-income groups. 

After evaluating the discussion in the EA Ch.3, pages 3-179 to 3-183, I have determined that there 

will no discernable impacts from any of the alternatives on Native Americans, women, other 

minorities, or the Civil Rights of any American citizen. 

PRE-DECISIONAL ADMINISTRATIVE REVIEW PROCESS 

The Ashland Trails Project record is on file at the Siskiyou Mountains Ranger District, Star Ranger 

Station at 6941 Upper Applegate Road, Jacksonville, Oregon, 97530. This project is subject to predecisional administrative review pursuant to 36 CFR 218, Subpart B. Also called the “objection 

process” the pre-decisional review process replaced the appeal process (36 CRF 215) in March 2013. 

The primary difference with the objection process is that a person may object to a project prior to the 

final decision, whereas under the appeal process, appeals were made after the decision. The full text 

of the rule can be found here: http://federal.eregulations.us/cfr/title36.part218.

Only individuals or organizations that submitted specific written or oral comments (36 CFR 218.2) 

during a designated opportunity for public participation (scoping or the public comment period) may 

object (36 CFR 218.5). Notice of objection must meet the requirements of 36 CFR 218.2. Objections 

can be submitted in writing, either electronically or in hard copy, but must be filed with the 

Reviewing Officer within 45 days following the publication date of the legal notice of the 

opportunity to object in the Mail Tribune, Medford, Oregon. The publication date of the legal notice 

is the exclusive means for calculating the time to file an objection. Those wishing to file an objection 
Ashland Trails Project Draft DN and FONSI 

27

to this draft decision should not rely upon dates or timeframe information provided by any other 

source. Objections sent by mail must be received before the close of the fifth business day after the 

objection filing period. 

Incorporation of documents by reference is not allowed, except for the following list of items that 

may be referenced by including date, page, and section of the cited document, along with a 

description of its content and applicability to the objection: 1) all or any part of a federal law or 

regulation; 2) Forest Service directives and land management plans; 3) documents referenced by the 

Forest Service in the subject EA; or 4) comments previously provided to the Forest Service by the 

objector during public involvement opportunities for the proposed project where written comments 

were requested by the Responsible Official. All other documents must be included with the objection 

(36 CFR 218.8(b)). 

Issues raised in objections must be based on previously submitted specific written comments 

regarding the proposed project or activity and attributed to the objector, unless the issue is based on 

new information that arose after the opportunities to comment. The burden is on the objector to 

demonstrate compliance with the requirement for objection issues 36 CFR 218.8(c). 

Minimum requirements of an objection are described at 218.8(d). An objection must include a 

description of those aspects of the proposed project addressed by the objection, including specific 

issues related to the proposed project; if applicable, how the objector believes the environmental 

analysis or draft decision specifically violates law, regulation, or policy; suggested remedies that 

would resolve the objection; supporting reasons for the reviewing officer to consider; and a statement 

that demonstrates the connection between prior specific written comments on the particular proposed 

project or activity and the content of the objection, unless the objection concerns an issues that arose 

after the designated opportunities for comment. 

Objections may be: 

Postal Delivery: Reviewing Officer, Rogue River- Siskiyou National Forest, Attn: Rob MacWhorter, 

3040 Biddle Road, Medford, Oregon, 97504. 

Emailed to: objections-pnw-rogueriver-siskiyou@fs.fed.us. Please put OBJECTION and the project 

name in the subject line. Electronic objections must be submitted as part of an actual e-mail message, 

or as an attachment in Microsoft Word (.doc), rich text format (.rtf), or portable document format 

(.pdf) only. E-mails submitted to addresses other than the ones listed above or in formats other than 

those listed above or containing viruses will be rejected. It is the responsibility of the objector to 

confirm receipt of objections submitted by electronic mail. For electronically mailed objections, the 

sender should normally receive an automated electronic acknowledgement from the agency as 

confirmation of receipt. If the sender does not receive an automated acknowledgement of receipt, it is 

the sender’s responsibility to ensure timely receipt by other means; 

Hand deliveries: Rogue River- Siskiyou National Forest Supervisor’s Office, 3040 Biddle Road, 

Medford, Oregon, 97504. Hand deliveries can occur between 8:00 AM and 4:30 PM, Monday 

through Friday except legal holidays; or 
Ashland Trails Project Draft DN and FONSI 

28

Faxed to: Rogue River- Siskiyou National Forest Supervisor, Attn: Rob MacWhorter at (541) 618-

2400. 

IMPLEMENTATION 

Implementation of this project is expected to begin in the fall of 2015. If no objection is filed, 

implementation may begin on, but not before, the fifth business day following the close of the 45-day 

objection period. If an objection is filed, implementation may occur immediately following the date 

of the final decision. 

CONTACT AND GENERAL INFORMATION 

The Ashland Trails Project record is on file at the Siskiyou Mountains Ranger District office at 6941 

Upper Applegate Road, Jacksonville, Oregon 97530. The EA and decision are also available on the 

Rogue River- Siskiyou National Forest webpage at: http://www.fs.usda.gov/project/?project=39748

For additional information concerning the specific activities authorized with this draft decision you 

may contact: 

Brian Long, Project Leader, Recreation 

Siskiyou Mountains Ranger District 

6941 Upper Applegate Road 

Jacksonville, OR 97530 

(541) 899-3815 

RESPONSIBLE OFFICIAL 

The District Ranger of the Siskiyou Mountains Ranger District on the Rogue River- Siskiyou 

National Forest is the responsible official responsible for deciding the type and extent of 

management activities in the Ashland Trails Project area. 

Signature reserved for final decision 

 

DONNA M. MICKLEY Date 

District Ranger 

Siskiyou Mountains Ranger District 

Rogue River- Siskiyou National Forest 
Draft DN Attachment A Page A - 1 Ashland Trails Project 

Response to Comments

ASHLAND TRAILS PROJECT 

DRAFT DECISION NOTICE AND FINDING OF NO SIGNIFICANT 

IMPACT 

ATTACHMENT A 

Response to Comments

36 CFR 215 

NOTICE AND COMMENT (SECTIONS 215.3, 215.5, AND 215.6) 

Copies of the December 2014 Ashland Trails Project Environmental Assessment (EA) and 

Appendices, along with an invitation to comment, were mailed to those individuals and organizations 

involved with the proposed action or who had requested a copy of the EA. Legal Notices were 

published in the Medford Mail Tribune on December 29, 2014 and January 7, 2015. The notices 

established a comment period under 36 Code of Federal Regulations (CFR) 215. The comment 

period began on December 29, 2014 and ended February 6, 2015, a period of 38 days. 

A total of 119 comment letters and emails were received during the comment period. The comment 

letters were read and coded based on content and intent by a U.S. Forest Service (Forest Service) 

planning team, with District Ranger/Responsible Official oversight, review and concurrence. The 

original comment letters and emails reflecting the Forest Service review and coding are made a part 

of the Project Record (incorporated by reference) and are available upon request. Table 1 summarizes 

the name and organization of persons who commented on the EA and provides the reference number 

assigned to the comment letter. 

 Table 1. Summary List Persons and Organizations who Commented on the ATP EA

Ref # Name Organization

ATP-1 Barbara and Brian Comnes Private citizens 

ATP-2 Barbara and Brian Comnes Private citizens

ATP-3 Andrea Napoli Private citizen

ATP-4 Curt Evans Private citizen

ATP-5 Milo Shubat Private citizen

ATP-6 Scot Krupa Ashland Cycle Sport

ATP-7 Chris Herbst Private citizen

ATP-8 RVMBA Board Rogue Valley Mountain Bike Association

ATP-9 Drew Mebane Private citizen

ATP-10 Andrea Napoli Private citizen

ATP-11 Justin Adams Private citizen

ATP-12 Diana Aldridge Private citizen

ATP-13 Annette Parsons and Jim Clover Private citizens

ATP-14 Jeff LaLande Private citizen

ATP-15 Brian Kolodzinski Private citizen

ATP-16 Leslye Wing Private citizen
Draft DN Attachment A Page A - 2 Ashland Trails Project 

Response to Comments

Ref # Name Organization

ATP-17 Valeria Lantz Private citizen

ATP-18 Hope Robertson Private citizen

ATP-19 Shiela Timmons Private citizen

ATP-20 Vern Crawford Private citizen

ATP-21 Alice Levey Private citizen

ATP-22 Allan Goffe Private citizen

ATP-23 Kevin Talbert Private citizen

ATP-24 Trish Broersma Private citizen

ATP-25 Jamie Hutchinson Private citizen

ATP-26 Chrissy Maloney Private citizen

ATP-27 Kellie Hill The Right Plan Nutrition Counseling

ATP-28 Nathan Riddle Private citizen

ATP-29 Paula Weldon Private citizen

ATP-30 Jim Bowers Private citizen

ATP-31 Amy Patton Private citizen

ATP-32 Patrick Honsinger Private citizen

ATP-33 Suzanne O’Daly Private citizen

ATP-34 Birte Ferguson Private citizen

ATP-35 Russell Lancaster Private citizen

ATP-36 Tia Bodington Private citizen

ATP-37 Shira Cluff Private citizen

ATP-38 Carol Hearns Private citizen

ATP-39 Terry Canavello Private citizen

ATP-40 Amy Nangle Private citizen

ATP-41 Mike Conner Private citizen

ATP-42 Skyler Conner-Coash Private citizen

ATP-43 Maciej Simm Private citizen

ATP-44 Mike Stadnisky FlowJo, LLC / Private citizen

ATP-45 Elaine Bothe Private citizen

ATP-46 Duncan Coppedge Private citizen

ATP-47 Brian Roberts Private citizen

ATP-48 Casey Frieder Private citizen

ATP-49 Marina Borowy Private citizen

ATP-50 Robert Hodge Siskiyou Corp / Private citizen

ATP-51 Victor Chang Private citizen

ATP-52 Barbara Kozol Private citizen

ATP-53 Suzanne Quilter Private citizen

ATP-54 Duane Pierce Hild Collision Center / Private citizen

ATP-55 Jennifer Butler Private citizen

ATP-56 John Price Private citizen

ATP-57 Jeanine Moy Klamath-Siskiyou Wildlands Center (KS Wild) 
Draft DN Attachment A Page A - 3 Ashland Trails Project 

