CHAPTER 2

Alternatives
Changes Between Draft and Final Environment Impact Statement

Added several Alternatives Considered But Eliminated

Added Alternative 4 to address DEIS comments over service days and barren 

core

Added Forest Plan amendments to Alternatives 2 and 3 to address campsites 

within 200 feet of meadows, streams, lakes, and key interest areas.

Added several mitigation measures.

Expanded the Monitoring Plan.

Made numerous, minor editorial and spelling corrections.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-1 February 2013

Okanogan-Wenatchee National Forest

Chapter

2

Alternatives

Introduction

Chapter 2 describes the proposed action and alternatives to the proposed action, including a no 

action alternative. The Interdisciplinary Team (ID Team) developed alternatives to the proposed 

action that respond to the purpose and need and address Key Issues identified by the public. 

Four alternatives for managing land and resources in the analysis area are described, analyzed, 

and compared. Alternative 1 is the “no action” alternative and would not issue permits to pack 

and saddle stock outfitter-guides; Alternative 2 is the proposed action, Alternative 3 is a 

modification of the proposed action to address issues identified in scoping, and Alternative 4 is a 

modification of the proposed action in response to comments on the Draft Environmental 

Impact Statement. The alternatives are compared, describing the differences among the

alternatives and providing a clear basis for choice to the Responsible Official. This chapter also 

describes the measures necessary to mitigate environmental effects, displays monitoring, and 

shows a summary comparison of the alternatives relative to the issues and the purpose and 

need for action.

This chapter is divided into five sections:

Alternative Development

Alternatives Considered but Eliminated from Detailed Study

Alternatives Considered in Detail

Mitigation Measures for Alternatives 2,3, and 4

Monitoring for Alternatives 2, 3, and 4

Comparison of the Alternatives

Alternative Development

The interdisciplinary team used the Purpose and Need, described in Chapter 1, as a framework 

for alternative formulation. The number of service days in wilderness was based on the range of 

the minimum extent necessary disclosed in the 2012 Needs Assessment. There are no 

limitations on service days outside wilderness, so the number of service days for non-wilderness 

sub-units was established to respond to public comments. 

The original Proposed Action was eliminated from detailed analysis, and the revised Proposed 

Action (see Chapter 1) became Alternative 2. It was evaluated in terms of the issues generated 

during public involvement. Alternative 3, an alternative to the proposed action, was developed 

to address issues raised during scoping, while still providing a portion of the minimum extent 

necessary for commercial services, as described in the purpose and need. Alternative 3 would

meet the purpose and need by issuing 10-year term permits, with a reduced number of annual 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-2 February 2013

Okanogan-Wenatchee National Forest

service days compared to the existing condition. It would also resolve inconsistencies between 

forest plan standards and guidelines for party size and barren core, and address the use of 

campsites within 200 feet of meadows, lakes, streams, and key interest areas.

Alternative 4 was developed to address concerns about the number of service days and the 

amount of barren core in campsites, raised during the public review of the Draft Environmental 

Impact Statement. It would meet the purpose and need by issuing 10-year permits, with an 

increase in service days compared to the existing condition. It would also resolve the 

inconsistencies between the party size and barren core standards and guidelines, and address 

the use of campsites within 200 feet of meadows, lakes, streams, and key interest areas.

A “no action” alternative, Alternative 1, provides a baseline for the environmental effects 

analysis. This alternative would not meet the purpose and need of responding to applications 

for 10-year special use permits for outfitter-guides and of reconciling barren core standards and 

party size standards. It does not meet the minimum extent necessary for commercial services 

and therefore includes the effects of not meeting the Purpose and Need.

Several alternatives were suggested during the public involvement and alternative formulation 

process that did not meet the Purpose and Need, or were outside the scope of the analysis. 

These alternatives are described in the following section. 

Alternatives Considered but Eliminated

The following alternatives were considered by the interdisciplinary team, but eliminated from 

further consideration for the reasons described below.

1. An alternative was considered but eliminated that would increase party size for 

outfitter-guides to 20 people and 35 head of stock, and increase annual service days to 

8,125. Another alternative would have increased the service days to 13,380. Increasing 

the party size in wilderness to any of these levels would have resulted in wilderness 

degradation by increasing the amount of disturbed area in campsites. Since service days 

are calculated based on actual use, there was no justification for increasing the number 

to 8,125 or 13,380. The highest number of service days actually used over the past five 

years, plus 25%, is approximately 4,600. Alternative 4 would authorize 6,700 service 

days, which is the highest amount of actual use in the past 10 years plus 25%. 

2. Alternatives were considered but eliminated that would allow outfitters to use between 

10,000 and 10,890 (1/4 acre) square feet of barren core in existing campsites, or not put 

a limit on barren core. The largest wilderness outfitter-guide camp is Crow Lake, which 

has approximately 9,610 square feet, followed by Sheep Mountain with 8,879 square 

feet. Based on this, allowing barren core to increase to 10,000 square feet or more 

would not be needed, and would lead to wilderness degradation. Alternative 4 would 

allow use of existing barren core in established campsites, with no increase permitted.

3. An alternative was considered that would not amend the Forest Plan to reduce party 

size and increase camp size for all users (outfitted and non-outfitted). The portion of 

the alternative pertaining to non-outfitted users was eliminated from further
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-3 February 2013

Okanogan-Wenatchee National Forest

consideration since it was outside the scope of analysis and purpose and need. 

Decreasing party size and adjusting standards and guidelines pertaining to outfitterguide camps was developed and analyzed as Alternative 3. Decreasing or not increasing 

the barren core size for the pack and saddle stock outfitter-guides was considered but 

eliminated, because it is physically impracticable to fit pack and saddle stock outfitterguide camps with 12 people and 18 head of stock inside areas of from 400 to 1,000 

square feet of bare mineral soil (refer to page C-1 for barren core calculations). There is 

a need to make campsite barren core standards and guidelines and party size 

allowances compatible for pack and saddle stock outfitter-guides in wilderness in order 

to provide the necessary pack and saddle stock outfitter-guide commercial services.

4. An alternative was considered but eliminated that would make no change to Forest Plan 

standards and guidelines for barren core. This alternative also increased the number of 

service days to 7,275. It was identified as the proposed action in the 2005 scoping 

letter. This alternative was eliminated because there is no justification for increasing 

the number of service days to this level, since service day allocation is based on actual 

use (also refer to eliminated alternative #1). It also would not have been consistent 

with existing Forest Plan standards and guidelines pertaining to barren core. The 

existing party size allowing up to 18 head of stock cannot fit into 400 to 1,000 square 

feet of barren core without creating more barren core, and/or endangering the stock 

animals and handlers. 

5. An alternative was considered but eliminated that would amend the Forest Plan to 

reduce outfitter-guide party size to 5 people and 2 head of stock. This alternative was 

not fully developed because the outfitter-guides would not be able to operate 

businesses with such a small party size and thus minimum required commercial services 

would not be provided to the public. The outfitters who use horses and mules typically 

have their clients ride horses, so the party includes at least as many head of stock as 

people, plus additional stock for packing. Elimination of pack and saddle stock outfitterguides is analyzed under Alternative 1, the no action alternative.

6. An alternative was considered but eliminated that would not allow campfires or 

firewood gathering in sub-alpine ecosystems. This alternative was eliminated because 

firewood gathering and campfires by pack and saddle stock outfitter-guides were not 

found to be adversely affecting resources (see Chapter 3.10 Terrestrial Wildlife), 

however, where coarse woody debris is not adequate, firewood gathering would be

prohibited.

7. An alternative to require pack and saddle stock outfitter-guides to bring commerciallyprocessed feed into wilderness, and not allow loose grazing of stock was considered but 

eliminated. This alternative would also require outfitters to bring buckets so water 

could be carried to stock, in order to eliminate stock going to streams, lakes, or 

wetlands. This alternative was eliminated because the analysis did not show that 

current grazing or watering techniques are causing unacceptable impacts to water, soil, 

riparian areas, or plant communities. Loose grazing disperses stock across large areas, 

minimizing impacts to wetlands, soil, and water. If stock were required to be confined 

in camp at all times, the amount of barren core in campsites would likely increase 

because stock confinement areas would be larger as a result of constant use, increasing 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-4 February 2013

Okanogan-Wenatchee National Forest

impacts to water quality, soil, vegetation, and wilderness character (refer to the 

Aquatics, Botany, Hydrology, and Soil sections of Chapter 3).

8. An alternative was considered but eliminated that would prohibit cooking on open fires, 

instead requiring cooking on stoves. This alternative was eliminated because any 

limitation on non-outfitted recreationists is outside the scope of the analysis. Applying 

this limitation to pack and saddle stock outfitter-guides was also eliminated because 

firewood gathering by outfitters, and outfitter campfires were not found to adversely 

affect air quality or the ecosystem (refer to the Terrestrial Wildlife and Specifically 

Required Disclosures, Air Quality).

9. An alternative to prohibit outfitters taking stock trucks on the Harts Pass road was 

considered but eliminated. The Harts Pass road has one short section that is narrow. 

The section has a posted speed limit of 10 miles per hour and has pull-outs to allow 

traffic to pass. Public travel is sufficiently safe; therefore eliminating outfitter-guide 

stock truck use on the road is not necessary.

10. An alternative was considered that would not have amended standard and guideline 

MA15B-21L, so pack and saddle stock outfitter-guides would not be allowed to camp 

within 200 feet of meadows, streams, lakes, or key interest areas, such as Lower 

Cathedral to the US/Canadian border. This would have prohibited outfitters from using 

most of the established campsite they frequent (approximately 86 out of 99) in the 

Pasayten Wilderness and portion of the Lake Chelan-Sawtooth Wilderness on the 

Methow Valley Ranger District.. In order to continue to operate, the pack and saddle 

stock outfitters would need to establish new campsites or increase the size of the 

existing campsites outside this zone. This would degrade wilderness character by 

decreasing opportunities for solitude and increasing campsite density, which would lead 

to increased impacts to soil, water, and vegetation. In addition, the environmental 

analysis of pack and saddle stock outfitter guide activities on meadows, streams, lakes, 

and key interest areas found isolated impacts, but overall all resources were in good 

condition. Therefore, this alternative was eliminated from further consideration. 

11. An alternative to not allow people to travel farther than 20 miles from a trailhead was 

considered but eliminated. It was outside the scope of the analysis since it pertained to 

all people, not just outfitter-guides. Limiting outfitter-guides to an area within 20 miles 

of trailheads was not considered further because the analysis found no environmental 

or social advantage to doing so. Implementation of this alternative would concentrate 

use within the 20 mile zone, leading to resource damage and increased encounters 

between parties, which would have adverse impacts to wilderness character, and would 

be inconsistent with encounter standards and guidelines in the Forest Plans.

12. An alternative was considered that would have limited the amount of client gear and 

food that could be transported to 60 or 70 pounds, and prohibit the use of wall tents. 

Some of the existing outfitters already limit the amount of gear each client can bring, 

and the outfitters are required to stay within the party size limitations. The party size 

limitation dictates the amount of gear and food that can be transported with any group 

of people. The amount of food and personal gear needed varies with the length, type, 

and season of the trip, so setting an arbitrary weight limit would eliminate the flexibility 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-5 February 2013

Okanogan-Wenatchee National Forest

to tailor the amount of gear and food to the type of trip, and could result in additional 

re-supply trips to longer-term camps. There is no need or justification for prohibiting 

wall tents. The Leave-No-Trace booklets advise people to use equipment that keeps 

people safe and comfortable in extreme conditions, which wall tents can do. Refer to 

Mitigation Measures 5 a and b for information on Leave-No-Trace direction for 

outfitters. 