Response to Comments

Ref # Name Organization

ATP-58 Jana’ Hjelmervik Private citizen

ATP-59 Jeff Leever Private citizen

ATP-60 Selene Raffel Private citizen

ATP-61 Mark Phelps Private citizen

ATP-62 Kathy Caulfield Private citizen

ATP-63 Dave Caulfield Private citizen

ATP-64 Elisabeth Geismar Private citizen

ATP-65 Annette Brophy Private citizen

ATP-66 Joe Brophy Private citizen

ATP-67 Nathan Granados Southern Oregon Outdoor Program

ATP-68 Penney Reed Private citizen

ATP-69 Tiffany Hokanson Private citizen

ATP-70 Diana Aldridge Private citizen

ATP-71 Joni Davis Hankin Private citizen

ATP-72 Trish Broersma Private citizen

ATP-73 Karen Piper Private citizen

ATP-74 Della Merrill Private citizen

ATP-75 Kellie Kinkead Private citizen

ATP-76 Jennifer Jensen Private citizen

ATP-77 James Bowers Private citizen

ATP-78 Debbie Hansen-Bernard Private citizen

ATP-79 Jason Becker Private citizen

ATP-80 Eric Iversen Private citizen

ATP-81 Joy Trevey-Lowell Private citizen

ATP-82 Doug Heiken Oregon Wild

ATP-83 Diane Newell Meyer Private citizen

ATP-84 Adam Elson Private citizen

ATP-85 Christy Frenzen Private citizen

ATP-86 Christine Cook Private citizen

ATP-87 Joseph Vaile KS Wild

ATP-88 Tom Lowell Private citizen

ATP-89 Joseph Vaile KS Wild

ATP-90 John Ford Bear Creek Bicycle

ATP-91 Jeanine Moy KS Wild - Adopt a Botanical Area Program

ATP-92 Nancy Firth Private citizen

ATP-93 Elisabeth Geismar Private citizen

ATP-94 Rich Vanderwyst Private citizen

ATP-95 Bob Plummer Private citizen

ATP-96 John Firth Private citizen

ATP-97 Chris Chambers City of Ashland

ATP-98 Tom Pike Private citizen
Draft DN Attachment A Page A - 4 Ashland Trails Project 

Response to Comments

Ref # Name Organization

ATP-99 Michael Bronze Rogue Valley Mountain Bike Association

ATP-100 Joe and Sharon Mosley Private citizens

ATP-101 Jake Sawyer Private citizen

ATP-102 Marilyn Bailey Private citizen

ATP-103 Mary Kwart Private citizen

ATP-104 Dragonfly Richards Private citizen

ATP-105 Dave Richards Private citizen

ATP-106 Paul Rowland Private citizen

ATP-107 Zane Houshour Private citizen

ATP-108 AWTA Board Ashland Woodlands and Trails Association

ATP-109 Matt Robertson Private citizen

ATP-110 Don Morehouse Private citizen

ATP-111 Blaine Pickett Private citizen

ATP-112 Robert Levorse Private citizen

ATP-113 Sean Fairbairn Private citizen

ATP-114 Kristi Mergenthaler Siskiyou Chapter, Native Plant Society of Oregon

ATP-115 Kate Cleland-Sipfle Private citizen

ATP-116 Luke Ruediger Private citizen

ATP-117 Colleen Horner Private citizen

ATP-118 Ted Clay Private citizen

ATP-119 Doobie Lawson Private citizen

FOREST SERVICE RESPONSE TO COMMENTS 

Comments were reviewed and sorted into two types – substantive and non-substantive. A 

substantive comment is defined as: “A review comment made by a commenter that offers a concern 

with factual basis that may have bearing on the decision being made.” A working definition of 

substantive that was used for categorizing substantive comments include those that: 

 Provide new information pertaining to the Proposed Action or an alternative 

 Identify a new relevant issue or expand upon an existing issue 

 Identify a different way (alternative) to meet the underlying need 

 Identify a specific flaw in the analysis 

 Ask a specific relevant question that can be meaningfully answered or referenced 

 Identify an additional source of credible research, which if utilized, could result in different 

effects 

Substantive comments were numerically coded in the Forest Service review (e.g., 101, 201) and 

recorded on the original comment letter or email. 

Non-substantive comments (and associated letter codes) are defined as those that: 

A - Primarily focus on personal values or opinion or simply provide or identify a preference 

(vote) for an alternative considered 
Draft DN Attachment A Page A - 5 Ashland Trails Project 

Response to Comments

B - Restate existing management direction, laws or policies that were utilized in the design and 

analysis of the project (or provide personal interpretation of such), or restate analysis or 

information documented in the EA

C - Provide comment that is considered outside the scope of the analysis (not in compliance with 

current laws and policies, is not relevant to the specific project proposal, or is outside of the 

Responsible Official’s decision space) 

D - Lack sufficient specificity to support a change in the analysis or permit a meaningful 

response, or are composed of general or vague statements not supported by data or research 

E – Opinion, political commentary, setup (often positive or supportive) 

Non-substantive comments were sorted using the above letter codes and recorded on the original 

comment letter or email. 

Each substantive comment received on the EA is summarized in bold below. A response from the 

Forest Service is also provided for each substantive comment. To minimize duplication, substantive 

comments addressing essentially the same topic or concern have been consolidated among the 

various letters. The parenthetical reference following each substantive comment (e.g., ATP-81, 82) 

indicates the reference number of the letter(s) where the substantive comment was raised. 

Comments and responses will be used to help the Responsible Officials reach an informed decision 

regarding the Ashland Trails Project. 

Substantive Comments - Corrections/Clarifications

Comment 101: Consideration of the Split Rock Trail as an existing historic trail 

Why is the Split Rock Trail identified as an existing historic trail in the EA? In some areas it is 

barely perceptible and early maps of the area do not indicate a trail was historically located 

along the proposed alignment. [ATP-1, 14, 114] 

Response: Section 2.3 (page 2-9) of the EA defines “existing historic trails” as “trails that were at 

one time System Trails and that were identified on Forest Service maps but for unknown reasons 

were dropped from the System. Some of these trails are thought to have been constructed prior to 

1910 and accessed fire lookouts and the Siskiyou Crest.” Section 3.4.12 in the EA (page 3-172) notes 

that existing maps of the area (ca 1896 and 1925) indicate that the southern half of the Split Rock 

Trail appears to have been in existence in 1896 as a pack trail, and later as a firefighting trail. Public 

comments received on the EA (ATP-14) also describe that later maps of the area (ca 1930-1950) 

show a trail connected the upper McDonald Creek Basin with Wagner Glade Gap (including the 

Wagner Glade Lookout) along the Siskiyou Crest Ridgeline. Although the present trail is ephemeral 

and barely perceptible in some locations, a trail alignment in the general vicinity of the Split Rock 

Trail was part of the Forest Service system at one point. As such, the Split Rock Trail is considered 

an existing historic trail for the purposes of the EA analysis. 

Comment 102: Emphasis on Bicycle Uses on Trails 

All alternatives provide substantially more mileage to bicycle uses than other uses. Why is the 

Forest Service emphasizing bicycle uses, particularly given the rugged and steep terrain and 

sensitivity of some areas (e.g., botanical resources in the McDonald Peak Botanical Area)? 

[ATP-1] 
Draft DN Attachment A Page A - 6 Ashland Trails Project 

Response to Comments

Response: Proposed managed uses were based on a variety of factors including trail location, use 

levels, predominant uses, and anticipated changes in use over time. As described in Section 3.2.1 

(page 3-7), running, hiking, and mountain bike use within the action area has grown dramatically 

over the last decade, particularly on trails in the vicinity of Ashland. The primary user conflict in the 

area is between downhill mountain bikers and pedestrians (hikers, runners, and dog walkers) and to a 

lesser extent, equestrians (in part, because equestrians indicate they don’t use the trail system 

frequently due to safety concerns). The EA alternatives considered trail configurations that would 

separate uses in the eastside of the action area, where use is highest, and disperse use to the westside 

of the action area to lessen trail density and contact with other uses (see Section 3.2.2, page 3-13). 

While it is anticipated that all uses in the action area will increase over time, bike use will likely 

increase substantially, and will continue to transition from cross-country to downhill mountain bike 

riding. Both Alternatives 2 and 3 in the EA recognize the potential for this increased use – including 

the potential for user conflict – by providing adequate trail mileage for all uses, and opportunities for 

dispersed and separate uses where appropriate. As summarized in Table 3-3 in the EA (page 3-14), 

between 36.7 miles (Alternative 3) and 43.2 miles (Alternative 2) 1 would be available to bikes under 

the alternatives. Comparatively, between 36.7 miles (Alternative 3) and 41.3 miles (Alternative 2) 

would be available to pedestrians, and between 27.2 miles (Alternative 3) and 30.9 miles (Alternative 

2) would be available to equestrians. 

Comment 103: Implementation Process 

Who will build and maintain the trails? What role will volunteers play in constructing trails? 

How will volunteers be organized and who will be allowed to host trail work days? Will the 

Forest Service apply for grant money? How will the Forest Service coordinate with the City of 

Ashland in areas where the trails connect with or extend into the City trail system? [ATP-7, 97] 

Response: As described in Section 2.2.4 (page 2-4) in the EA, trails would be constructed by trained 

volunteers, user groups, and youth organizations under the direction of Forest Service staff. Trail 

maintenance would be completed by trained volunteers and recreation special use permit holders. All 

trails would be constructed in accordance with the Trails Management Handbook, Forest Service 

Handbook (FSH) 2309.18; the design parameters provided in Section 2.2.3 of the EA (page 2-3); and 

the Project Design Criteria (PDC) summarized in Table 2-9 of the EA (pages 2-30 to 2-33). 

It is anticipated that user groups, such as the Ashland Woodlands and Trails Association (AWTA), 

would continue to play an important role in helping to organize trail construction and maintenance 

groups. Where possible, the Forest Service would apply for grant money to construct and maintain 

trails. 

Forest Service staff would work closely with the City of Ashland Forest Lands Commission to ensure 

that trails that cross onto City property are compatible with City trail easements, design, and 

managed uses, and would not encroach onto private property where no easement exists. 

Comment 104: Decommissioning the Jabberwocky, Pete’s Punisher, Poison Oak, and Lower 

Marty’s Trails 

Why is the Forest Service proposing to decommission the Jabberwocky, Pete’s Punisher, 

Poison Oak, & Lower Marty’s Trails? These trails provide opportunities for advanced runners 

 

1

 The miles of trails for hiker/pedestrian and bicycles summarized in Table 3-3 for Alternative 2 (i.e., 19.9) was 

incorrect. The correct mileage is 10.4 miles. 
Draft DN Attachment A Page A - 7 Ashland Trails Project 

Response to Comments

and mountain bikers and closing them may lead to additional illegal trail building to meet the 

demand for more advanced trail opportunities. [ATP-9, 15] 

Response: As described in Section 1.2 of the EA (page 1-3), the purpose of the proposed action is to 

provide for an adequate and sustainable trail system that minimizes impacts to soil, water, cultural, 

vegetation and wildlife resources and discourages unauthorized trail proliferation. The Jabberwocky, 

Pete’s Punisher, Poison Oak and Lower Marty’s Trails would be decommissioned or rerouted under 

Alternatives 2 and 3 for the following reasons: 

 About 95% of the trail grades along the existing alignment of the Jabberwocky Trail are 

unsustainable (i.e., too steep) and portions of the trail are located in Riparian Reserves.2

Under Alternatives 2 and 3, the existing historic trail alignment would be rerouted out of 

Riparian Reserves onto an alignment consistent with the Trail Class 2 standards provided in 

FSH 2309.18 (see Section 2.2.3 in the EA, page 2-3). 

 Trail grades associated with the Pete’s Punisher and Poison Oak Trails are too steep, and 

present a significant potential for continued erosion. These trails would be closed and 

rehabilitated. The Wonder and Not Stirred Trails, which would be constructed under 

Alternatives 2 and 3, would provide a loop experience in place of the Poison Oak Trail. 

 The Lower Marty’s Trail above Lambs Saddle is comprised of steep, braided trails that are 

not sustainable. Under Alternatives 2 and 3, 0.4 mile of the existing trail alignment above 

Lambs Saddle would be closed and rehabilitated and replaced with a single, consolidated trail 

constructed at a more sustainable grade. 

Please refer to Comment107 for a discussion of how the Forest Service will monitor and manage for 

unauthorized trail proliferation in the action area. 

Comment 105: Decommissioning the Caterpillar Trail 

Why is the Forest Service proposing to decommission the Caterpillar Trail? [ATP-13, 67] 

Response: The Forest Service is not proposing to decommission the Caterpillar Trail. Under all 

alternatives, the Caterpillar Trail would remain open to all non-motorized uses (see Table 2-2 in the 

EA, page 2-10). 

During the scoping period, some members of the public suggested removing bicycle use from the 

section of the Caterpillar Trail that extends from the Lizard junction to Road 2060 (i.e., the “Close 

the Gap” proposal), which may have been interpreted as a proposal to “decommission” the 

Caterpillar Trail. Please refer to Comment 203 for a discussion of the Close the Gap proposal. 

Comment 106: Decommissioning the Winburn Trap Trail 

Why is the Forest Service proposing to decommission the Winburn Trap Trail? This trail is an 

important historic trail and should be rerouted to provide pedestrian and equestrian access. 

The Time Warp Trail was rerouted around northern spotted owl habitat to provide access for 

bicycles, but the Forest Service will not make a similar accommodation on the Winburn Trap 

Trail for equestrians. [ATP-32, 81, 94] 

 

2

 As described in Section 1.5.1 of the EA (page 1-11), Riparian Reserves (which are allocated under the Northwest 

Forest Plan) include lands along stream, lakes, ponds, wetlands, unstable areas, and potential unstable areas that are 

subject to special Standards and Guidelines designed to conserve aquatic and riparian-dependant species. 
Draft DN Attachment A Page A - 8 Ashland Trails Project 

Response to Comments

Response: The Winburn Trap Trail would be decommissioned under Alternative 3 to avoid northern 

spotted owl (Strix occidentalis caurina) nest patches and to minimize potential water quality 

concerns in and around Reeder Reservoir, the source of Ashland’s water supply, as a result of 

ongoing trail use. As described in Section 3.3.3 in the EA (page 3-61), this trail is currently located 

within two spotted owl core areas. Increased use of this trail with no seasonal restrictions3 would 

likely be detrimental to spotted owl nest sites and may cause displacement of owls over the longterm. In addition, the Winburn Trap Trail accounts for about 1.3 acres of disturbance in Riparian 

Reserves (see Section 3.3.1, page 3-21) and provides seven stream crossings, many of which are 

located along an existing legacy roadbed which has an increased potential to deliver sediment to the 

watershed during a storm event (page 3-22). The proposal to decommission this trail under 

Alternative 3 reflects consideration of these combined resource concerns. Repurposing this trail 

solely for equestrian use would not alleviate these concerns, and would not be consistent with the 

purpose of the purpose action: to provide for an adequate and sustainable trail system that minimizes 

impacts to soil, water, cultural, vegetation, and wildlife resources. 

The Upper Time Warp Trail is an existing historic trail that would become a System Trail open to 

bicycle uses under Alternatives 2 and 3. Approximately 1.0 miles of the existing alignment would be 

rerouted under Alternative 3 to avoid northern spotted owl habitat, including a nest patch (see 

Section 3.3.3, page 3-64). Although the trail alignment would still be located with a spotted owl core 

area, the potential for disturbance of a nest patch would be removed and the overall potential for 

disturbance of spotted owl sites reduced. There are no other resource concerns associated with this 

trail alignment. 

Comment 107: Consideration of illegal or off-trail uses 

The EA does not adequately consider the impacts of illegal or off-trail uses. Allowing bikes on 

the Split Rock Trail would result in additional illegal bike use on the Wagner Butte Trail, 

where bikes are not allowed. In addition, authorizing recreational use on trails in close 

proximity to sensitive resources (e.g., special-status plants along the Split Rock Trail) would 

increase the potential for damage to those resources from off-trail use. [ATP-83, 114] 

Response: As described in Section 3.2.2 in the EA (page 3-15), the current system of trails 

(authorized and unapproved) is not meeting public demand and has resulted in unauthorized trail 

construction and off-trail uses. The addition of between 24.9 miles (Alternative 3) and 31.4 miles 

(Alternative 2) of new sustainable System Trails under the action alternatives, and the separation of 

managed uses in high use areas, would better meet public demand and lessen the probability of 

unauthorized trail proliferation. Moreover, proper trail design, regular maintenance, and adequate 

signage (including use-specific trail maps) under the action alternatives would reduce inadvertent 

impacts to sensitive resources from off-trail uses, and would simplify enforcement efforts within the 

action area. The Forest Service will continue to monitor ongoing trail uses in the action area to 

determine if additional management actions are necessary to address impacts associated with off-trail 

uses. 

Please refer to the response to Comment 203 for a discussion of potential impacts on special-status 

plants along the Split Rock Trail and the PDC that would be implemented to minimize impacts to 

those species. 

Comment 108: Impact to Subalpine Fir 

 

3

 Seasonal restrictions to reduce effects on northern spotted owl nest sites were considered by the IDT for routes in 

owl core areas; however there was low confidence that they would be effectively enforced over the long-term. 

Disturbance from trail use would be particularly detrimental during the breeding season (primarily March – June). 
Draft DN Attachment A Page A - 9 Ashland Trails Project 

Response to Comments

The EA does not consider impacts to subalpine fir along the Split Rock Trail. [ATP-83] 

Response: The EA considers impacts to sensitive plant species and communities including federallylisted, Forest Service sensitive, Northwest Forest Plan (NWFP) Survey and Manage Species, and 

locally rare species of vascular plants, bryophytes, lichens or fungi (see Section 3.49 in the EA, pages 

3-152 to 3-162). Subalpine fir does meet any of these criteria and, accordingly, was not specifically 

discussed in the EA. 

Of note, implementation of PDC GEN-5 under the action alternatives would ensure that trail 

construction and maintenance activities avoid removal of trees with a diameter-at-breast height (dbh) 

greater than 6 inches. As such, it is unlikely that mature subalpine fir trees would be impacted during 

construction of the Split Rock Trail under Alternatives 2 or 3. 

Comment 109: Unauthorized motor vehicle use on the Split Rock Trail 

Authorizing the Split Rock Trail as a System Trail could invite illegal motorbike and other 

ATV use as the area cannot be economically patrolled on a regular basis. [ATP-83] 

Response: Motorized trail uses will be governed by the Forest Service’s motor vehicle use map 

(MVUM) which designates where motorized uses are allowed within the Forest. Persons using 

motorized vehicles in areas they are not allowed, including all trails within the action area, would be 

subject to enforcement action. Please refer to the response to Comment 107 for a discussion of how 

illegal or off-trail uses were considered in the EA. 

Comment 110: Characterization of Potential Wilderness Areas 

The EA states that an inventory of Potential Wilderness Areas (PWA) has not been completed, 

but goes on to state that no PWAs occur in the action area. This logic is circular in that a PWA 

can’t be identified until an inventory has been completed, but since the inventory has not been 

completed, it can’t definitively be stated they do not occur there. [ATP-83] 

Response: As described in Section 3.4.11 in the EA (page 3-166), PWAs are identified using 

inventory procedures found in FSH 1909.12, Chapter 71. An inventory of PWA’s has not been 

completed on the Rogue River-Siskiyou National Forest, so no PWAs have been identified. This 

statement is not intended to infer that an inventory in the future would not identify PWAs, but rather 

than the inventory process has not been completed. 

It is important to note that PWAs do not reflect a land designation decision, do not imply or impart 

any particular level of management direction, are not an evaluation of potential wilderness (FSH 

1909.12, Chapter 72), and are not preliminary administrative recommendations for wilderness 

designation (FSH 1909.12, Chapter 73). The inventory of PWAs does not change the administrative 

boundary of an Inventoried Roadless Area (IRA) or any congressionally designated Wilderness. 

Comment 111: Availability of Biological Evaluation and Survey and Manage Reports for the 

Proposed Action 

It is our understanding that Forest Service policy requires inclusion of a Biological Evaluation 

and NWFP Survey and Manage Species Reports for the proposed action be appended to the 

EA, or otherwise made available for public review [ATP-91, 114] 
Draft DN Attachment A Page A - 10 Ashland Trails Project 

Response to Comments

Response: Forest Service policy does not require that a Biological Evaluation or NWFP Survey and 

Manage Species Report be appended to an EA. The following reports were prepared for the proposed 

action, and are available on request from the Siskiyou Mountains Ranger District. The information 

provided in these reports was used to prepare the EA, and is consistent with the analysis provided in 

the EA. 