13. An alternative was considered but eliminated that would require the pack and saddle 

stock outfitter-guides to have safe and courteous passage of others on trails, and be 

courteous to people they encounter. The outfitters receive a performance evaluation 

annually, and are rated on their interactions with non-outfitted public. There have been 

very few reported problems over the past 10 years. In addition, interactions on the 

trails require cooperation by all parties, as described in Leave-No-Trace booklets. One 

of the principles of Leave-No-Trace is that groups leading or riding livestock have the 

right-of-way on trails. Hikers should move to the downhill side and talk quietly to riders 

as they pass, since horses and other pack animals frighten easily. No mitigation 

measure is needed.

14. An alternative was considered but eliminated that would have required the outfitters to 

provide maps to all clients and drop camp parties. The Forest Service has never 

received a complaint from an outfitter-guide client about not receiving adequate or 

appropriate information from the outfitter. Outfitter-guides provide wilderness and 

Leave-No-Trace information to clients. The outfitter is able to provide more detailed 

information about the area around camps in full-service or progressive trips, when the 

guide is with the clients throughout the trip. Drop camp clients are responsible for 

having maps and knowing the area where they are dropped. No mitigation measure is 

needed.

15. An alternative was considered but eliminated that would have prohibited the outfitters 

or their clients from discharging weapons except for hunting or protection. This would 

have included shooting rodent such as ground squirrels. The outfitters must follow 

state laws regarding hunting. There are also CFRs about discharging firearms. No 

additional mitigation is needed.

16. An alternative was considered but eliminated that would have required the outfitters to 

provide humane care of their animals. The outfitters are already required to do this. 

Treatment of stock is one of the evaluation criteria in the annual performance review. 

No mitigation measure is needed. 

17. An alternative was considered but eliminated that would have required the outfitters to 

hitch stock in clean, sanitary conditions. Clean, sanitary conditions do not exist in stock 

camps, with the exception of the kitchen or cooking area. Mitigation measure 7b states 

that heavy concentrations of stock manure near campsites or in areas where stock have 

been tied will be scattered to ensure it does not become an attractant for wildlife or 

degrade water or campsite quality. Refer to FEIS page 2-15. The mitigation measure 

identifying loose grazing as the preferred method (8a) helps minimize manure build-up. 

No additional mitigation measure is needed. 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-6 February 2013

Okanogan-Wenatchee National Forest

18. An alternative was considered but eliminated that would have required outfitters to 

extinguish campfires until they are cold before leaving the area. Reports of outfitterguides leaving campfires burning are very rare, but if an outfitter does leave a campfire 

burning, it would violate the CFR 261.5 d. Refer to FEIS page 2-12 for discussion of CRFs 

and Appendix D. CFRs are legal requirements and outfitters must comply with them. 

No mitigation measure is necessary.

19. An alternative was considered but eliminated that would have prohibited loose grazing 

from any camp within two miles of a lake. The outfitters must comply with the CFR and 

standard and guideline prohibiting livestock grazing within 200 feet of lakeshores. The 

Forest Service monitors areas where stock loose graze to ensure utilization standards 

are being met, and that there is no unacceptable resource damage occurring. Loose 

grazing stock may move to lakes to water, but would then return to dryer upland slopes 

where the preferable plant species grow. If outfitter stock were found grazing within 

200 feet of a lake, the outfitter would be required to alter the loose grazing pattern to 

ensure compliance with the CFR. 

20. An alternative was considered but eliminated that would allow current use to continue

without amending the Forest Plan or completing a NEPA analysis. Alternatives that 

would not amend the Forest Plan are discussed in Eliminated Alternatives 3, 4 and 10 

above. The alternative of issuing the permits without NEPA was eliminated because it 

would violate NEPA. Ten-year permits cannot be issued until the environmental analysis 

is completed. All of the Pack and Saddle Stock Outfitter-Guides are operating under 

one-year Special Use Permits that expire on March 31, 2012, and none of them has ever 

held a ten-year permit. 

21. An alternative was considered but eliminated that would set the party size between 12 

heartbeats, and the current 12 people and 18 head of stock. This was eliminated 

because any party size between these two would be within the range set by Alternatives 

2 and 4, and Alternative 3. Another element of the eliminated alternative would be that 

re-supply trips would not be allowed, and only the stock needed to pack parties in and 

out would be allowed. This was eliminated from consideration because it would 

effectively eliminate full-service camps. Most full-service camp parties consist of 4 to 5 

clients, a wrangler, and a cook. Six people riding six horses would be at the party size 

limitation of 12 heartbeats, and leave no room for pack stock. Prohibiting re-supply 

trips to bring the gear and food to these camps would make these trips impossible. Fullservice camps represent a large part of the pack and saddle stock outfitter-guide 

businesses, so no longer being able to offer them would seriously impact the viability of 

the businesses. This would limit access to the wilderness for many people, and not 

meet the minimum extent necessary for commercial services. 

22. An alternative was considered but eliminated that would have closed the Bald Mountain 

camp to outfitter-guide use. The analysis of the camp found that, aside from the impact 

to the near-by wetlands, the camp is having only minimal environmental effects. While 

stock trails through the wetland are trampling hummocks, damaging vegetation, and 

compacting the soil, the impacts are isolated to this small area, and not causing a 

change in natural plant succession, or negatively impacting water quality or soil (outside 

the trail tread). Also, the final recommendations of the Recreation Activity Review did 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-7 February 2013

Okanogan-Wenatchee National Forest

include closing the camp. The Botany/Ecology appendix of the Recreation Activity 

Review did recommend closing the Bald Mountain camp. After further field analysis and 

attempts to locate an alternative camp location, the Forest Service decided to work with 

the outfitter to mitigate impacts from stock traveling through the nearby wetland as an 

alternative to closing the camp (FEIS page Appendix F-3). If conditions become

unacceptable, the camp can be closed, as stated in Mitigation Measure 1g on FEIS page 

2-13.

23. An alternative was considered but eliminated that would provide a list of approved 

camps for parties with 8 or more horses or mules. Outfitters using llamas or burros 

would not be restricted to these campsites. This alternative was eliminated because it is 

not necessary. The outfitters would not be allowed to increase the amount of barren 

core in any campsite, and therefore would only use campsites large enough to 

accommodate the size of the party on any given trip. 

24. An alternative was considered but eliminated that would have established the service 

days included to the highest level of actual use over the past 10 to 15 years, increased 

by 25%. The number of service days in Alternative 4 is the highest amount of actual use 

between 1999 and 2009, increased by 25%. Longer time spans (such as 15 years) were 

considered but eliminated because the intent of the handbook direction is to assign 

service days at levels that reflect current use. Extending the actual use consideration 

period beyond 10 years in the past would inflate use beyond what would likely occur in 

upcoming 10 years. 

25. An alternative was considered but eliminated that would move campsites on a regular 

basis to avoid exceeding bare ground standards. The alternative would have specified 

that campsites be relocated to drier lodgepole forests, and to areas where horses and 

mules have more room to forage, including areas outside the wilderness, such as the 

upper Twisp River. Moving campsites periodically to allow established campsites to 

recover leads to wilderness degradation over time. Vegetation grows slowly in the high 

elevation wilderness areas, and abandoned campsites are commonly used by nonoutfitted parties, so new vegetation does not re-establish. The end product would two 

campsites where there used to be one, and cumulative degradation of wilderness 

character. 

Relocating campsites to drier ecosystems would not be practical. Campsites are located 

at desired destinations, so if these drier ecosystems are not in the vicinity of the desired 

destinations, moving campsites to the ecosystem would not work. Also, campsites in 

drier ecosystems take longer to restore than campsites in moist ecosystems because the 

vegetation grows much faster in wet areas compared to dry areas. The only effective 

way to stop use of an established campsite is for it to become completely re-vegetated 

so people looking for a campsite don’t even see the old camp. Established campsites in 

dry ecosystems tend to remain visible for decades, so use would continue.

The land outside the wilderness boundary in the Twisp River is a narrow band of steep, 

forested slopes with the Twisp River riparian area and the Twisp River Road running 

through the middle. Campsites along this road would not provide the backcountry 

experience the outfitters currently offer, nor would campsites outside of wilderness 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-8 February 2013

Okanogan-Wenatchee National Forest

address the necessity for a minimum amount of outfitter-guide services inside 

wilderness as defined in the Needs Assessment. 

26. An alternative was considered but eliminated that would have reduced party size to the 

number of stock and people that could fit in 400 square feet. The party size would be 

considerably smaller that was analyzed in Alternative 3, and would be similar to 

Eliminated Alternative #5. As with that alternative, the outfitter-guides would not be 

able to operate businesses with such a small party size and thus minimum required 

commercial services would not be provided to the public, but was eliminated from 

detailed study. 

27. The proposed actions from the 2005 scoping letter, and the DEIS (Alternative 2) were 

both eliminated from further consideration. The Forest Service Handbook was revised 

after the 2005 scoping and the number of service days in the proposed action was not 

consistent with the handbook direction for determining service days (FSH 2709.11, 

Chapter 40). It was modified to meet the direction, and the original version was 

eliminated. The proposed action in the DEIS was eliminated when public comments 

pointed out that it did not comply with MA15B-21L, pertaining to camps within 200 feet 

of meadows, lakes, streams, and key interest areas. A forest plan amendment was 

added to the proposed action, and the version in the DEIS was eliminated from further 

consideration. 

Alternatives Considered in Detail

Alternative 1 is the No Action alternative. The Proposed Action is Alternative 2. Alternative 3 

was developed to respond to the issues and would reduce annual service days to 3,125 and not 

include additional assigned sites. Alternative 4 was developed to respond to comments 

regarding barren core and party size that were received in response to the DEIS.

ALTERNATIVE 1--NO ACTION

Objective

Eliminate pack and saddle stock outfitter-guide recreation use within the analysis area. 

Description

This alternative would not issue special use permits to pack and saddle stock outfitter-guides. 

There would be no commercial pack and saddle stock outfitter-guide operations within the 

analysis area.

Mitigation and Monitoring

No specific mitigation or monitoring would occur that is not already prescribed by the Forest 

Plans.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-9 February 2013

Okanogan-Wenatchee National Forest

ALTERNATIVE 2

Objectives

Alternative 2 would:

Provide pack and saddle stock outfitter-guide services in the analysis area, which includes 

the Pasayten and Lake Chelan-Sawtooth Wilderness Areas, North Cascades, Sawtooth 

Backcountry, Middle Methow, Bear/Ramsey/Volstead, and Alta Lake analysis area sub-units 

on the Methow Valley, Tonasket, and Chelan Ranger Districts. 

Resolve inconsistencies between Forest Plan standards and guidelines by amending the 

Okanogan and Wenatchee Forest Plans to allow larger wilderness campsite barren cores to 

accommodate the established party size (12 people and 18 head of stock), and by allowing 

outfitter-guides to use existing camps within 200 feet of meadows, streams, lakes, and key 

interest areas while managing the Wilderness areas to maintain wilderness character.

Provide enough service days in the Pasayten and Lake Chelan-Sawtooth wildernesses to fall 

within the range of service days needed to meet the minimum extent necessary to provide 

commercial services for wilderness appropriate activities.

Authorize the highest amount of actual use service days of the existing pack and saddle 

stock outfitter-guides over the past five years and create a pool of days that will give an 

opportunity for pack and saddle stock outfitter-guides to develop a modest amount of 

growth (25%). This follows Forest Service Handbook 2709.11, Chapter 40 direction for 

determining service days (US Forest Service, 2008a). 

Description

This alternative would issue 10-year term special use permits for pack and saddle stock outfitterguides on the Methow, Chelan, and Tonasket Ranger Districts. Assigned sites (camps and base 

camps) would allow closer monitoring and modification of operations to reduce the size of the 

barren core and address other resource concerns. Assigned camp sites would be used for most 

full-service camps. Appendix A includes a list of authorized campsites. A total of 4,620 annual 

service days would be divided among the outfitters, or replacements who meet term permit 

requirements. The outfitters would have a total of 270 animal unit months for authorized 

grazing.

The service days would be distributed among the different portions of the analysis area, with 

each business receiving approximately the same proportion of service days it had in the past, 

compared to all pack and saddle stock outfitters. Figure 2-1 shows the distribution in the 

different areas. When the 10-year permits are issued, the number of service days allocated to 

each outfitter would be determined by adding the highest actual use in the past 5 years, plus 

25%. Any unallocated service days would be held in pool for outfitters to access on a year-toyear basis if and when demand exceeds individually allocated service days. The number of 

allocated service days would be adjusted at the 5-year mark in the 10-year permits using the 

same technique, without exceeding 4,620.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-10 February 2013

Okanogan-Wenatchee National Forest

Figure 2-1. Alternative 2: Number of Service Days by Area and Total

Area Total Service Days

Pasayten Wilderness 2,000

Lake Chelan-Sawtooth Wilderness 720

(240 on Methow Valley)

(480 on Chelan)

North Cascades 200

Sawtooth Backcountry 400

(140 on Methow Valley)

(260 on Chelan)

Bear/Ramsey 100

North Cascades

(Day Rides)

450

Alta Lake

(Day Rides)

750

Middle Methow 0

Total 4,620

The day rides in the North Cascades and Alta Lake areas are horse riding or hiking with pack 

support for a portion of, or an entire day. Rides range from a half-hour to all day, with the 

majority lasting one hour. Day rides generally leave from private land adjacent to NFS land, and 

occur on trails seldom used by non-outfitted hikers or horseback riders.

The rest of the service days are for overnight camping. Five camp locations would be assigned 

to the horse and mule packers to allow closer monitoring. In the Pasayten Wilderness assigned 

sites (see Map 1-4 in the Map Section of this document) would include camps at Bald Mountain, 

Sheep Mountain, and Beaver Creek, Crow Lake, and Whistler. Assigned sites would be used for 

full-service trips. Outfitters would be allowed to set up camps at these locations, and leave 

them for the entire season. All camp equipment except hitch rails, corrals, and tent poles would 

be removed from the camp at the end of the season, and would not be cached over the winter. 

Camp locations for all other trips would be limited to existing pre-approved locations (refer to 

Appendix A for the majority of consistently used campsites). Camping equipment and supplies 

could not be left in these locations for more than 24 hours when the camp is not occupied.

Existing base camps Andrews Creek, Billygoat, Crater Creek, and Slate Creek trailheads and at 

the Fish Creek Camp would also be assigned as described above. Each location would have 

corrals, livestock watering troughs, and other improvements necessary to protect resources. 

These base camps would provide places where outfitter-guides can keep pack and saddle stock 

during times of high use, and as starting locations where clients meet outfitters.

Forest Plan Amendments

A non-significant amendment would make standards for outfitter-guide campsites more 

compatible with party size limitations and provide for non-degradation of wilderness conditions

as required in Okanogan Forest Plan (USDA Forest Service 1989b) (MA15B-21D, page 4-91). For 

the Wenatchee Forest Plan (USDA Forest Service 1990) the amendment would improve the
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-11 February 2013

Okanogan-Wenatchee National Forest

compatibility of outfitter-guide campsites with some ‘limits of acceptable change’ indicators 

(Table IV-15, page IV-77). The amendment would only apply to pack and saddle stock outfitterguides in the Pasayten and Lake Chelan-Sawtooth Wilderness Areas. The following standard and 

guideline would be added as standard and guideline MA15B-21BB to the Okanogan Forest Plan

and to Table IV-15 on page IV-77 of the Wenatchee Forest Plan:

Pack and saddle stock outfitter-guides shall not be allowed to increase the existing 

amount of barren core (bare, mineral soil) in established campsites. In campsites where 

the existing amount of barren core exceeds 5,250 square feet, outfitter-guides shall not 

use more than 5,250 square feet of the barren core. All pack and saddle stock outfitterguides shall use the same delineated, 5,250 square-foot area for each camp and shall 

not use any area outside of the delineated 5,250 square-foot area.

The Okanogan Forest Plan currently does not allow vegetation loss to exceed 400 square feet 

(MA15B-22B). The Wenatchee Forest Plan allows vegetation loss of up to 1,000 square feet 

(Table IV-15, page IV-77). Due to historical use, including large party-sizes and livestock grazing, 

some existing camps exceed 5,250 square feet. Continued use and short growing seasons have 

perpetuated some of these camps even though livestock grazing is no longer occurring and party 

size is now limited. It is physically impracticable to fit camps with 12 people and 18 head of 

stock inside areas of 400 to 1,000 square feet. Using computations (see Appendix C), 5,250 

square feet was identified as an area in which 12 people and 18 head of stock could reasonably 

camp. This amendment would require outfitter-guides to identify the portion of the impacted 

area for consistent use. This would be included in the Camp Management Plan for each 

campsite. Areas outside of the designated area would not be used, allowing recovery to 

proceed. This amendment would improve the overall trend of non-degradation of wilderness 

conditions.

Another non-significant amendment to the Okanogan Forest Plan would allow pack and saddle 

stock outfitter-guides to use existing campsites within 200 feet of meadows, lakes, streams and 

key interest areas in the Pasayten and Lake Chelan-Sawtooth wilderness areas to avoid 

degradation of wilderness character and resources. The Wenatchee Forest Plan (USDA Forest 

Service 1990) does not have a standard and guideline restricting camping near these features. 

The Okanogan Forest Plan (USDA Forest Service 1989b) includes the following standard and 

guideline: 

MA15B-21L - Campsites should be located at least 200 feet slope distance from 

meadows, lakes, streams, and key interest areas. Camping may be restricted or 

prohibited in certain areas to protect wilderness values.

There are approximately 75 established campsites regularly used by the pack and saddle stock 

outfitter-guides in the Pasayten Wilderness, and approximately 24 in the Okanogan portion of 

the Lake Chelan-Sawtooth Wilderness. Of these 99 existing campsites, 86 fall within 200 feet of 

meadows, streams or lakes or key interest areas. This amendment responds to public 

comments regarding inconsistency with Forest Plan Standards and Guidelines and would allow 

the pack and saddle stock outfitter-guides to use the established campsites in this 200-foot 

zone. The second sentence of the existing standard and guideline would not be amended and 

would still apply to outfitter-guide activities. This amendment would prevent degradation of 

wilderness conditions. The standard and guideline would be amended as follows:
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-12 February 2013

Okanogan-Wenatchee National Forest

MA15B-21L Campsites should be located at least 200 feet slope distance from 

meadows, lakes, streams, and key interest areas, except for established campsites used 

by pack and saddle stock outfitter-guides. Camping may be restricted or prohibited in 

certain areas to protect wilderness values.

Based on direction found in the Forest Service Manual 1926.51 (USDA Forest Service 2006a), 

these are non-significant amendments to both Forest Plans for the following reasons:

The amendments apply only to outfitter-guide use areas in the Pasayten Wilderness and the 

Lake-Chelan-Sawtooth Wilderness (Okanogan Forest Plan Management Area 15B and 

Wenatchee Forest Plan Management Prescription W-1, primitive and semi-primitive 

wilderness classes). There are no established campsites designated for use by the pack and 

saddle stock outfitter in the Transition wilderness class. 

The amendment applies only to pack and saddle stock outfitter-guides and not to other 

users of wilderness. Outfitter-guide use is 10% of overall use in the Pasayten Wilderness 

and 2% of overall use in the Lake Chelan-Sawtooth Wilderness. 

The amendment is designed to avoid degradation of wilderness conditions and limit 

acceptable change; some existing impacts would diminish over time.

No management area boundaries would change.

Therefore amendments are not significant because they are minor changes that do not 

significantly alter the multiple use goals and objectives for long-term land and resource 

management.

ALTERNATIVE 3

Objectives

Alternative 3 would:

Provide pack and saddle stock outfitter-guide services in the analysis area, which includes 

the Pasayten and Lake Chelan-Sawtooth Wilderness Areas, North Cascades, Sawtooth 

Backcountry, Middle Methow, Bear/Ramsey/Volstead, and Alta Lake analysis area sub-units 

on the Methow Valley, Tonasket, and Chelan Ranger Districts. 

Reduce the number of service days to respond to concerns over botany, wetlands, aquatic 

habitat, wilderness character, and terrestrial wildlife.

Reduce the number of service days to address concerns about water quality, wilderness, 

riparian habitat, wildlife, wetlands, and native plant species. 

Resolve inconsistencies between Forest Plan standards and guidelines by amending the 

Okanogan and Wenatchee Forest Plans to reduce maximum party size to 12 heartbeats, 

allow large enough campsite barren cores to accommodate the reduced party size, and by 

allowing outfitter-guides to use existing camps within 200 feet of dry meadows, but 

prohibiting camping within 200 feet of wetlands, streams, lakes, and key interest areas.

Authorize the average number of used service days over the past five years, plus 25% for a 

modest amount of growth. 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-13 February 2013

Okanogan-Wenatchee National Forest

Description

This alternative would issue 10-year term special use permits for pack and saddle stock outfitterguides on the Methow, Chelan, and Tonasket Ranger Districts. Assigned sites (camps and base 

camps) would allow closer monitoring and modification of operations to reduce the size of the 

barren core and address other resource concerns. Assigned camp sites would be used for most 

full-service camps. Appendix A includes a list of authorized campsites. A total of 2,660 service

days would be divided between the outfitters, or replacements for these outfitters who meet

requirements for term permits. The outfitters would have a total of 150 animal unit months for 

authorized grazing.

The service days would be distributed among the different portions of the analysis area, with 

each business receiving approximately the same proportion of service days it had in the past, 

compared to all pack and saddle stock outfitters. Figure 2-2 shows the distribution in the

different areas. When the 10-year permits are issued, the number of service days allocated to 

each outfitter would be determined averaging the amount of actual use in the past 5 years. Any 

unallocated service days would be held in pool for outfitters to access on a year-to-year basis if 

and when demand exceeds individually allocated service days. The number of allocated service 

days would be adjusted at the 5-year mark in the 10-year permits using the same technique, 

without exceeding 2,660.

Figure 2-2. Alternative 3: Number of Service Days by Area and Total

Area Total Service Days

Pasayten Wilderness 1,000

Lake Chelan-Sawtooth Wilderness 320

(100 on Methow Valley)

(220 on Chelan)

North Cascades 180

Sawtooth Backcountry 160

(70 on Methow Valley)

(90 on Chelan)

Bear/Ramsey 50

North Cascades

(day rides)

360

Alta Lake

(day rides)

590

Middle Methow 0

Total 2,660

The day rides in the North Cascades and Alta Lake areas are horse riding or hiking with pack 

support for a portion of, or an entire day. Rides range from a half-hour to all day, with the 

majority lasting one hour. Day rides generally leave from private land adjacent to NFS land, and 

occur on trails seldom used by non-outfitted hikers or horseback riders.