 Wildlife Biological Evaluation and Specialist Report, Ashland Trails Project (Prepared by 

Bonnie Allison, Forest Service Wildlife Biologist) 

 Biological Evaluation for Threatened, Endangered, and Sensitive (TES) Vascular Plants, 

Bryophytes, Lichens and Fungi, Ashland Trails Project (Prepared by Wayne Rolle, Forest 

Service Botanist) 

 Ashland Trails Project: Report on Northwest Forest Plan Survey and Mange (S&M) Fungi, 

Lichens, Bryophytes, and Vascular Plants (Prepared by Wayne Rolle, Forest Service 

Botanist) 

Comment 112: Decommissioning the Reservoir Trail 

Why is the Forest Service proposing to decommission the historic trail from Ashland Creek 

east fork to Lambs Saddle (i.e., the Reservoir Trail)? This trail is an important part of the 

watershed’s historic trail system. [ATP-94, 112] 

Response: The Reservoir Trail would be closed and rehabilitated under Alternatives 2 and 3 to 

minimize potential water quality impacts to the perennial East Fork of Ashland Creek and Reeder 

Reservoir, the source of Ashland’s water supply. This trail is also located in the Ashland Creek 

Research Natural Area (RNA). As described in Section 1.5.1 of the EA (page 1-11), an RNA is a 

Management Area allocation identified in the Rogue River National Forest Land and Resource 

Management Plan (LRMP) whose goal is to provide areas for research, observation and study of 

undisturbed ecosystems. Maintenance of natural processes within the RNA are a prime consideration, 

and management activities must be approved by the Director of the Pacific Northwest Research 

Station. The Director of the Pacific Northwest Research Station has indicated that the existing 

unapproved Reservoir Trail should be decommissioned in order to meet the Standards and Guidelines 

provide for RNAs in the LRMP. 

Comment 113: Clarification of Figure 1-2 

Figure 1-2 should be revised to show land allocations extending at least 1⁄2 mile beyond the 

Ashland Watershed boundary to better illustrate how the McDonald Peak Botanical Area 

would be affected by the Split Rock Trail. [ATP-114] 

Response: Figure 1-2 in the EA (page 1-9) is included to illustrate the land management allocations 

within the approximately 12,700 acre area in the Rogue River-Siskiyou National Forest where the 

proposed action would be located (i.e., the action area). Although the graphic doesn’t reflect the full 

extent of the McDonald Peak Botanical Area (which extends onto the Klamath National Forest), the 

analysis area considered for assessing impacts to this area is concurrent with the boundary of the 

botanical area (see Section 3.4.8, page 3-149). 

Comment 114: Equestrian Use in the Action Area 

The EA does not describe horses as the historical user of the watershed, or accurately 

characterize why equestrian use has declined over time and migrated to the westside of the 

action area (i.e., due to safety concerns associated with horse-bicycle interactions). [ATP-81] 
Draft DN Attachment A Page A - 11 Ashland Trails Project 

Response to Comments

Response: Section 3.2.1 in the EA (pages 3-3 to 3-4) describes historic recreational uses in the action 

area and is focused largely on infrastructure that facilitated recreational uses over time – i.e., historic 

trails, roads, and early Civilian Conservation Corps campgrounds and picnic grounds. Although no 

specific mention of equestrian use in the watershed is provided in that section, the Forest Service 

acknowledges that horses were used in the watershed for recreational and other purposes in the early 

1900’s, as the commenter suggests. The Forest Service also acknowledges that equestrian use in the 

watershed has decreased over time, and migrated to the lesser-used westside of the watershed, due, in 

part, to concerns expressed by some equestrians about unsafe interactions between horses and 

bicycles. 

Appreciating the potential for user conflicts in general, including conflicts between equestrians and 

bicycles, the alternatives considered in the EA consider various trail configurations to disperse and 

separate uses. Please refer to the response to Comment 102. 

Comment 115: Public comments provided during February 2011 trail development meetings 

The City of Ashland held two meetings in February 2011 to solicit comments from users on the 

AWTA Trails Master Plan. Those comments were largely ignored by the Forest Service, which 

is inappropriate given the Memorandum of Understanding (MOU) between the City and 

Forest Service. [ATP-81] 

Response: The February 2011 meetings were hosted by AWTA, not the City of Ashland, to solicit 

input on the initial draft of their Trails Master Plan. The Forest Service reviewed these comments 

both during scoping and in comments provided on the Draft EA.4 However, because specific 

information on the commenter and the context in which the comments were provided was not 

apparent (i.e., specific to the Forest Service proposed action), these comments were not considered 

substantive to the EA analysis. 

As described in Section 1.6.3 in the EA (pages 1-15 to 1-16), the MOU between the City and Forest 

Service defines the roles and responsibilities of both jurisdictions in the management of the Ashland 

Watershed. It provides the City an opportunity to offer input to the Forest Service during planning, 

implementation, and management review of projects in the watershed. In accordance with the MOU, 

Forest Service staff have met with City staff on several occasions during development of the EA 

analysis to discuss proposed trail alignments, managed uses, and potential conflicts with the City trail 

system. 

Comment 116: Allowed uses on the Horn Gap Trail 

The Horn Gap Trail has always had the designation as a hiker/equestrian trail that is not open 

to bikes. This is evidenced in the trail markers at the top of the trail where the traditional metal 

trail symbols of a hiker and horse are attached to a wood sign, as well as a bike sign with a 

slash on it. Recently, a new sign has been erected indicating “it isn’t recommended horsemen 

use it”. Alternatives 2 and 3 would officially open the trail to bicycle use, which would 

eliminate an opportunity for equestrians to ride without bikes on the west side of the action 

area. [ATP-81] 

Response: The Horn Gap Trail is an existing System Trail that was constructed in 1993 as a “tie 

trail” to create loop trails for mountain bikers off of Road 2060. It has historically been used by 

mountain bikers and pedestrians, with equestrian use not recommended. However, since it was 

 

4

 In both cases, these comments were appended to the Safe Trails Plan proposal provided by Joy Trevey-Lowell on 

behalf of equestrian users groups. 
Draft DN Attachment A Page A - 12 Ashland Trails Project 

Response to Comments

constructed, Road 2060 has been gated and use of the Horn Gap Trail by downhill mountain bikes 

has decreased due to access being more difficult. The Horn Gap Trail now provides a good trail 

opportunity for all uses.

The EA did not analyze or propose any changes to current uses on the Horn Gap Trail. No official 

Forest Service signage has been placed on this trail recently, including any signs discouraging horse 

use or excluding bike use. In all cases, following a final decision on the proposed action, inaccurate 

signage on existing and any new System Trails would be removed and updated by the Forest Service, 

as appropriate. 

The commenter is correct that under all alternatives, the Horn Gap Trail would remain open to all 

non-motorized uses, including equestrian uses. Opportunities for equestrians to use trails separate 

from bicycles would be provided on the Ric’s, Red Queen, Lewis Loop, and Bandersnatch Trails 

under Alternatives 2 and 3. Although other trails on the west side of the action area (e.g., Split Rock 

or Wagner Glade Trails) authorized under the action alternatives would not separate uses, they would 

disperse use away from the City of Ashland, where the potential for horses and bikes to interact 

would be less because there would be fewer users. 

Comment 117: Process used to select trails for proposed decommissioning 

All trails proposed for decommissioning in the watershed under Alternative 3 are bike trails 

not horse trails. [ATP-81] 

Response: The trails proposed for decommissioning under Alternatives 2 and 3 were specifically 

identified for closure and rehabilitation by the Interdisciplinary Team (IDT) because their design is 

not sustainable (i.e., use is resulting in unacceptable adverse impacts to soil, water, cultural, 

vegetation, and wildlife resources) or they do not offer a desirable recreation opportunity. Trails were 

not selected for decommissioning based on presumed or dominant use. 

Please refer to the response to Comment 104 for a discussion of why the Lower Marty’s, 

Jabberwocky, Pete’s Punisher, and Poison Oak Trails would be decommissioned under Alternatives 

2 and 3. The responses to Comments 103 and 112 describe why the Winburn Trap and Reservoir 

Trails would be decommissioned under the action alternatives, respectively. 

Comment 118: Preferential treatment of certain users groups 

Several trails were realigned to avoid sensitive resources to allow continued bicycle use while 

similar accommodations were not made for other user groups. For example, the Jabberwocky 

Trail was redesigned to allow continued mountain bike use but a proposal to allow a trail from 

Red Queen to Lewis Loop for equestrian use was not considered. Please clarify why one user 

has preferential treatment. [ATP-81] 

Response: In all cases, proposed trail designs and locations considered resource constraints, 

including potential impacts to soil, water, cultural, vegetation, and wildlife resources. The 

Jabberwocky Trail was relocated to avoid Riparian Reserves and lessen the trail grade. A new trail 

between Red Queen and Lewis Loop was not proposed because all possible alignments would bisect 

Riparian Reserves and Pacific fisher (Pekania pennanti [formerly Martes pennanti]) habitat. 

Please refer to the response to Comment 102 for a discussion of how managed uses were considered 

in developing the action alternatives. 
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Response to Comments

Substantive Comments – Possible New Relevant Issue or “Flaw” in Analysis

Comment 201: Equestrian safety concerns in the area of Red Queen Trail 

In the Safe Trails Plan provided to the Forest Service during public scoping, equestrian groups 

identified safety concerns in the area of the Red Queen Trail that were not addressed in the 

EA. Specifically, they stated the proposed convergence of the Red Queen, Alice in Wonderland, 

Jabberwocky, and Lizard Trails offered no safe opportunity for horses to access the Lewis 

Loop Trail without interacting with bicycles, some of which would be travelling downhill at 

speed. Re-designating the lower section of the Caterpillar Trail for pedestrian / equestrian uses 

would provide the needed safe connection between the Red Queen and Lewis Loop Trails. This 

suggestion was referred to as the “Close the Gap” proposal at the public comment meeting on 

February 6, 2015, and in many comments received during the public comment period on the 

EA. [ATP-12, 19] 

Response: In developing the alignments and proposed uses for the trails in this area, the Forest 

Service anticipated the majority of bike traffic that currently use the Caterpillar Trail would be 

redirected to the Lizard Trail, which would be designed to better accommodate bikes (e.g., fewer 

switchbacks). Commenters, through the “Close the Gap” proposal, have suggested modifications that 

would provide a contiguous no-bike trail from the Red Queen Trail, via the Caterpillar Trail, to the 

Lewis Loop Trail. The Responsible Official will consider this proposal and other safety concerns in 

her decision on the proposed action. 

Comment 202: Seasonal restrictions to limit erosion and trail damage 

The EA did not consider seasonal restrictions (e.g., closing trails in wet winter months) to limit 

erosion and trail damage from bikes. [ATP-31] 

Response: The EA did not consider seasonal restrictions on any recreational uses because, outside of 

trails proposed for decommissioning, trail conditions in the action area are not so degraded that 

closing trails seasonally is necessary or warranted. As described in Section 3.4.2 in the EA (page 3-

113), soils in the action area are generally comprised of decomposed granite and are typically well to 

excessively drained. The location and design of most trails further minimizes the potential for 

erosion, rilling, and/or ponding, which limits damage to trails during wet periods. Seasonal 

restrictions are also difficult to enforce. The Forest Service will monitor trails conditions and uses in 

the action area to determine if seasonal restrictions (or other types of management actions) become 

necessary in the future to maintain a sustainable trail system. 

Comment 203: Impacts to monument plant and Howell’s tauschia 

The EA did not adequately consider impacts to monument plant (Swertia radiata) and Howell’s 

tauschia (tauschia howelli) along the Split Rock Trail, particularly considering the potential for 

increased off-trail uses. [ATP-83] 

Response: Impacts to both monument plan t and Howell’s tauschia are considered in Section 3.59 of 

the Draft EA, Specifically, as described on page 3-152, Howell’s tauschia is considered an extremely 

rare species whose habitat is specialized and easily disturbed. It is known to occur near the south end 

of the Split Rock Trail, as well as the east side of the summit of McDonald Peak. The EA 

acknowledges that under both action alternatives, tauschia could be impacted if the Split Rock Trail 

alignment isn’t carefully routed, or if recreational users stray from the established trail alignment (see 

page 3-158). The IDT identified two PDC to reduce these potential impacts to tauschia. PDC BOT-1 
Draft DN Attachment A Page A - 14 Ashland Trails Project 

Response to Comments

and BOT-2 would require that the route of the reestablished Split Rock Trail be chosen to minimize 

impacts to Howell’s tauschia at its south end and to avoid impacts at McDonald Peak. PDC BOT-1 

would also require that ancillary measures, such as rock-lined borders or signs, be considered to 

discourage trail users from leaving the trail and potentially disturbing the tauschia populations at this 

location. 

Section 3.4.9 also discusses monument plant, and potential impacts to this species under the action 

alternatives. As described on page 3-155 of the Draft EA, monument plant is regularly encountered 

in the Siskiyou Mountains along the ridge from the McDonald Peak vicinity to about 1 mile north of 

Wagner Butte. Potential impacts to monument plant in the vicinity of the Split Rock Trail would be 

minimized by implementing PDC BOT-4, which would require the Forest Service botanist to assist 

in reestablishing the trail route where it may pass through or near patches of monument plant. With 

implementation of this PDC, impacts would be limited to the loss of a few individuals along the Split 

Rock Trail, which would have no effect on the local viability of the species (see page 3-160). 

Please refer to the response to Comment 107 for a discussion of illegal or off-trail uses. 

Comment 204: Consideration of unleashed dogs 

The EA did not consider the impact of unleashed dogs which intensifies potential use conflicts 

between all groups and wildlife. [ATP-94] 

Response: Section 3.3.2 in the EA (pages 3-45 to 3-46) describes the potential effects of disturbance 

to wildlife from non-motorized recreation, including disturbance specifically associated with dog 

presence. As described in that section, human recreation in general and dog presence in particular has 

been associated with reduced carnivore abundance, habitat avoidance, direct and indirect mortality, 

and disruption of normal activities (e.g., feeding, resting). In fact, under both action alternatives, 

several trails were either proposed to be rerouted or decommissioned specifically to avoid and 

minimize potential impacts to wildlife from continued recreational use, including adverse 

interactions with dogs. 

There are no specific regulations that prohibit dogs in the action area, or require that dogs be 

maintained on leash. Under Alternatives 2 and 3, the Forest Service would install signage at 

trailheads describing trail etiquette, including suggestions that dogs be kept on leash or under verbal 

control. In addition, Forest Service staff will continue to monitor use in the action area to determine 

if additional restrictions on dog use are necessary in the future. 

Comment 205: Impacts on McDonald Peak Botanical Area 

Section 3.4.8 in the EA (page 3-152) includes the following statement in the discussion of 

impacts to the McDonald Peak Botanical Area under Alternative 2: “Maintenance and 

management of this trail [Split Rock Trail] as a System Trail would reduce potential adverse 

effects on the Botanical Area from unapproved use.” The statement is unsupported by evidence 

or rationale in this section or elsewhere in the EA. If the Forest Service insists on including this 

statement in the EA, we request that evidence and/or rationale be provided. The reference to 

PDCs in this section is also off-topic and does not support the untrue statement opening the 

paragraph. [ATP-114] 

Response: Section 3.4.8 (page 3-151) in the EA describes that dispersed recreational uses in the 

botanical area are likely to increase over time due to population growth, even if the Split Rock Trail 

is not authorized as a System Trail under the proposed action. The statement on page 3-152 is 

intended to reflect that the establishment and maintenance of a single trail alignment along the 
Draft DN Attachment A Page A - 15 Ashland Trails Project 

Response to Comments

ridgeline in this area would consolidate use and limit direct impacts to botanical resources as more 

people use the area in the future. The specific PDC referenced in the section summarizes measures 

that would be implemented to protect sensitive botanical resources along the Split Rock Trail if it 

authorized as a System Trail, as well as measures to reduce the likelihood that users would leave the 

trail once it is established. It is also important to note that this section acknowledges that impacts to 

the botanical area under the action alternatives could be more substantial than under Alternative 1 

(No Action), where the Split Rock Trail would not be reestablished and use of the historic alignment 

would likely be lower than if it were established as a System Trail. 

The Responsible Official will consider potential impacts to the McDonald Peak Botanical Area when 

making a final decision on the proposed action. 

Substantive Comments – Possible Alternative Configurations or Reroutes 

Comment 301: Reroute Wagner Glade Trail 

One commenter suggested the Wagner Glade Trail be rerouted to make the alignment more 

sustainable. [ATP-7] 

Response: If the Wagner Glade Trail is authorized as a System Trail under Alternatives 2 or 3, small 

segments of the existing historic alignment would be rerouted to establish breaks in the grade where 

the trail is particularly steep. Rolling dips may also be installed in areas where there is a long run 

between drainage features. 

Comment 302: Proposed Alternate Configuration of Managed Uses 

Many commenters provided suggested changes to managed use configurations for specific 

trails, or suggested certain uses be allowed in one direction only. [ATP-8, 11, 12, 13, 16, 17, 18, 

19, 20, 21, 24, 26, 27, 28, 29, 33, 34, 35, 37, 38, 40, 42, 43, 45, 47, 49, 50, 53, 54, 56, 58, 59, 62, 63, 

64, 65, 66, 68, 69,70, 71, 72, 74, 75, 76, 78, 79, 81, 82, 83, 88, 89, 92, 95, 96, 98, 100, 101, 102, 104, 

105, 106, 107, 108, 109, 110, 112, 114, 115,118] 

Response: As defined in Section 2.2.2 in the EA (page 2-2), managed use refers to the mode(s) of 

travel that are actively managed and appropriate for a trail based on its design. There can be more 

than one managed use for a trail, and managed uses are often a subset of allowed uses. For example, 

on a trail that is closed to all motorized use, the managed use could include hiker/pedestrian and 

equestrian uses, while the allowed uses may also include bicycles. 

Table 2 summarizes the alternate use configurations for specific trail alignments suggested by 

commenters, as well as the proposed managed uses for trails under each of the alternatives 

considered in the EA. The table also provides a brief discussion articulating the rationale behind the 

proposed managed uses provided in the EA. The Responsible Official will consider proposed

alternate uses configurations when making a final decision on the proposed action. 
Draft DN Attachment A Page A - 16 Ashland Trails Project 

Response to Comments

Table 2. Proposed Alternate Configurations of Managed Uses by Trail

Trail Name Alternative 11 Alternative 2 Alternative 3 Proposed Alternate Managed Uses Discussion

Caterpillar All non-motorized uses  Pedestrian only

 Pedestrian and equestrian only

Please refer to the response to 

Comment 201 for a discussion of 

alternate uses proposed for the 

Caterpillar Trail. 

Catwalk All non-motorized uses

 Bike only

 Bike only, one direction (downhill)

 All non-motorized uses, one 

direction (downhill)

The Catwalk Trail is currently 

regularly used by both pedestrians 

and bicycles. Designating it as a 

bicycle trail would conflict with long 

standing use patterns in the area, 

and present additional enforcement 

and user conflict concerns.

Toothpick All non-motorized uses  Pedestrian and equestrian only

Bikes currently use the Toothpick 

Trail to access the Caterpillar Trail. 

Removing bikes as a managed use

would detrimentally affect a large 

portion of the current use by requiring 

bikes to go down Tolman Creek 

Road, rather than the preferred route 

of continuing on the Toothpick Trail to 

the Caterpillar Trail. 

Upper Horn Gap All non-motorized uses  Pedestrian and equestrian only Please refer to the response to 

Comment 116.

Alice in Wonderland All non-motorized uses Bike Bike  All non-motorized uses

The Alice in Wonderland Trail has 

historically been open to all uses and 

is an important link to the trail system.

Upper Time Warp None Bike Bike  Pedestrian and Equestrian

The Upper Time Warp Trail is 

currently primarily used by downhill 

mountain bikes. Allowing pedestrians 

and equestrians on Upper Time Warp 

may result in user conflict.

Wagner Glade None All non-motorized uses All non-motorized uses  Pedestrian only

The Wagner Glade Trail would 

disperse use to the west side of the 

action area, and provide an 

opportunity for access to more 

remote / lesser used areas. It would 

also provide a loop opportunity with 

the Split Rock Trail.
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Response to Comments

Trail Name Alternative 11 Alternative 2 Alternative 3 Proposed Alternate Managed Uses Discussion

Winburn Trap None All non-motorized uses Decommissioned  Pedestrian and equestrian only Please refer to the response to 

Comment 106.

Split Rock None All non-motorized uses All-non motorized uses  Pedestrian only

 Pedestrian and equestrian only

The Split Rock Trail would disperse 

use to the west side of the action 

area, and provide an opportunity for 

access to more remote / lesser used 

areas. 

Lower Marty’s None Pedestrian and bike Pedestrian and bike None --

Jabberwocky None Pedestrian and bike Pedestrian and bike 

 Bike only

 Bike only, one direction (downhill)

 Pedestrian and bikes, one direction 

(downhill)

The Jabberwocky Trail is currently 

primarily used as a bike trail, with 

some pedestrian use. 

Fell on Knee None Pedestrian and bike Pedestrian and bike None --

Upper Missing Link None Pedestrian and bike Pedestrian and bike 

 Bike only

 Bike only, one direction (downhill)

 Pedestrian and bikes, one direction 

(downhill)

 Pedestrian only

The Upper Missing Link Trail is 

currently primarily used as a bike trail, 

with some pedestrian use. 

Lower Missing Link None Pedestrian and bike Pedestrian and bike 

 Bike only

 Bike only, one direction (downhill)

 Pedestrian and bikes, one direction 

(downhill)

The Lower Missing Link Trail is 

currently primarily used as a bike trail, 

with some pedestrian use. 

No Candies None Pedestrian and bike Pedestrian and bike  All non-motorized uses

The design and alignment of this trail 

– which is twisty and narrow with very 

limited site distance – is not best 

suited to a multiple use trail 

accommodating equestrians. 