The rest of the service days would be for overnight camping. Sheep Mountain, Crow Lake, and 

Whistler camps would be assigned sites in the Pasayten Wilderness. The pack and saddle stock 

outfitter-guides would not be allowed to use Bald Mountain and Beaver Creek camps because of 

their proximity to wetlands. Two additional existing campsites would be chosen and designated 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-14 February 2013

Okanogan-Wenatchee National Forest

as assigned sites to replace Bald Mountain and Beaver Creek camps. Assigned sites would be

used for full-service trips. Outfitters would be allowed to set up camps at these locations, and 

leave them for the entire season. All camp equipment except hitch rails, corrals, and tent poles 

would be removed from the camp at the end of the season, and would not be cached over the 

winter. Camp locations for all other trips would be limited to existing pre-approved locations

(refer to Appendix A for the majority of consistently used campsites). Camping equipment and 

supplies could not be left in these locations for more than 24 hours when the camp is not 

occupied.

Existing sites for base camps at the Andrews Creek, Billygoat, Crater Creek, and Slate Creek 

trailheads, and at Fish Creek would be assigned as described above. Each location would have 

corrals, livestock watering troughs, and other improvements necessary to protect resources. 

These base camps would provide places where outfitter-guides can keep pack and saddle stock 

during times of high use, and as starting locations where clients meet the outfitters.

Forest Plan Amendments

A non-significant amendment to the Forest Plans would designate a reasonable amount of 

barren core in pack and saddle stock outfitter-guide camps in order to allow these needed 

commercial services to continue. For this alternative the following standards and guidelines 

would be added to the Okanogan and Wenatchee Forest Plans. These standard and guidelines

would pertain only to pack and saddle outfitter-guide operations in the Pasayten and Lake 

Chelan-Sawtooth Wilderness Areas. The Okanogan Forest Plan would be amended by adding 

the following to MA15B-21N and the Forest Plan would be amended by adding the following to 

the party size limitation on page IV-74:

Pack and saddle stock outfitter-guides shall have a maximum party size of 12 (combination 

of people and stock).

The Okanogan Forest Plan would be amended by adding the following to MA15B-22B and the 

Wenatchee Forest Plan would be amended by adding the following to Table IV-15, page IV-77:

Pack and saddle stock outfitter-guides shall not be allowed to increase the existing 

amount of barren core (bare, mineral soil) in established campsites. In campsites where 

the existing amount of barren core exceeds 2,800 square feet, outfitter-guides shall not 

use more than 2,800 square feet of the barren core. All pack and saddle stock outfitterguides shall use the same delineated, 2,800 square-foot area for each camp and shall 

not use any area outside of the delineated 2,800 square-foot area.

Another non-significant amendment to the Okanogan Forest Plan would allow pack and saddle 

stock outfitter-guides to use existing campsites within 200 feet of dry wetlands, but prohibit 

camping within 200 feet of wetlands, lakes, streams and key interest areas in the Pasayten and 

Lake Chelan-Sawtooth wilderness areas. The Wenatchee Forest Plan (USDA Forest Service 1990) 

does not have a standard and guideline restricting camping near these features and 

inconsistencies with this Forest Plan standard and guideline. The Okanogan Forest Plan (USDA 

Forest Service 1989b) includes the following standard and guideline (MA 15B-21L). 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-15 February 2013

Okanogan-Wenatchee National Forest

Campsites should be located at least 200 feet slope distance from meadows, lakes, 

streams, and key interest areas. Camping may be restricted or prohibited in certain 

areas to protect wilderness values.

There are approximately 75 established campsites regularly used by the pack and saddle stock 

outfitter-guides in the Pasayten Wilderness, and approximately 24 in the Okanogan portion of 

the Lake Chelan-Sawtooth Wilderness. Of these, 86 fall within 200 feet of meadows, streams, 

lakes, or key interest areas. “Meadow” is a vegetation description that applies to a broad range 

of conditions, from dry, open fields to wetlands (including wet meadows). Prohibiting camping 

within 200 feet of wetlands, streams, lakes, or key interest areas responds to concerns raised 

during the public review of the Draft Environmental Impact Statement about impacts to these 

features. There are 46 established campsites that are within 200 feet of wetlands, streams, 

lakes, and key interest areas, and pack and saddle stock outfitter-guides use would not be 

authorized in these. There would be 53 campsites available for pack and saddle stock use. The 

amended standard and guideline would read as follows:

MA15B-21L Campsites should be located at least 200 feet slope distance from dry 

meadows, wetlands, lakes, streams, and key interest areas, except for established 

campsites used by pack and saddle stock outfitter-guides within 200 feet of dry 

meadows. Camping may be restricted or prohibited in certain areas to protect 

wilderness values.

Based on direction found in the Forest Service Manual 1926.51 (USDA Forest Service 2006a), 

these are non-significant amendments to both Forest Plans for the following reasons:

The amendments apply only to outfitter-guide use areas in the Pasayten Wilderness and the 

Lake-Chelan-Sawtooth Wilderness (Okanogan Forest Plan Management Area 15B and 

Wenatchee Forest Plan, WI-1 primitive and semi-primitive wilderness classes). There are no 

established campsites designated for use by the pack and saddle stock outfitter in the 

Transition wilderness class. 

The amendments apply only to pack and saddle stock outfitter-guides and not to other users 

of wilderness. Outfitter-guide use is 10% of overall use in the Pasayten Wilderness and 2% 

of overall use in the Lake Chelan-Sawtooth Wilderness. 

The amendments are designed to avoid degradation of wilderness conditions and limit 

acceptable change; some existing impacts would diminish over time.

No management area boundaries would change.

Therefore the amendments are not significant because they are minor changes that do not 

significantly alter the multiple use goals and objectives for long-term land and resource 

management.

ALTERNATIVE 4

Objectives

Alternative 4 would:

Provide pack and saddle stock outfitter-guide services in the analysis area, which includes 

the Pasayten and Lake Chelan-Sawtooth wilderness areas, North Cascades, Sawtooth 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-16 February 2013

Okanogan-Wenatchee National Forest

Backcountry, Middle Methow, Bear/Ramsey/Volstead, and Alta Lake analysis area sub-units 

on the Methow Valley, Tonasket, and Chelan Ranger Districts. 

Resolve inconsistencies between Forest Plan standards and guidelines by amending the 

Okanogan and Wenatchee Forest Plans to allow large enough campsite barren cores to 

accommodate the established party size (12 people and 18 head of stock), and by allowing 

outfitter-guides to use existing camps within 200 feet of meadows, streams, lakes, and key 

interest areas, while managing the Wilderness Areas to maintain wilderness character.

Increase service days in the Pasayten and Lake Chelan-Sawtooth wildernesses to meet the 

upper range of the minimum extent necessary determination. 

Establish a number of authorized service days that matches the highest amount used by the 

outfitters over the past ten years plus 25%. Assign service days to permits following 

handbook direction (highest actual use levels in the past five years), and create a pool of 

days with the remaining service days that will give an opportunity for pack and saddle stock 

outfitter-guides businesses to meet the demand for services seen in the early 2000s. 

Description

This alternative would issue 10-year term special use permits for pack and saddle stock outfitterguides on the Methow, Chelan, and Tonasket Ranger Districts. Assigned sites (camps and base 

camps) would allow closer monitoring and modification of operations to reduce the size of the 

barren core and address other resource concerns. Assigned camp sites would be used for most 

full-service camps. Appendix A includes a list of authorized campsites. A total of 6,700 annual 

service days would be divided among the outfitters, or replacements who meet term permit 

requirements, and a pool of priority use service days. The outfitters would have a total of 390

animal unit months for authorized grazing.

The service days would be distributed among the different portions of the analysis area, with 

each business receiving approximately the same proportion of service days it had in the past, 

compared to all pack and saddle stock outfitters. Figure 2-3 shows the distribution in the 

different areas. When the 10-year permits are issued, the number of service days allocated to 

each outfitter would be determined by adding the highest actual use in the past 5 years, plus 

25%. Any unallocated service days would be held in pool for outfitters to access on a year-toyear basis if and when demand exceeds individually allocated service days. The number of 

allocated service days would be adjusted at the 5-year mark in the 10-year permits using the 

same technique, without exceeding 6,700.

Figure 2-3. Alternative 4: Number of Service Days by Area and Total

Area Total Service Days

Pasayten Wilderness 2,170

Lake Chelan-Sawtooth Wilderness 825

North Cascades 200

Sawtooth Backcountry 805

Bear/Ramsey 100

North Cascades

(Day Rides)

1,150

Alta Lake

(Day Rides)

1,450

Middle Methow 0

Total 6,700
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-17 February 2013

Okanogan-Wenatchee National Forest

The day rides in the North Cascades and Alta Lake areas are horse riding or hiking with pack 

support for a portion of or an entire day. Rides range from a half-hour to all day, with the 

majority lasting one hour. Day rides generally leave from private land adjacent to NFS land, and 

occur on trails seldom used by non-outfitted hikers or horseback riders.

The rest of the service days are for overnight camping. Five camp locations would be assigned 

to the horse and mule packers to allow closer monitoring. In the Pasayten Wilderness assigned 

sites (see Map 1-4 in the Map Section of this document) include camps at Bald Mountain, Sheep 

Mountain, and Beaver Creek, Crow Lake, and Whistler. Assigned sites would be used for fullservice trips. Outfitters would be allowed to set up camps at these locations, and leave them for 

the entire season. All camp equipment except hitch rails, corrals, and tent poles would be 

removed from the camp at the end of the season, and would not be cached over the winter. 

Camp locations for all other trips would be limited to existing pre-approved locations (refer to 

Appendix A for the majority of consistently used campsites). Camping equipment and supplies 

could not be left in these locations for more than 24 hours when the camp is not occupied.

Existing base camps Andrews Creek, Billygoat, Crater Creek, and Slate Creek trailheads and at 

the Fish Creek Camp would be assigned as described above. Each location would have corrals, 

livestock watering troughs, and other improvements necessary to protect resources. These base 

camps would provide places where outfitter-guides could keep pack and saddle stock during 

times of high use, and as starting locations where clients meet outfitters.

Forest Plan Amendments

A non-significant amendment would make standards for outfitter-guide campsites more 

compatible with party size limitations and provide for non-degradation of wilderness conditions 

as required in Okanogan Forest Plan (USDA Forest Service 1989b) (MA15B-21D, page 4-91). For 

the Wenatchee Forest Plan (USDA Forest Service 1990) the amendment would improve the 

compatibility of outfitter-guide campsites with some ‘limits of acceptable change’ indicators 

(Table IV-15, page IV-77). The amendment would only apply to pack and saddle stock outfitterguides in the Pasayten and Lake Chelan-Sawtooth Wilderness Areas. The Okanogan Forest Plan 

would be amended by adding the following to MA15B-22B and the Wenatchee Forest Plan 

would be amended by adding the following to Table IV-15, page IV-77:

Pack and saddle stock outfitter-guides are allowed to use existing barren core in 

established campsites, but shall not be allowed to increase the amount of barren core 

(bare, mineral soil. 