Upper Eastview None All non-motorized uses All non-motorized uses None --

Chain Saw None Decommissioned Decommissioned None --

Epstein Cut-Off None Decommissioned Decommissioned None --

Insane Drop None Decommissioned Decommissioned None --

Offshoot None Decommissioned Decommissioned None --

Pete’s Punisher None Decommissioned Decommissioned

 Pedestrian and equestrian only on 

upper 1 mile; decommission lower 

0.3 mile

Please refer to the response to 

Comment 104 for a discussion of why 

the Pete’s Punisher Trail would be 
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Response to Comments

Trail Name Alternative 11 Alternative 2 Alternative 3 Proposed Alternate Managed Uses Discussion

 All non-motorized uses decommissioned under Alternatives 2 

and 3. 

Poison Oak None Decommissioned Decommissioned  All non-motorized uses

Please refer to the response to 

Comment 104 for a discussion of why 

the Poison Oak Trail would be 

decommissioned under Alternatives 2 

and 3. 

Reservoir (East 

Fork) None Decommissioned Decommissioned  All non-motorized uses Pedestrian only

Please refer to the response to 

Comment 112 for a discussion of why 

the Reservoir Trail would be 

decommissioned under Alternatives 2 

and 3. 

Ric’s None Pedestrian and 

equestrian 

Pedestrian and 

equestrian

 Pedestrian only

 Pedestrian and bikes only

 Lower Ric’s – bike only; Upper Ric’s 

– pedestrian and equestrian only

The proposal to designate Ric’s Trail 

as a pedestrian and equestrian trail 

was made, in part, to provide hikers 

and runners an option for accessing 

the 4 Corners Trailhead off Tolman 

Creek Road without the potential for 

conflict with bicycles and 

encroachment onto private property. 

Designating Ric’s Trail as a bicycle 

trail would conflict with long standing 

use patterns in the area, and present 

additional enforcement and user 

conflict concerns.

Freak Went Flyer None Bike Not constructed None --

RIP 1 None Bike Not constructed None --

Wonder None Pedestrian and bike Pedestrian and bike

 All non-motorized uses

 All non-motorized uses, bikes one 

direction (uphill)

 Pedestrian and equestrian only

The proposal to limit the Wonder Trail

to pedestrians and bikes was based 

on a lack of adequate locations for 

other users to pass equestrians on 

trail due to limited visibility and steep 

side slopes, and in recognition that 

the gated Road 2060 provides access 

for many users to the westside of the 

watershed. 

Red Queen None Pedestrian and Pedestrian and  Pedestrian and bike only The Red Queen Trail would provide a 
Draft DN Attachment A Page A - 19 Ashland Trails Project 

Response to Comments

Trail Name Alternative 11 Alternative 2 Alternative 3 Proposed Alternate Managed Uses Discussion

equestrian equestrian  Pedestrian only bike-free opportunity for equestrians 

and pedestrians to access the 

Bandersnatch Trail on City lands. 

Bikes would be restricted to the 

Jabberwocky Trail to separate uses in 

this heavily used area.

Lewis Loop None Pedestrian and 

equestrian

Pedestrian and 

equestrian None --

Shaken None All non-motorized uses All non-motorized uses None --

Not Stirred None Pedestrian and bike Pedestrian and bike  Bike only

The Not Stirred Trail would provide 

an opportunity for multi-use access 

on the westside of the action area, 

where use and user conflict are 

generally much lower due to limited 

access.

Lizard None Bike Bike None --

Bandersnatch None Pedestrian and 

equestrian

Pedestrian and 

equestrian

None --

1 Uses are not managed for these trails under Alternative 1 because they are – and would not become - System Trails subject to Forest Service management.
Draft DN Attachment A Page A - 20 Ashland Trails Project 

Response to Comments

Comment 303: Authorization of Split Rock Trail 

Several commenters suggested the Split Rock Trail should not be authorized as a System Trail 

under any of the alternatives (i.e., there should be no improvement of the existing condition). 

Reasons cited include the need for preserving trail-less backcountry areas; potential impacts to 

rare plants and wildflowers; difficulties in monitoring and enforcing uses in the area; and the 

potential for bicycles to use the trail to create other unauthorized trails downhill from the 

ridgeline. [ATP-14, 23, 57, 86, 91, 116, 117] 

Response: The Split Rock Trail is proposed as a System Trail under Alternatives 2 and 3 to disperse 

use to the west side of the watershed. There are currently several braided trails located in the general 

vicinity of the Split Rock Trail, and dispersed use is anticipated to increase in the future, even if the 

Split Rock Trail is not authorized as a System Trail. Providing a single trail alignment along the 

ridgeline in this area would consolidate use and limit direct impacts to botanical resources as more 

people use the area in the future. 

Please refer to the responses to Comment 107 for consideration of illegal and off-trail uses in the 

action area (including commitments to ongoing monitoring and enforcement); Comment 203 for a 

discussion of impacts to rare plants adjacent to the Split Rock Trail; and Comment 302 for a 

discussion of alternate trail uses considered for the Split Rock Trail. 

The Responsible Official will consider all impacts associated with the Split Rock Trail when making 

a final decision on the proposed action. 

Comment 304: Authorization of Upper Time Warp Trail 

One commenter suggested the Upper Time Warp Trail should not be authorized as a System 

Trail under any of the alternatives due to potential adverse impacts on botanical resources and 

roadless area values. [ATP-116] 

Response: As described in Section 3.4.12 in the EA (page 3-172), the Upper Time Warp Trail is an 

existing historic trail that was in existence as the Mt. Ashland Trail and part of the Forest Service 

trail system until 1954. Under Alternatives 2 and 3, the Upper Time Warp Trail would be authorized 

as a System Trail to disperse use to the west side of the watershed. Approximately 1.0 mile of the 

existing alignment would be rerouted under Alternative 3 to avoid northern spotted owl habitat. 

Although this popular downhill mountain bike trail is currently maintained by local mountain bike 

groups and AWTA as a System Trail, the Forest Service would be responsible for ensuring it is 

sustainably constructed and used. PDC BOT-5 would require the Forest Service to periodically 

monitor the first 1⁄2 mile of the trail alignment to make sure recreational users trying to avoid 

lingering snowfield on the trail do not create brained routes and/or unduly disturb population of 

Henderson’s horkelia or Mt. Ashland lupine (Lupinus aridus ssp. ashlandensis). Preventative 

measures, such as early season closure or awareness signs, would also be considered if warranted. 

Potential effects on the McDonald Peak IRA are described in Section 3.4.11 of the EA (pages 3-164 

to 3-168). The addition of the Upper Time Warp, Split Rock, and Wagner Glade Trails as authorized 

System Trails under Alternatives 2 and 3 would increase the trail area within the IRA by 

approximately 9.2 miles or 5.57 acres (Alternative 2) or 8.8 miles or 5.33 acres (Alternative 3). This 

would likely result in increased use in the IRA, which could impact existing opportunities for 

solitude, quiet, and dispersed recreation. 
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Response to Comments

The Responsible Official will consider all impacts to the IRA and other resources impacted by 

authorization of the Upper Time Warp Trail when making a final decision on the proposed action. 

Substantive Comments - Other

Comment #401: Trail design and signage 

Several commenters suggested that better trail design and signage would improve safety 

conditions and reduce resource damage in the action area. [ATP-16, 17, 18, 21, 26, 29, 33, 34, 

38, 57, 58, 59, 62, 63, 65, 66, 69, 70, 71, 72, 74, 76, 78, 88, 91, 92, 96] 

Response: Section 2.2.3 in the EA (pages 2-2 to 2-4) summarizes the design parameters that would 

be used to construct and maintain all trails in the action area, including tread width, clearing limit, 

target grade, surface material, and slope alignment. All trails would be designed, constructed, and 

maintained to the Trail Class 2 standards provided in the Trails Management Handbook, FSH 

2309.18. The Forest Service will also consider trail specific conditions, topography, and other 

factors (such as mitigation of site-specific safety concerns or adjustments to accommodate other 

resource concerns) in siting and constructing trails under the proposed action. 

All trails will be signed with uses that are excluded and multiuse trails will be signed with trail 

etiquette guidelines to reduce user conflict (see PDC GEN-10). In addition, the Forest Service will 

work closely with user groups and the City of Ashland to develop a revised trail map that clearly 

illustrates managed uses in the action area. 

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ASHLAND TRAILS PROJECT 

DRAFT DECISION NOTICE AND FINDING OF NO SIGNIFICANT 

IMPACT 

ATTACHMENT B 

Draft Environmental Assessment 

Errata

Changes, corrections, and clarifications have been made to the Ashland Trails Project Draft 

Environmental Assessment (EA) based on public and agency comment and internal review by the 

U.S. Forest Service (Forest Service). The changes were made to improve the consistency, clarity, and 

intent of the information provided in the Draft EA, and to respond to comments on the EA analysis. 

These changes, which are summarized in Table 1, are within the scope and analysis of the Draft EA 

and do not change the Forest Service’s consideration or conclusions regarding the environmental 

consequences of the proposed action or alternatives. 

Changes reflected in bold and italics in Table 1 represent additions to the text in the Draft EA; 

changes reflected as strikethrough represent deletions from the text. 

The Draft EA and responses to comments on the Draft EA are available for review in the project 

record at the Star Ranger Station, Jacksonville, Oregon, and will be posted on the project website for 

public review (http://www.fs.usda.gov/project/?project=39748).
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Table 1. Ashland Trails Project Draft EA Errata 

Page Section Errata

Figure 1-2 1.5, Management Direction Figure 1-2 notes the entire National Forest lands lie within Late Successional Reserve land allocation. This 

statement should be clarified to reflect that some small pockets of land within the boundary are not within 

the LSR (e.g., are administratively withdrawn, etc.) (see Figure 3-4).

1-1 1.1, Background Second paragraph: "This increase in use has resulted in increased user conflicts, particularly in the vicinity of 

the City of Ashland, were where the majority..."

1-11 1.5.1, Management Allocation, 

Footnote 1

"Although MS-25 MA-25 is actually identified...."

1-13 1.5.1, Management Allocation, 

Klamath National Forest Land 

Resources Management Plan

The citation for the quoted Standards and Guidelines for the Klamath National Forest LRMP should be USDA 

Forest Service 1995b 1995a, 4-85

2-12 2.3.2, Alternative 2 - Proposed Action First paragraph, first sentence: "Approximately 30.9 miles 31.4 miles of trails would be incorporated into the 

approved trail network in the action area under this alternative including 21.5 miles 22.0 miles of existing 

historic and unapproved trails and 9.4 miles of new proposed trails."

2-12 Table 2-4 Jabberwocky - Length = 1.2 miles 1.7 mile; Total = 30.9 miles 31.4 miles

2-23 Table 2-8 Alternative 2 Existing Historic / Unapproved Trails = 21.5 miles 22.0 miles; Total = 46.7 miles 47.2 miles

2-23 Table 2-8 Purpose and Need Element: Provide a Sustainable Non-Motorized Trail System - Alternative 2: "21.5 miles

22.0 miles of existing historic trails...."

2-24 Table 2-8 Purpose and Need Element: Provide a Trail System Commensurate with Public Demand - Alternative 2: "Total 

System Trails: 46.7 miles 47.2 miles"

2-24 Table 2-8 Purpose and Need Element: Reduce User Conflict - Alternative 2: "Total miles by managed use would 

include...19.9 miles 10.4 miles hiker/pedestrian and bike only uses..."

2-25 Table 2-8 Purpose and Need Element: Reduce Unapproved Trail Proliferation - Alternative 2: "Similar to Alternative 2, 

although total addition to System Trail mileage would be less (30.9miles 31.4 miles)."

2-26 Table 2-8 Effects on Water Quality Due to Erosion and Sediment Delivery: Exceedance of TMDL - Alternative 1: 

"...TMDL load allocations could be exceeded during flood events if legacy stream crossings fail."

2-28 Section 2.5.1, Project Design Criteria 

and Mitigation Measures

"Project design criteria...were developed by the IDT to address site-specific environmental site-specific 

environmental concerns..."

2-36 Section 2.6.2, Safe Trails Plan 

Alternative

First paragraph, fourth sentence: "Similarly, the Windburn Trap Trail would be decommissioned under 

Alternative 3 due to its proximity to spotted owl nest sites, and to minimize potential water quality 

concerns in and around Reeder Reservoir, the source of Ashland's water supply, as a result of ongoing trail 

use."

3-1 Section 3.1.2, Alternatives Evaluated First paragraph, second sentence: "As required by...NEPA, Alternative 1, which indicates what would happen 

if the proposed action were not taken, and provides a baseline to evaluate the impacts of the action 

alternatives."

3-2 Table 3-1 Describing the Ashland Forest Resiliency Project: "Implementation of this project began in the spring of 
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2010."

3-6 Table 3-2 System Trails - Alternative 2 - 46.7 miles 47.2 miles; Total miles - 46.7 miles 47.2 miles

3-6 Table 3-2, Footnote 2 "System Trails are trails that are part of approved trails in the action area, and that are currently managed by 

the Forest Service in accordance with current management plans and FSH 2309.18."

3-11 3.2.1, Background - User Conflict Second paragraph, second sentence: "Trails on the east side of the Ashland watershed can be accessed 

through six locations: the White Rabbit trailhead; the White Rabbit Trail from the Siskiyou Mountain Park; 

the Toothpick Trail from the Tolman Creek Road; the Coggins Saddle (Four Corners) trailhead; the Upper and 

Lower Eastview Trailheads; the Bull Gap (Lower) trailhead; and the Upper Bull Gap/Mt. Ashland Ski area 

Trailhead (Figure 2-3)." Access to the trail system is also provided at locations outside of the Forest 

boundary, including at the White Rabbit Trail from Siskiyou Mountain Park and the Toothpick Trail from 

Tolman Creek Road. 

3-12 3.2.2, Purpose and Need Elements -

Provide a Sustainable Non-Motorized 

Trail System

First paragraph, second sentence: "All of these trails, with the exception of the Reservoir Trail and several 

trails that would be closed under Alternative 3 to avoid northern spotted owl (Strix occidentalis caurina) and 

Pacific fisher (Pekania pennanti) habitat, and minimize potential effects on Late-Successional Reserve (LSR) 

function..."

3-12 3.2.2, Purpose and Need Elements -

Provide a Sustainable Non-Motorized 

Trail System

Second paragraph, second sentence: "Under Alternative 2, 21.5 miles 22.0 miles of existing historic and 

existing unapproved trails would be authorized as System Trails....".

3-12 3.2.2, Purpose and Need Elements -

Provide a Trail System Commensurate 

with Current Public Demand

Second paragraph, third sentence: "Under Alternative 2, a total of 46.7 miles 47.2 miles of System Trails 

would be authorized in the action area....".

3-13 3.2.2, Purpose and Need Elements -

Reduce User Conflict

First paragraph, second sentence: " As described above, both action alternatives would increase the mileage 

of System Trails in the action area compared to Alternative 1 by between 24.9 miles (Alternative 3) and 30.9 

miles 31.4 miles (Alternative 2)."

3-13 3.2.2, Purpose and Need Elements -

Reduce User Conflict

Second paragraph, fourth sentence: "Further out, the Split Rock.....and Upper Time Warp (Alternative 2 only)

Trails..."

3-13 3.2.2, Purpose and Need Elements -

Reduce User Conflict

Fourth paragraph, third sentence: "Under the action alternatives...about 21% 22% (Alternative 2) and 23% 

(Alternative 3) would be managed for hiker/pedestrian and bicycle use....".

3-14 Table 3-3 Alternative 2: (1) All Non-Motorized Uses: 26.9 miles, 57.6% 57.0%; (2) Hiker/Pedestrian, Bicycle: 19.9 miles

10.4 miles, 23.4% 22.0%; (3) Hiker/Pedestrian, Equestrian: 4.0 miles, 8.6% 8.5%; (4) Bicycle: 5.9 miles 12.6% 

12.5%; TOTAL 46.7 miles 47.2 miles

3-15 3.2.2, Purpose and Need Elements -

Reduce Unapproved Trail Proliferation

Second paragraph, third sentence: "The addition of between 24.9 miles (Alternative 3) and 30.9 miles 31.4 

miles (Alternative 2)...."

3-25 Figure3-3b Photo 10: "Approximate location of the Not Stirred trail crossing of a perennial stream/wetland proposed 

under Alternative B Alternative 2. Trail would not cross stream under Alternative C Alternative 3."

3-21 Section 3.3.1, Issue: Potential Effects Second paragraph, third sentence: "Of the subwatersheds in the action area, Ashland Creek contains 
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on Water Quality Due to Erosion and 

Sediment Delivery, Existing Trail 

Conditions

approximately 74% of the excising existing historic...."

3-22 Section 3.3.1, Issue: Potential Effects 

on Water Quality Due to Erosion and 

Sediment Delivery, Existing Trail 

Conditions

First paragraph after Table 3-7, last sentence: "Appendix B summarizes the results of the WEPP prediction 

model." The results of the WEPP prediction model were not included as an appendix to the EA, but can be 

made available on request.

3-30 Section 3.3.1, Issue: Potential Effects 

on Water Quality Due to Erosion and 

Sediment Delivery, Alternative 2, 

Erosion and Sediment Delivery

Last paragraph, third sentence: "When compared to Alternative 1, Alternative 2 would resulting in a longterm..."

3-31 Section 3.3.1, Issue: Potential Effects 

on Water Quality Due to Erosion and 

Sediment Delivery, Alternative 2, 

Erosion and Sediment Delivery

First paragraph, first sentence: "Riparian Reserve disturbance according to proposed managed under 

Alternative 2 is summarized..."

3-31 Section 3.3.1, Issue: Potential Effects 

on Water Quality Due to Erosion and 

Sediment Delivery, Alternative 2, 

Erosion and Sediment Delivery

First paragraph, first complete sentence:"Literature reviews......(...Cole and Spildie 1995 1998...)"

3-39 Section 3.3.1, Issue: Potential Effects 

on Water Quality Due to Erosion and 

Sediment Delivery, Alternative 3, 

Cumulative Effects

First full paragraph, fifth sentence: "As noted above....to coordinate proposed changes to the Forestry

Service trail system."

3-45 Section 3.3.2, Issue: Potential Effects 

on Late-Successional Reserves, Effects 

Mechanisms and Analytic Framework

Second paragraph, last sentence: "This information also informs the analysis provided in Sections 3.3.4, 

3.3.5, and 3.3.6 Sections 3.3.3, 3.3.4 and 3.4.1."

3-48 Section 3.3.2, Issue: Potential Effects 

on Late-Successional Reserves, 

Alternative 2, Direct and Indirect 

Effects

First paragraph, first sentence: "Alternative 2 would result in authorization of 30.9 miles 31.4 miles of new 

System Trails, including 8.7 miles 9.2 miles of existing unapproved trails...."

3-51 Section 3.3.2, Issue: Potential Effects 

on Late-Successional Reserves, 

Cumulative Effects

Fourth paragraph, forth sentence: "The nearest existing, non-System Trail to the Mt. Ashland ski area..."

3-52 Section 3.3.2, Issue: Potential Effects 

on Late-Successional Reserves, 

Summary

First paragraph, last sentence: "The net effect of the Preferred Alternative Alternative 3 when compared to 

existing conditions, the No Action Alternative Alternative 1, and Proposed Action Alternative Alternative 2,

is considered neutral to LSR values."
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3-64 Section 3.3.3, Issue: Potential Effects 

on Northern Spotted Owl and Their 

Habitat, Alternative 3, Direct and 

Indirect Effects

First paragraph, second sentence: "The Winburn Trap Trail would not be authorized for recreational use 

under this alternative, which would remove ongoing disturbance to known owl nest sites in the vicinity, 

which would and reduce impacts to spotted owls compared to Alternatives 1 and 2."

3-67 Section 3.3.3, Issue: Potential Effects 

on Northern Spotted Owl and Their 

Habitat, Summary

First paragraph, last sentence: "Refer to Sections 3.3.4 through 3.3.6 Sections 3.3.4 and 3.4.1 for the 

supporting analysis specific to the other species listed in Table 3-29."

3-70 Section 3.3.4, Issue: Potential Effects 

on Pacific Fisher and Their Habitat, 

Status, Distribution, and Occurrence 

within the Analysis Area

First paragraph, last sentence: "Two recent surveys that have......(Aubry et al. 2005, Farber and Criss 2005

2006)."

3-79 Section 3.4.1, Issue: Potential Effects 

on Forest Service Sensitive Species, 

Management Indicator Species, NWFP 

Survey and Manage Species, Migratory 

Birds, and Other Sensitive Terrestrial 

Species, Background

Third paragraph, first sentence: "The following provides a summary of the management direction specific to 

the noted "special-status" species within the analysis area..."

3-83 Section 3.4.1, Issue: Potential Effects 

on Forest Service Sensitive Species, 

Management Indicator Species, NWFP 

Survey and Manage Species, Migratory 

Birds, and Other Sensitive Terrestrial 

Species, Survey and Manage Species

First paragraph, last sentence: "Management recommendations for the known sites of Chase Chace

sideband..."