The Okanogan Forest Plan currently does not allow vegetation loss to exceed 400 square feet 

(MA15B-22B). The Wenatchee Forest Plan allows vegetation loss of up to 1,000 square feet 

(Table IV-15, page IV-77). Due to historical use, including large party-sizes and livestock grazing, 

many existing camps exceed these levels. Continued use and short growing seasons have 

perpetuated barren core in some of these camps even though livestock grazing is no longer 

occurring and party size is now limited. It is physically impracticable to fit camps with 12 people 

and 18 head of stock inside areas of 400 to 1,000 square feet. The existing amount of barren 

core in campsites currently used by the outfitters is large enough to accommodate the party 

size. All campsites with more than 5,250 square feet of barren core would have a Camp 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-18 February 2013

Okanogan-Wenatchee National Forest

Management Plan to track the barren core and ensure it is not increasing. This amendment 

would continue the overall trend of non-degradation of wilderness conditions, specifically 

related to campsite conditions.

Another non-significant amendment to the Okanogan Forest Plan would allow pack and saddle 

stock outfitter-guides to use existing campsites within 200 feet of meadows, lakes, streams and 

key interest areas in the Pasayten and Lake Chelan-Sawtooth wilderness areas to avoid 

degradation of wilderness character and resources. The Wenatchee Forest Plan (USDA Forest 

Service 1990) does not have a standard and guideline restricting camping near these features. 

The Okanogan Forest Plan (USDA Forest Service 1989b) includes the following standard and 

guideline (MA 15B-21L). 

Campsites should be located at least 200 feet slope distance from meadows, lakes, 

streams, and key interest areas. Camping may be restricted or prohibited in certain 

areas to protect wilderness values.

There are approximately 75 established campsites regularly used by the pack and saddle stock 

outfitter-guides in the Pasayten Wilderness, and approximately 24 in the Okanogan portion of 

the Lake Chelan-Sawtooth Wilderness. Of these 99 existing campsites, 86 fall within 200 feet of 

meadows, streams or lakes or key interest areas. This amendment responds to public 

comments regarding inconsistency with Forest Plan Standards and Guidelines and would allow 

the pack and saddle stock outfitter-guides to use the established campsites in this 200-foot 

zone. The second sentence of the existing standard and guideline would not be amended and 

would still apply to outfitter-guide activities. This amendment would prevent degradation of 

wilderness conditions. The standard and guideline would be amended as follows:

MA15B-21K Campsites should be located at least 200 feet slope distance from 

meadows, lakes, streams, and key interest areas, except for established campsites used 

by pack and saddle stock outfitter-guides. Camping may be restricted or prohibited in 

certain areas to protect wilderness values.

Based on direction found in the Forest Service Manual 1926.51 (USDA Forest Service 2006a), 

these are non-significant amendments to both Forest Plans for the following reasons:

The amendments apply only to outfitter-guide use areas in the Pasayten Wilderness and the 

Lake-Chelan-Sawtooth Wilderness (Okanogan Forest Plan Management Area 15B and 

Wenatchee Forest Plan, WI-1 primitive and semi-primitive wilderness classes). There are no 

established campsites designated for use by the pack and saddle stock outfitter in the 

Transition wilderness class. 

The amendments applies only to pack and saddle stock outfitter-guides and not to other 

users of wilderness. Outfitter-guide use is 10% of overall use in the Pasayten Wilderness 

and 2% of overall use in the Lake Chelan-Sawtooth Wilderness. 

The amendments are designed to avoid degradation of wilderness conditions and limit 

acceptable change; some existing impacts would diminish over time.

No management area boundaries would change.

Therefore the amendments are not significant because they are minor changes that do not 

significantly alter the multiple use goals and objectives for long-term land and resource 

management.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-19 February 2013

Okanogan-Wenatchee National Forest

Mitigation Measures for Alternatives 2, 3, and 4

These measures would be used to reduce negative effects on project area resources. They are 

considered part of the alternatives and would be incorporated as such. All mitigation measures 

listed are common to Alternatives 2, 3 and 4, unless otherwise noted, and will be required if one 

of these alternatives is implemented. Mitigation measures are designed to ensure that human 

activities in wilderness shall follow a non-degradation policy (Okanogan Forest Plan Standard 

and Guideline MA15B-21D) within the limits of acceptable change (Wenatchee Forest Plan WI-1 

Management Prescription and Table IV-15, page IV-77).

These mitigation measures also serve as the Best Management Practices (BMP) to protect water 

quality, as required by the Forest Plans.

In addition to the measures listed below, Appendix D lists general prohibitions and prohibitions 

listed in prior Okanogan and Wenatchee National Forest orders for specific wilderness and 

backcountry areas under 36 CFR (Code of Federal Regulations) 261. All applicable prohibitions 

are legal mitigation established for resource protection and are incorporated by reference. 

This list of mitigation measures would become standard practice for the pack and saddle stock 

outfitter-guides and incorporated into annual operating plans if one of the action alternatives is 

selected for implementation. Placing them in the operating plan would be an effective way of 

insuring they are followed, since the outfitters would risk non-compliance and permit action if 

they do not comply.

1. Campsites

The objective of the following measures would be to protect wilderness character, and 

minimize the effect of camps on vegetation, wildlife habitat, water quality, aquatic habitat, 

and soil. 

a) All camp locations, including full-service and drop camps, will be approved prior to use. 

If an alternative campsite must be used due to occupation or emergency, the outfitter 

will select an established campsite large enough to accommodate the party size. The 

outfitter will notify the permit administrator within one week from the end of the trip in 

which an alternate location is used.

b) Camp Management Plans will be developed for assigned sites. Camp facilities for the 

necessary level of operation will be identified and excess facilities phased out. Any new 

facilities constructed for resource protection should be located to the extent practical in 

areas where visual impact would be minimal, and be constructed of native materials. 

The facilities cannot be for comfort or convenience. Excess areas of compacted bare 

mineral soil will be identified for each assigned camp. Activities that prevent the 

revegetation or recovery of these excess areas will not be allowed. All equipment and 

materials that have been or will be transported into the wilderness will be taken out at 

the end of the authorized period of use each season.

c) In established campsites within wilderness where the existing amount of barren core 

exceeds 5,250 square feet (Alternative 2) or 2,800 square feet (Alternative 3), outfitter-
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-20 February 2013

Okanogan-Wenatchee National Forest

guides will not be allowed to use more than the specified amount of barren core. Camp 

Management Plans will be developed for these sites, with the specific area of allowed 

use identified in the plan. The same camp area will be used on successive visits by all 

outfitters.

d) In Alternative 4, outfitter-guides would be allowed to use all existing barren core in 

established campsites. A camp management plan would be developed for all campsites 

with more than 5,250 square feet of barren core. 

e) Outfitter-guides shall use existing barren core areas in wilderness campsites. The 

objective of this mitigation is that the outfitters would not create new or additional 

barren core or bare mineral soil1. Temporary increases could occur with prior approval 

if camps are being restructured or if camp sections are being restored, but over time, no 

net increase in barren core would be allowed.

f) Outfitter-guides shall not create any new exposed tree roots. 

g) Outfitters will be prohibited from creating new campsites. The Forest Service will close 

camps when needed to protect resources. If an assigned site must be closed, another 

existing campsite of sufficient size could be designated as assigned. 

2. Campsite Use Limitations

The objective of the following measures is to minimize the chance that pack and saddle 

stock outfitter-guide uses displaces non-outfitted users. 

a) Outfitted pack and saddle stock use at Hidden Lakes will be limited to two parties at a 

time and to two or three parties at a time at Spanish Camp/Remmel Lake, Corral Lake, 

and Crow Lake, except during the September hunting season. This will be accomplished 

during itinerary review and scheduling and through permit administration. Assigned 

sites in these locations could be relocated if necessary to sufficiently sized established 

camps, but there would be no more than 2 assigned sited in each area at any time.

b) Camping at Silver Lake, Buckskin Lake, Ferguson Lake, Fred Lake, and Doris Lake would 

be limited to drop camps (no overnight stock).

c) Camping at Black Lake would be limited to drop camps (no overnight stock), with none 

on weekends or holidays between Memorial Day and Labor Day.

d) A limited number of full-service camps would be allowed at Oval Lakes. The trips would 

not be back-to-back, rather separated in time to allow the graze to recover. A 

controlled number of drop camps, when stock do not remain overnight, would be 

allowed.

 

1

All barren core measurements are approximate. Repeat measurements of barren core will fluctuate from one year 

to the next based on use patterns, weather (influencing vegetation growth), and accuracy and pattern of actual 

measurements. Refer to Wilderness Section in Chapter 3 for more information.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-21 February 2013

Okanogan-Wenatchee National Forest

e) Approval for camping at North Lake and Louis Lake would be made on a case-by-case 

basis considering time of year, number of clients, camp location, and other factors. Only 

drop camps would be approved, with none on weekends or holidays between Memorial 

Day and Labor Day.

f) No pack and saddle stock outfitter-guide camps would be allowed at Twisp Pass or Libby 

Lake.

g) Camping at Star Lake, Tuckaway Lake, Bernice Lake, and Surprise Lake would be limited 

to drop camps (no overnight stock). 

h) Non-assigned sites will be available on a “first-come, first-served” basis for either 

commercial or non-commercial camping purposes. No outfitter shall move or remove 

any other parties equipment at non-assigned sites. All equipment and materials will be 

taken out of non-assigned sites at the end of each trip.

3. Campfires and Firewood

The objectives of the following measures would be to minimize potential impacts to wildlife 

and aquatic habitat and wilderness character.

a) Campfires are prohibited where down wood is insufficient for large woody debris 

habitat requirements.

b) Downed trees larger than 12 inches in diameter located within 200 feet of streams will 

not be used for firewood.

c) No standing trees, including snags, will be cut or damaged, nor will any material be 

attached to trees with nails or wire. On rare occasions, standing trees or snags may be 

cut if an immediate, unavoidable safety hazard is posed. 

d) At assigned sites, firewood will be stored without a covering and out of sight of any 

Forest Service system trail. Only the amount of firewood to be utilized for the current 

use season will be stored. Skidding of firewood with stock is prohibited. Firewood 

storage is prohibited at non-assigned sites.

4. Regulations

The objective of the following measures is to ensure outfitter-guides and clients adhere to 

all rules and regulations.

a) All outfitter-guides and clients are subject to the same rules and regulations that pertain 

to the non-guided public regarding travel on roads and trails, and camping in 

backcountry and wilderness. Outfitter-guides shall review with clients pertinent 

regulations and appropriate use practices for backcountry and wilderness travel 

including those posted at trailheads and/or referenced in the operating plan. This 

applies to drop-camp clients as well as to guided groups.

b) All applicable regulations will be reviewed with clients including any special orders 

establishing use restrictions at specific areas (see Appendix D).
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-22 February 2013

Okanogan-Wenatchee National Forest

5. Leave-No-Trace

The objective of the following measures is to minimize impacts to wilderness character.

a) Pack and saddle stock outfitters-guides will follow Leave-No-Trace principles. LeaveNo-Trace is not a dogmatic approach to camping, horse use, or backcountry behavior, 

but rather a guide for minimizing impacts. The key to minimizing impact is to develop 

the necessary judgment and experience base to effectively make the appropriate 

decision for a given situation. The pack and saddle stock outfitters-guides have choices 

when practicing Leave-No-Trace techniques. Because of site-specific environmental 

conditions, low-impact practices are subject to variations and outfitters may choose 

among those variations to fit specific circumstances. 

b) Outfitter-guides will review Leave-No-Trace practices with clients, including those at 

drop camps. Specific educational tools to be employed will be detailed in operating 

plans. Instruction on minimum impact will begin prior to the trip so clients arrive both 

mentally and physically prepared. Instruction will continue during the trip so clients 

understand the importance of using these techniques and can implement them 

consistently. Outfitter-guides will also teach clients about wilderness values as 

described in the Wilderness Act of 1964.

6. Trails

The objectives of the following measures are to prevent an increase in trail density and 

unauthorized trail construction.

a) Outfitted pack and saddle stock use in wilderness will be limited to existing trails with 

well-established tread. Constructing, placing or maintaining any kind of trail or other 

improvement on National Forest System land without a special use authorization, 

contract, or approved operating plan is prohibited (36 CFR 261.10a).

b) Trail maintenance work needed for operations will be restricted to the maintained 

Forest Service system trails and access trails to established camps, unless prior approval 

is granted. Maintenance will be consistent with Forest Service trail standards and 

requires prior Forest Service approval.

c) Pack and saddle stock outfitter-guides will be prohibited on the Easy Pass, Rainy Lake, 

Lake Ann, Blue Lake and Washington Pass trails.

7. Sanitation and Litter

The objective of the following measures is to ensure that human waste, manure, garbage, 

hunting refuse, and dead stock animals do not become an attractant for wildlife or degrade 

water or campsite quality.

a) All human excrement and toilet paper will be disposed of properly by burying it in a 

small shallow hole at least 200 feet from any water source, or by packing it out. A slit 

trench or latrine may be used where there are more than 12 person days in a camp, or if 

a guide determines that clients lack judgment to properly use shallow holes. Slit 

trenches will be completely covered over and camouflaged when camp is vacated.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-23 February 2013

Okanogan-Wenatchee National Forest

b) Heavy concentrations of stock manure near campsites or in other areas where stock 

have been tied or held will be scattered away from open water.

c) Parties engaged in hunting will ensure that stripped carcasses, gut-piles, hides, or other 

such refuse are disposed of away from campsites, trails, and sources of water.

d) In the event that pack or saddle stock should die on National Forest System land, the 

District shall be notified promptly, and the outfitter will properly dispose of the dead 

animal by dragging it at least one-quarter mile from system trails, blowing it up, or 

cutting it up and scattering the pieces.

e) All non-combustible garbage will be packed out of campsites at the end of each trip. 

Combustible items must either be burned or packed out at the end of each trip.

8. Stock Grazing and Containment

The objective of the following measures is to minimize the effects of stock grazing on 

wetlands, sensitive plants, water quality, vegetation, and aquatic habitat.

a) Loose grazing is the preferred method for outfitter stock to reduce resource damage 

from concentrated use.

b) Location of overnight stock handling facilities (corrals, hitch rails, highlines) would be 

designated and approved, and constructed out of native materials. Facilities will be 

designed to adequately handle concentrated stock use to minimize off-site effects.

c) Based on submitted itineraries and known resource conditions, outfitters may be 

required to carry supplemental feed. 

d) Overnight picketing of stock in subalpine meadows will not be allowed. 

e) Outfitter-guide pack and saddle stock grazing could be limited to designated suitable 

grazing areas during times of high use, or in areas of high use.

f) Stock must be ridden, or led, except when grazing, and not permitted to run loose on 

trails or travel routes.

g) Where and whenever it becomes necessary to restrict or limit the use of native forage 

by pack and saddle stock for resource protection, the outfitter may be required to pack 

in and supply all necessary feed when range conditions do not allow loose grazing of 

pack stock.

h) Outfitter-guide pack and saddle stock will not be allowed to graze in the meadows at 

Rainy Lake turnoff or in Whistler Basin.

i) Stock containment areas within campsites must be located at least 200 feet from 

lakeshores.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-24 February 2013

Okanogan-Wenatchee National Forest

j) In campsites within the Chelan Ranger District portion of the Lake Chelan-Sawtooth 

Wilderness, tie stock on well-placed high lines during periods when not feeding, and fed 

animals in nose bags or feed bags to avoid littering a site.

9. Party Size

The objectives of the following measures are to help reduce impacts from outfitter-guide 

camps in terms of size and grazing impacts.

a) Party size over the established limits must be requested by outfitter-guides at least 

seven days in advance of departure. Oversize parties may be approved based on factors 

listed in Okanogan Forest Plan standard and guideline MA15B-21N, and in the 

Wenatchee Forest Plan on page E-4, item 1.f. 

b) Party size outside wilderness will be designated in the outfitter-guide operating plan.

c) Only stock necessary for each trip will be permitted. 

10. Vegetation and Soils

The objective of the following measures is to minimize effects of pack and saddle stock 

outfitter-guides on vegetation and soil.

a) Other than approved trail maintenance work along Forest Service system trails, green 

trees and other live vegetation shall not be cut or removed, and efforts will be taken to 

minimize trampling or other damage to vegetation beyond those impacts likely to 

recover within one growing season.

b) Soils displaced by activities such as latrine construction or pawing by stock will, to the 

extent practical, be replaced or smoothed out.

c) Stock travel routes through wetlands and wet meadows would be managed to 

concentrate stock on a minimum number of pathways by placing obstacles in braided 

trail areas a way to minimize trails and damage to vegetation and soil. 

11. Wildlife

The objective of the following measures is to comply with habitat management 

requirements for threatened and endangered species, and to reduce the possibility of 

negative encounters between people and wildlife.

a) Feeding or harassing of wildlife will be prohibited. Activities that may disrupt wildlife, 

such as chasing wildlife or making excessive noise, shall be avoided. When observing 

animals, outfitters shall keep a distance to avoid influencing animal behavior, generally 

100 to 300 feet or more, when possible.

b) Outfitter-guides with clients engaged in hunting shall discuss the importance of 

distinguishing between grizzly bears and black bears, between lynx and bobcats, and 

between wolves and coyotes. It shall also be emphasized that grizzly bears, lynx, and 

wolves are protected by Federal law.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-25 February 2013

Okanogan-Wenatchee National Forest

c) Outfitter-guides and clients shall securely store, using wildlife-resistant containers or 

hanging methods, all food, garbage, toiletries, and other possible wildlife attractants. 

These measures will be discussed with clients. Outfitters shall follow any additional 

guidelines provided by wildlife biologists in regards to acceptable food and trash 

handling/storage methods.

d) Negative encounters with bears (either grizzly bear or black bear) will be reported to the 

Methow Valley or Chelan Ranger Districts. Sightings of grizzly bears will be reported as 

soon as possible to either District.

e) Rodent control, other than rat or mouse traps, is prohibited.

f) Salt use will be approved in advance and applied in such a manner as to minimize 

wildlife attraction, and avoid trampling disturbance, such as keeping salt on a tarp or in 

a container to reduce the amount leaching into the soil. Salt will be removed when 

camps are not occupied.

g) Outfitter-guides must maintain control of dogs at all times, and must not menace of 

annoy other visitors, stock, or wildlife.

12. Aquatic Resources

The objective of the following measures is to comply with habitat management 

requirements for threatened and endangered species, and to ensure compliance with 

Aquatic Conservation Strategy and Riparian Management Objectives.

a) Train outfitter-guides who use areas with bull trout spawning how to identify bull trout 

redds so they can be avoided at trail-stream crossings. 

b) Outfitter-guides who provide angling services or activities shall provide fishing 

regulations and bull trout identification information to personnel and clients.

c) The Fish Camp campsite in the Wolf Creek drainage and Drop Camp G in the upper Lost 

River area will be closed to camping from September 1 through October 15 to reduce 

the risk of trampling redds.

d) Along Wolf Creek and the Lost River areas at Hidden and Cougar Lakes and Diamond 

Creek that contain bull trout, outfitter-guides and clients will not wade in streams from 

September 1 to October 15 to minimize the possibility of disturbing bull trout redds. 

e) Hazardous material handling or storage (including fuel) will be located at least 200 feet 

from lakes and streams.

f) The fish screen on the transmission line leading to the stock watering tank in the 

Andrews Creek base camp would be improved to meet the NMFS criteria. 

g) Outfitter-guides would be limited to using the Thirtymile Ford up to two times or four 

river crossings each year. If redds are located within the vicinity of the ford, stock would

be prohibited immediately and for the remainder of the season. 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-26 February 2013

Okanogan-Wenatchee National Forest

13. Invasive Species

The objective of the following measures is to prevent the establishment and spread of 

invasive species in the analysis area.

a) Precautions will be taken to prevent the introduction and spread of noxious weeds on 

National Forest System land. Outfitter-guides and clients shall prevent the transport of 

any seeds by removing any plant material attached to vehicles, shoes, clothing, or the 

bodies of pack and saddle stock.

b) Supplemental feed will be commercially processed feed, or weed-free certified 

processed hay cubes. Only certified weed-free hay shall be allowed on all National 

Forest System Land [36 CFR 261.58(t)].

c) Outfitters should consider feeding commercially-processed feed or hay that is certified 

weed-free for several days prior to trip departure to minimize the spread of weed seed 

through manure.

d) Outfitters will follow a weed identification and mapping program under Forest Service 

direction. Forest Service will provide the weed information.

e) Outfitters will be responsible for surveying campsites for weeds, and assisting in control 

measures as directed by the Forest Service.

Monitoring

All monitoring would be conducted by trained Forest Service employees or volunteers.

OUTFITTER-GUIDE OPERATIONS

A representative sample of outfitter-guide camps and operations would be checked seasonally 

by wilderness rangers and/or permit administrators for compliance with the terms of the 

permit, operating plan, and applicable laws and regulations. Inspections would be done when 

the outfitters are occupying the camp, but be unannounced. Field inspection reports include 

seven items:

1. Service to the public

2. Compliance with permit conditions

3. Compliance with operating plan

4. Equipment and livestock

5. Safety

6. Resource protection

Field inspection reports would be used by the permit administrators when preparing the annual 

outfitter-guide performance evaluations. Violations would result in non-compliance letters or 

notification, and potential for permit action.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-27 February 2013

Okanogan-Wenatchee National Forest

WILDERNESS

Wilderness monitoring would follow the process detailed in Monitoring Selected Conditions 

Related to Wilderness Character: A National Framework, 2005 (Landers, et al, 2005). Outfitterguide activities would be modified or controlled if impacts to wilderness character become 

unacceptable. Specific areas that would be closely monitored include lakes in the vicinity of 

Harts Pass and the Pacific Crest Trail, Hidden Lakes, Crow and Corral Lakes/Sheep Mountain 

area, Spanish Camp, and Black Lake in the Pasayten Wilderness, and Oval, North, Louis, 

Williams, Libby, Star, Tuckaway, Bernice, and Surprise Lakes and Twisp Pass in the Lake ChelanSawtooth Wilderness.

Campsite Monitoring

The number of wilderness campsites used by outfitter-guides inventoried and monitored 

annually would vary with the budget and workforce, but the assigned sites would be monitored 

at least once per year of use, and a representative sample of non-assigned sites would be 

monitored frequently enough to assess the outfitter’s compliance with the terms and conditions 

of the permits. Biophysical conditions at sites would be measured using indicators such as 

barren core, number of trees with exposed roots, number of mutilated trees and number of 

access trails. Water sources and water bodies near campsites would be checked for evidence of 

soap, other chemicals, and biological contaminants that may be introduced by human activity. 

Additional physical and social related indicators would be recorded. Pack and saddle stock 

outfitter-guide use of campsites would be adjusted if necessary to address new resource 

concerns.