3-86 Section 3.4.1, Issue: Potential Effects 

on Forest Service Sensitive Species, 

Management Indicator Species, NWFP 

Survey and Manage Species, Migratory 

Birds, and Other Sensitive Terrestrial 

Species, Northern Bald Eagle

Third paragraph, first sentence: "An active bald eagle nest (Nest 1034) is located east of the action area on 

BLM managed lands around Emigrant Lake the. The nest is located..."

3-87 Section 3.4.1, Issue: Potential Effects 

on Forest Service Sensitive Species, 

Management Indicator Species, NWFP 

Survey and Manage Species, Migratory 

Birds, and Other Sensitive Terrestrial 

Species, Travelling Sideband

First paragraph, second sentence: "It can be found din basalt talus and rock outcrops..."

3-88 Section 3.4.1, Issue: Potential Effects First paragraph, second sentence: "Today it is found in....(Frest and Johannes 1996 1995...)."
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on Forest Service Sensitive Species, 

Management Indicator Species, NWFP 

Survey and Manage Species, Migratory 

Birds, and Other Sensitive Terrestrial 

Species, Siskiyou Hesperian

3-88 Section 3.4.1, Issue: Potential Effects 

on Forest Service Sensitive Species, 

Management Indicator Species, NWFP 

Survey and Manage Species, Migratory 

Birds, and Other Sensitive Terrestrial 

Species, Siskiyou Hesperian

First paragraph, last sentence: "It may occur in...(Frest and Johannes 1996 1995...)."

3-91 Section 3.4.1, Issue: Potential Effects 

on Forest Service Sensitive Species, 

Management Indicator Species, NWFP 

Survey and Manage Species, Migratory 

Birds, and Other Sensitive Terrestrial 

Species, Management Indicator 

Species

First complete paragraph, second sentence: "Indicator species act....Forest Plan (1989 page IV-10 and 11, 

FEIS page III-102)."

3-101 Section 3.4.1, Issue: Potential Effects 

on Forest Service Sensitive Species, 

Management Indicator Species, NWFP 

Survey and Manage Species, Migratory 

Birds, and Other Sensitive Terrestrial 

Species, Alternative 1, Great Gray Owl

Second paragraph, first sentence: "Noise above ambient levels....wood would likely remain very low..."

3-105 Section 3.4.1, Issue: Potential Effects 

on Forest Service Sensitive Species, 

Management Indicator Species, NWFP 

Survey and Manage Species, Migratory 

Birds, and Other Sensitive Terrestrial 

Species, Alternative 2, Great Gray Owl

First paragraph, fourth sentence: "Noise above ambient levels....wood would likely remain very low..."

3-121 Section 3.4.2, Issue - Potential Effects 

on Soil Resources, Alternative 1, Direct 

and Indirect Effects

Second paragraph, third sentence: "Existing historic and unapproved trails currently directly impact about

6.1 acres 6.21 acres of soils within the analysis area (Table 3-40)."

3-134 Section 3.4.3, Issue - Potential Effects 

on Geologic Slope Stability, 

Comparison of Alternatives

Third bullet: "The proposed re-route of the Jabberwocky Trail under Alternatives 2 and 3 would avoid the 

most LHZ 1 and 2 slopes, reducing reduce the percent of trail length along LHZ 1 and 2 slopes to to areas to

between 33% (Alternative 3) and 47% (Alternative 2), relative to (compared to 47% for Alternative 2 and 
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56% for Alternative 1)."

3-141 Section 3.4.5, Issue: Attainment of 

Aquatic Conservation Strategy 

Objectives, 

ACS Objective 2 bullet, third sentence: "Twelve stream crossings would be decommissioned under 

Alternative 3, resulting in a net decrease of four stream crossings in the analysis area (see Table 3-11 Table 

3-16)

3-144 Section 3.4.6, Potential Effects on 

Aquatic Species and Habitats, 

Alternative 1, Coarse and Fine 

Sediment

Second paragraph, second sentence: "However, total annual sediment delivery....erosion predictor model 

(Appendix B), ranges..."

3-155 3.4.9, Issue - Potential Effects on 

Federally-Listed, Forest Service 

Sensitive, NWFP Survey and 

Management Species, or Locally Rare 

Species of Vascular Plants, Bryophytes, 

Lichens, or Fungi - Effects Mechanisms 

and Analytic Framework

First paragraph, first sentence: "As described in detail in Biological Evaluation (Rolle 2014) and Survey and 

Manage Report (Rolle 2013 completed in support of the proposed action...the The effects analysis in this 

section EA is informed by field reconnaissance of the analysis area by the Forest Service botanist in the 

summers of 2011, 2012 and 2013 (Rolle 2013, 2014)."

3-155 3.4.9, Issue - Potential Effects on 

Federally-Listed, Forest Service 

Sensitive, NWFP Survey and 

Management Species, or Locally Rare 

Species of Vascular Plants, Bryophytes, 

Lichens, or Fungi - Effects Mechanisms 

and Analytic Framework

First paragraph, second sentence: "During those surveys, all the existing unapproved and historic trail 

alignments (excluding Lower Marty's and No Candies Trails)..."

3-158 3.4.9, Issue - Potential Effects on 

Federally-Listed, Forest Service 

Sensitive, NWFP Survey and 

Management Species, or Locally Rare 

Species of Vascular Plants, Bryophytes, 

Lichens, or Fungi, Alternative 2, 

Howell's Tauschia

Last paragraph, last sentence: "It is not known if these impacts could be greater, however, than those 

associated with Alternative 1 where the Split Rock Trail would not be reestablished, and recreational use 

would likely remain low but not channeled into specific routes that minimize impacts to tauschia."

3-160 3.4.9, Issue - Potential Effects on 

Federally-Listed, Forest Service 

Sensitive, NWFP Survey and 

Management Species, or Locally Rare 

Species of Vascular Plants, Bryophytes, 

Lichens, or Fungi, Alternative 2, 

Gastroboletus Turbinatus

First paragraph, last sentence: "Although unlikely, this potential impact to gastroboletus turbinatus under 

Alternative 2 would could be similar to greater than Alternative 1 where no trail construction would occur. " 
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3-160 3.4.9, Issue - Potential Effects on 

Federally-Listed, Forest Service 

Sensitive, NWFP Survey and 

Management Species, or Locally Rare 

Species of Vascular Plants, Bryophytes, 

Lichens, or Fungi, Alternative 2, 

Monument Plant

First paragraph, last sentence: "This impact would be similar to Alternative 1. Although no effect on the local 

viability of this species is expected under Alternative 2, the loss of individuals during trail construction 

would be greater than under Alternative 1, where no trail construction would occur."

3-161 3.4.9, Issue - Potential Effects on 

Federally-Listed, Forest Service 

Sensitive, NWFP Survey and 

Management Species, or Locally Rare 

Species of Vascular Plants, Bryophytes, 

Lichens, or Fungi, Alternative 3, Mt. 

Ashland Lupine

First paragraph, second sentence: "Impacts associated with the winter late spring / early summer use of the 

Upper Time Warp Trail when lingering snow banks are present would be minimized..."

3-161 3.4.9, Issue - Potential Effects on 

Federally-Listed, Forest Service 

Sensitive, NWFP Survey and 

Management Species, or Locally Rare 

Species of Vascular Plants, Bryophytes, 

Lichens, or Fungi, Alternative 3, ThreeToothed Horkelia

First paragraph: "The potential direct and indirect effects on three-toothed horkelia under Alternative three

would be the same as those described for Alternative 2 be less than Alternative 2 because the Winburn 

Trap Trail would be decommissioned. PDC BOT-8 and BOT-9 would require that known populations of threetoothed horkelia along the Winburn Trap and Lower Marty's Trails be marked...."

3-161 3.4.9, Issue - Potential Effects on 

Federally-Listed, Forest Service 

Sensitive, NWFP Survey and 

Management Species, or Locally Rare 

Species of Vascular Plants, Bryophytes, 

Lichens, or Fungi, Alternative 3, 

Gastroboletus Turbinatus

First paragraph, last sentence: "This impact is comparable to Alternatives 1. Although unlikely, this potential

impact to gastroboletus turbinatus under Alternative 3 would could be similar to greater than Alternative 1 

where no trail construction would occur. " 

3-162 3.4.9, Issue - Potential Effects on 

Federally-Listed, Forest Service 

Sensitive, NWFP Survey and 

Management Species, or Locally Rare 

Species of Vascular Plants, Bryophytes, 

Lichens, or Fungi, Alternative 3, 

Monument Plant

First paragraph, fourth sentence: "With implementation of this PDC, trail-related impacts to monument 

plants would not be anticipated and would be be minor and would not affect the local viability of this 

species. These impacts would be similar to those associated with Alternative 1. 

6-6 6.3, Chapter 3-Affected Environment & Frest T.J. and E.J. Johannes (1995 and 2000)
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Environmental Consequences

6-7 6.3, Chapter 3-Affected Environment & 

Environmental Consequences

Place carriage return between reference for Leonard et al. (1993) and Lofroth et al. (2010)

6-8 6.3, Chapter 3-Affected Environment & 

Environmental Consequences

Place carriage return between reference for Nice and VanBuskirk (1996) and North Coast Regional Water 

Quality Control Board (2010)

6-8 6.3, Chapter 3-Affected Environment & 

Environmental Consequences

Place carriage return between reference for Nussbaum et. al. (1983) and Olive and Marion (2009) 

6-9 6.3, Chapter 3-Affected Environment & 

Environmental Consequences

Place carriage return between reference for Patton (1994) and Pilgrim and Schwartz (2013)

6-12 6.3, Chapter 3-Affected Environment & 

Environmental Consequences

Add the following reference, as cited on page 3-168 of the EA: USDA Forest Service. 2004. Programmatic 

Agreement Among the United States Department of Agriculture Forest Service Pacific Northwest Region 

(Region 6), the Advisory Council on Historic Preservation, and the Oregon State Historical Preservation 

Officer Regarding Cultural Resources Management in the State of Oregon by the USDA Forest Service. 

June 4.

. 


In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national 

origin, religion, sex, gender identity (including gender expression), sexual orientation, disability, age, marital status, family/parental status, income 

derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in any program or activity conducted or 

funded by USDA (not all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident. 

Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign 

Language, etc.) should contact the responsible Agency or USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA through the 

Federal Relay Service at (800) 877-8339. 

To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, found online at http://www.ascr.usda.

gov/complaint_filing_cust.html and at any USDA office or write a letter addressed to USDA and provide in the letter all of the information requested in 

the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of 

Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; 

or (3) email: program.intake@usda.gov . 

For Further Information Contact:

Brian Long

Siskiyou Mountains Ranger District

6941 Upper Applegate Road

Jacksonville, Oregon 97530

(541) 899-3815 

for the greatest good