Encounter Monitoring

Wilderness rangers would record encounter data on a daily basis while in the field; this includes 

time, location, number of people, number of stock, number of parties, type of use, and 

wilderness permits (where applicable). If encounters begin to exceed the Forest Plan standard 

and guidelines, adjustments may be made in pack and saddle stock outfitter-guide activities to 

reduce encounters. Potential adjustments could include limiting the number or size of outfitted 

parties in crowded areas.

PACK AND SADDLE STOCK GRAZING

Monitoring pack and saddle stock grazing utilization would occur in loose grazing areas around 

outfitter campsites, and near trailheads where stock are grazed. Forest Service monitoring 

guidelines specify that monitoring sites should be located outside livestock concentration areas 

and should be free of compounding use, such as the use directly around outfitter camps (Burton 

et al. 2011). Monitoring representative areas outside the camps would allow cause-and-effect 

relationships to be established. 

Wilderness rangers would monitor grazing utilization and impacts to wetlands by walking 

through areas that stock graze, and making ocular estimates of the amount of forage used by 

stock, or hoof action or trailing in wetlands. If grazing utilization is approaching standards, 

wilderness rangers would report the conditions, and formal monitoring would be scheduled for 

the area. Formal monitoring would be conducted by a modified stubble height utilization 

method to measure the level of use on key forage species. Utilization would be estimated by a 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-28 February 2013

Okanogan-Wenatchee National Forest

modified residue and height-weight method (Coulloudon et al. 1999), in which stubble height is 

measured and a simplified clip and balance technique to develop height-weight curves is used 

(Reese 1991). From height-weight curves, utilization can be estimated from the average stubble 

height measured at each location. Forest utilization standards for range allotments allow for 

45% use in upland forested areas, 55% use in upland grasslands, and 45% use in riparian 

meadows. 

Grazing areas would also be monitored for unacceptable impacts to wetlands. Unacceptable 

impacts could include excessive trailing, soil erosion, and grazing exceeding standards. If 

unacceptable impacts are observed, a more detailed analysis would be conducted to determine 

extent of trailing, species composition, forage utilization, and evidence of soil erosion. This 

information would be used to develop a baseline site condition. If future monitoring indicated a 

downward trend, a restoration plan, including potential modification of outfitter-guide 

activities, would be developed and implemented. 

RIPARIAN AREAS

Pack and saddle stock outfitter-guide campsites within riparian areas would be monitored to 

ensure the outfitter activities are meeting riparian area standards and guidelines. There are 24 

established outfitter-guide camps within riparian management areas or riparian habitat 

conservation areas. Of these, six are in bull trout critical habitat and one is in Chinook and 

steelhead critical habitat. All basecamps would be monitored each year. All backcountry camps 

in critical habitat would be monitored once every three years. All other riparian campsites would 

be monitored once to twice every ten years. 

Biophysical conditions at sites would be measured using indicators such as barren core, number 

of trees with exposed roots, number of mutilated trees and number of access trails. Additional 

physical and social related indicators would be recorded, such as stream bank disturbance, 

streamside vegetation disturbance at access points, and evidence of firewood collection of 

wood over 12 inches in diameter. Each site would have photos taken and a lineal estimate of 

streambank and vegetation disturbance. This information would be reviewed by fish biologist to 

see if further field review is warranted. The outfitter-guide activities would also be monitored 

to validate implementation and effectiveness of the Best Management Practices and assure 

compliance with the Clean Water Act, State water quality regulations and forest plan standards.

Changes in campsite conditions would not be attributable to any particular user, such as 

outfitter-guides, unless the party causing the damage is observed. If unacceptable changes are 

noted, pack and saddle stock outfitter-guides may be restricted from using the impacted camps 

until the sites recover.

The campsites would also be included in the Outfitter-Guide Operations monitoring described 

above. The frequency of these monitoring visits will depend on outfitter occupancy of the 

camps. As stated above, if pack and saddle stock outfitter-guides are found to be out of 

compliance with the terms and conditions of their permits, leading to degraded riparian habitat, 

this will be addressed through notices of non-compliance or permit action.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-29 February 2013

Okanogan-Wenatchee National Forest

Key Monitoring Elements of riparian campsite monitoring include:

Streambank disturbance

Streamside vegetation disturbance

Downed wood ≥12 inches 

Fisheries Specific Monitoring

Bull Trout

Lost River (Diamond Creek) and Cougar Lake campsites, Wolf Creek Sough Forth, 

North Fork, and Little Fish campsites, and the Billygoat Base Camps would be 

monitored for recreational impacts to bull trout and their critical habitat. Specific 

criteria to assess are effects to vegetation and streambank erosion from river 

access.

The Thirtymile Ford would be monitored for signs of bull trout spawning habitat or 

redds. Ford conditions would be assessed annually for signs of riverbank damage 

and sign of spawning gravel and redds. 

Chinook and Steelhead

Andrews Base Camp would be monitored, with specific criteria to assess are effects 

to vegetation, erosion from the corral, and stock signs along the river. 

The Thirtymile Ford would also be monitored for signs of Chinook or steelhead 

spawning habitat or redds. If redds are documented at the ford, it would be closed 

immediately, and the outfitter-guide would not be able to use the ford for the 

remainder of the season. The Forest Service would reinitiate consultation with the 

regulatory agencies

Adaptive Monitoring Strategy - Due to limited resources and the fact that pack and saddle stock 

outfitter-guide use is generally light on the landscape, the adaptive monitoring strategy that first 

involves a two-stage review of pack and saddle stock outfitter-guide impacts to aquatic and 

riparian resources. 

1. The proposed field monitoring plan would begin with backcountry rangers who are in 

the project area all summer. They would review the streams adjacent to the riparian 

campsites. During this review, a description of the condition of streambank stability, 

streamside vegetation, and whether downed wood >12 inches in diameter is being used 

for firewood would be recorded. Additionally, photos would be taken of these habitat 

elements. This short report would be taken back to the project fish biologist for further 

review. 

2. If the initial report suggests resource conditions or impacts are exceeding resource 

objectives, the project fish biologist would visit the site in the field. This review would 

look at channel conditions and whether activities in the area are out of compliance with 

the ACS or RHMOs. If the monitoring shows conditions are meeting resource objectives, 

no action would occur. When desired resource conditions are not met, such as excessive 

streambank alteration or herbaceous and shrub utilization or operating instructions are 

not followed, recreation and aquatic staff would work together with the pack and 

saddle stock outfitter-guides to further reduce their impacts
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-30 February 2013

Okanogan-Wenatchee National Forest

Comparison of Alternatives

Figure 2-4 provides a side-by-side description of each alternative and a summary of how each 

alternative responds to the Purpose and Need and each Significant Issue. See Chapter 1 for 

background on the issues, and Chapter 3 for a complete description of the effects and for the 

scientific basis for results in Figure 2-4.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-31 February 2013

Okanogan-Wenatchee National Forest

Figure 2-4: Comparison of Alternatives

Unit of 

Measure

Current Alternative 1 Alternative 2 Alternative 3 Alternative 4

Total Number of Service 

Days 

Service Days 4,460 0 4,620 2,660 6,700

Total Number of Visitor 

Days (outfitted and 

private)

Visitor Days 168,300 163,840 168,460 166,500 170,540

Percent of Visitor Days 

Outfitted by Pack and 

Saddle Stock OutfitterGuides 

Percent 3% 0% 3% 2% 4%

Percent Change in Total 

Number of Visitor Days 

Compared to Current

Percent -3% +0.1% -1% +1%

Total Number of Pack 

and Saddle Stock Visitor 

Days

Visitor Days 28,880 24,420 29,040 27,080 31,136

Percent of Pack and 

Saddle Stock Visitor Days 

Outfitted

Percent 15% 0% 16% 10% 22%

Percent Change in Total 

Pack and Saddle Stock 

Visitor Days Compared 

Current

Percent -15% +0.6% -6% +8%

Percent Change in 

Service Days Compared 

to Current

Service Days -100% +4% -40% +50%

Forest Plan Amendment 

to Party Size

No Amendment No Amendment

(12 people/18 head of 

stock)

12 Heartbeats No Amendment

(12 people/18 head of 

stock)
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-32 February 2013

Okanogan-Wenatchee National Forest

Unit of 

Measure

Current Alternative 1 Alternative 2 Alternative 3 Alternative 4

Forest Plan Amendment 

to Camp Location

No Amendment Outfitters allowed to 

use established 

campsites within 200 

feet of meadows, lakes, 

streams, and special 

interest areas

Outfitters allowed to 

use established 

campsites within 200 

feet of meadows. 

Prohibited from using 

campsites within 200 

feet of wetlands, 

streams, lakes, and 

special interest areas.

Outfitters allowed 

to use established 

campsites within 

200 feet of 

meadows, lakes, 

streams, and special 

interest areas

Forest Plan Amendment 

to Barren Core

No Amendment Outfitters would be 

allowed to use up to 

5,250 square feet of 

barren core. In camps 

with more, outfitters 

must reuse the same 

5,250 square feet each 

time. Outfitters would 

be prohibited from 

creating additional 

barren core in any 

camp. Excess barren 

core would be restored.

Outfitters would be 

allowed to use up to 

2,800 square feet of 

barren core. In camps 

with more, outfitters 

must reuse the same 

2,800 square feet each 

time. Outfitters would 

be prohibited from 

creating additional 

barren core in any 

camp. Excess barren 

core would be 

restored..

Outfitters would be 

allowed to use 

existing barren core 

in established 

campsites, but 

would be prohibited 

from creating 

additional barren 

core. 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-33 February 2013

Okanogan-Wenatchee National Forest

Purpose and Need Unit of 

Measure

Alternative 1 Alternative 2 Alternative 3 Alternative 4

1. Respond to Permit 

Applications for outfitter-guide 

permits. 

Qualitative 

discussion

Would deny applications, 

and no pack and saddle 

stock outfitter-guide 

permits would be issued.

10-year permits would 

be issued with service 

day calculations 

consistent with FSH 

2709.11 – highest actual 

use in past 5 years plus 

25%.

10-year permits 

would be issued, but 

with 40% fewer 

service days 

compared to the 

current allowed use. 

10-year permits would 

be issued with enough 

service days to match 

the highest actual use 

in the past 10 years 

plus 25%. 

2. Protect wilderness character 

in the Pasayten and Lake 

Chelan-Sawtooth Wilderness 

Areas while providing 

necessary pack and saddle 

stock outfitter-guide 

commercial services.

Qualitative 

discussion

The wilderness character 

would be protected, but 

no pack and saddle stock 

commercial services 

would be provided for 

realizing recreational or 

other wilderness 

proposes. 

Wilderness character 

would be protected 

since impacts to 

opportunities for 

solitude would be minor 

and localized. The 

number of service days 

would be within the 

range of the minimum 

extent necessary for 

realizing the recreational 

purposes of the areas 

would be provided.

Wilderness character 

would be protected 

since impacts to 

opportunities for 

solitude would be 

minor and localized. 

Pack and saddle stock 

commercial services 

would be provided, 

but for less than the 

minimum amount 

necessary for 

realizing the 

recreational purposes 

of the areas.

Wilderness character 

would be protected 

since impacts to 

opportunities for 

solitude would be 

minor and localized. 

The upper range of 

the minimum amount 

of pack and saddle 

stock commercial 

services necessary for 

realizing the 

recreational purposes 

of the areas would be 

provided.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-34 February 2013

Okanogan-Wenatchee National Forest

Purpose and Need Unit of 

Measure

Alternative 1 Alternative 2 Alternative 3 Alternative 4

3. Make standards and 

guidelines for campsite barren 

core in wilderness compatible 

with party size for pack and 

saddle stock outfitter-guides.

Qualitative 

discussion

Forest Plans would not be 

amended, but there 

would be no pack and 

saddle stock outfitterguide activities.

Forest Plan amendment 

would allow up outfitterguides to use up to 5,250 

square feet of barren 

core in existing camps 

that exceed that size. In 

established campsites, 

barren core would not 

be allowed to increase. 

This would be 

compatible with a party 

size of 12 and 18, 

although use patterns at 

campsites with over 

5,250 square feet would 

be modified. 

Forest Plan 

amendment would 

allow up outfitterguides to use up to 

2,800 square feet of 

barren core in 

existing camps that 

exceed that size. In 

established 

campsites, barren 

core would not be 

allowed to increase. 

This would be 

compatible with a 

party size of 12 

heartbeats, although 

use patterns at 

campsites with over 

2,800 square feet 

would be modified. 

Forest Plan 

amendment would 

allow up outfitterguides to use existing 

barren core in 

established campsites, 

but not increase the 

amount of barren 

core. This would be 

fully compatible with a 

party size of 12 people 

and 18 stock. 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-35 February 2013

Okanogan-Wenatchee National Forest

Significant Issue Unit of 

Measure

Alternative 1 Alternative 2 Alternative 3 Alternative 4

1. Current and proposed pack 

and saddle outfitted use does 

not comply with some Forest 

Plan wilderness standards and 

guidelines or with the 

Wilderness Act because the 

party size and amount of use 

perpetuates large camps and 

degrades the condition of the 

wilderness.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-36 February 2013

Okanogan-Wenatchee National Forest

Significant Issue Unit of 

Measure

Alternative 1 Alternative 2 Alternative 3 Alternative 4

a) Compliance with the 

Wilderness Act in terms of the 

qualities that make up 

wilderness character: 

untrammeled, undeveloped, 

natural, and opportunities for 

solitude or primitive and 

unconfined recreation.

Qualitative 

discussion

Pack and saddle stock 

outfitter-guides would 

not operate in

wilderness. There would 

be a 32% reduction in 

the number of pack and 

saddle stock users in the 

Pasayten and a 6% 

reduction in the Lake 

Chelan-Sawtooth. The 

untrammeled and 

undeveloped qualities of 

wilderness character 

would be unaffected. 

There would be minor, 

localized beneficial 

impacts to the natural 

quality since fewer pack 

and saddle stock would 

be grazing, and 

potentially damaging 

stream banks at 

watering sites. 

Opportunities for 

solitude would also be 

beneficially impacted on 

a local, minor level with 

the reduced number of 

pack and saddle stock 

users.

There would be 

approximately 4% more 

pack and saddle stock 

users in the Pasayten, 

and no increase in the 

Lake Chelan-Sawtooth 

compared to current 

numbers. The 

untrammeled and 

undeveloped qualities 

would be unaffected. 

The natural quality of 

the Pasayten and Lake 

Chelan-Sawtooth 

wilderness areas would 

continue to receive 

minor, localized 

impacts. Opportunities 

for solitude would have 

minor, localized, 

negative impacts due 

to encounters and 

campsite size and 

location.

There would be a 14% 

decrease in the number 

of pack and saddle stock 

users in the Pasayten, 

and a 3% decrease in the 

Lake Chelan-Sawtooth. 

The untrammeled and 

undeveloped qualities 

would be unaffected. 

The natural quality 

would continue to have 

minor, localized impacts 

from stock grazing, and 

damage to stream banks 

at watering spots. 

Opportunities for 

solitude would improve 

slightly because of the 

decrease in pack and 

saddle stock users, but 

the increase would be 

small enough to likely go 

unnoticed by most 

users. 

There would be 

approximately 6% more 

pack and saddle stock 

users in the Pasayten, 

and a 1% increase in 

the Lake ChelanSawtooth compared to 

current numbers. The 

untrammeled and 

undeveloped qualities 

would be unaffected. 

The natural quality of 

the Pasayten and Lake 

Chelan-Sawtooth 

wilderness areas would 

continue to receive 

minor, localized 

impacts. Opportunities 

for solitude would have 

minor, localized, 

negative impacts due to 

encounters and 

campsite size and 

location.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-37 February 2013

Okanogan-Wenatchee National Forest

Significant Issue Unit of 

Measure

Alternative 1 Alternative 2 Alternative 3 Alternative 4

b)Compliance with 

Wilderness Management Tool 

(non-degradation policy)

Qualitative 

discussion

There would be no pack 

and saddle stock 

outfitter-guides. The 

elimination would 

reduce use at some 

existing sites, and lead 

to some natural 

restoration of barren 

core areas not used by 

the non-outfitted pack 

and saddle stock parties.

Pasayten and Lake 

Chelan-Sawtooth 

would continue on an 

improving trend, with 

no degradation. Forest 

Plan amendments 

would limit the amount 

of barren core 

outfitters can use, 

allowing natural 

restoration to occur in 

camps with existing 

barren cores exceeding 

5,250 square feet, and 

allow use of existing 

campsites within 200 

feet of meadows, lakes, 

streams and key 

interest areas. No new 

campsites would be 

created. Mitigation 

measures would insure 

that outfitter-guides do 

not further degrade the 

condition of the 

wilderness.

Pasayten and Lake 

Chelan-Sawtooth would 

continue on an 

improving trend, with no 

degradation. Forest 

Plan amendments would 

limit the amount of 

barren core outfitters 

can use, allowing natural 

restoration to occur in 

camps with existing 

barren cores exceeding 

2,800 square feet. The 

reduced party size 

would help reduce size 

of barren core in 

campsites. Prohibiting 

camping in camps within 

200 feet of wetlands, 

lakes, streams, and key 

interest areas would 

prevent continuing 

impacts to these 

campsites from 

outfitter-guides. 

Mitigation measures 

would insure that 

outfitter-guides do not 

further degrade the 

condition of the 

wilderness.

Pasayten and Lake 

Chelan-Sawtooth would 

continue on an 

improving trend, with 

no degradation. Forest 

Plan amendments 

would allow outfitters 

to use existing barren 

core in established 

campsites, but prohibit 

creation of additional 

barren core. Use of 

existing camps within 

200 feet of meadows, 

lakes, streams and key 

interest areas would be 

allowed. No new 

campsites would be 

Mitigation measures 

would insure that 

outfitter-guides do not 

further degrade the 

condition of the 

wilderness.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-38 February 2013

Okanogan-Wenatchee National Forest

Significant Issue Unit of 

Measure

Alternative 1 Alternative 2 Alternative 3 Alternative 4

c) Compliance with standards 

and guidelines, and the effect 

the proposed Forest Plan 

amendments will have on 

wilderness character

Qualitative 

discussion

No permits would be 

issued for pack and 

saddle stock outfitterguides, so compliance 

with standards and 

guidelines would not be 

applicable. 

Outfitter-guide 

activities would comply 

with amended 

standards and 

guidelines. The forest 

plan amendments

would have minor, 

localized impacts on 

the opportunities for 

solitude by authorizing 

larger areas of barren 

core in outfitter camps

compared to existing 

standards. The 

outfitters would be 

prohibited from 

creating new camps, or 

increasing the size of 

existing barren cores, 

so the result will be a 

slight decrease in the 

amount of barren core 

at large, established 

camps. The second 

forest plan amendment 

would allow outfitters 

to use established 

campsites within 200 

feet of meadows, lakes, 

streams, and key 

interest areas. 

Outfitter-guide activities 

would comply with 

amended standards and 

guidelines. The Forest 

Plan amendments would 

have minor, localized 

impacts on the 

opportunities for 

solitude by authorizing 

larger areas of barren 

core in outfitter camps

compared to existing 

standards. The 

outfitters would be 

prohibited from creating 

new camps, or 

increasing the size of 

existing barren cores, so 

the result will a larger 

decrease in the amount 

of barren core at large, 

established camps, 

compared to Alternative 

2. They would be 

prohibited from using 

campsites within 200 

feet of wetlands, lakes, 

streams, or key interest 

areas, which would 

reduce the number of 

campsites available. 

This would degrade 

wilderness character in 

isolated areas. 

Outfitter-guide

activities would comply 

with amended 

standards and 

guidelines. The forest 

plan amendments 

would have minor, 

localized impacts on the 

opportunities for 

solitude by authorizing 

larger areas of barren 

core in outfitter camps 

compared to existing 

standards. The 

outfitters would be 

prohibited from 

creating new camps, or 

increasing the size of 

existing barren cores. 

The existing amount of 

barren core would 

remain. The second 

forest plan amendment 

would allow outfitters 

to use established 

campsites within 200

feet of meadows, lakes, 

streams, and key 

interest areas. This 

would avoid the 

necessity to create new 

camps, which would 

degrade wilderness 

character.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-39 February 2013

Okanogan-Wenatchee National Forest

Significant Issue Unit of 

Measure

Alternative 1 Alternative 2 Alternative 3 Alternative 4

d)Total Number of Service

Days in Pasayten Wilderness

and total number of visitor 

days (outfitted and private) 

Service Days

Visitor Days

0 Service Days

16,900 Visitor Days

2,000 Service Days

18,900 Visitor Days

1,000 Service Days

17,900 Visitor Days

2,170 Service Days

19,070 Visitor Days

e) Total Number of Pack and 

Saddle Stock Visitor Days in 

Pasayten Wilderness 

(outfitted and private) and 

percent outfitted

Visitor Days

Percent 

Outfitted

3,810 Pack & Saddle 

Visitor Days

0% outfitted

5,810 Pack & Saddle 

Visitor Days

34% outfitted

4,810 Pack & Saddle 

Visitor Days

21% outfitted

5,966 Pack & Saddle 

Visitor Days

36% outfitted

d)Total Number of Service 

Days in Lake Chelan-Sawtooth

Wilderness and total number 

of visitor days (outfitted and 

private)

Service Days

Visitor Days

0 Service Days

35,885 Visitor Days

720 Service Days

36,605 Visitor Days

320 Service Days

36,205 Visitor Days

825 Service Days

36,710 Visitor Days

d)Total Number of Service 

Days in Pasayten Wilderness 

and total number of visitor 

days (outfitted and private)

Visitor Days

Percent 

Outfitted

12,095 Pack and Saddle 

Visitor Days

0 outfitted

12,815 Pack and Saddle 

Visitor Days

6% outfitted

12,415 Pack and Saddle 

Visitor Days

3% outfitted

12,920 Pack and Saddle 

Visitor Days

6% outfitted

2. Current outfitted use could 

degrade wetlands and habitat 

for native plant species.

a) wetland within 500 feet of 

pack and saddle stock camps, 

and percentage of total 

wetlands in analysis area

Estimated 

number of 

acres and 

percent of 

total

86

1%

86

1%

25.2

0.3%

86

1%
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-40 February 2013

Okanogan-Wenatchee National Forest

Significant Issue Unit of 

Measure

Alternative 1 Alternative 2 Alternative 3 Alternative 4

b) effects of activities on 

wetlands

Qualitative 

discussion

Pack and saddle stock 

outfitter-guides would 

have no impacts on 

wetlands. 10% 

reduction in pack and 

saddle stock would 

reduce localized impacts 

of grazing and trampling 

of vegetation in and 

around campsites. The 

damage to vegetation 

would continue to be 

isolated in context of all 

the wetlands in the 

analysis area.

Localized impacts to 

the 87 acres of 

wetlands would 

continue, but 

mitigation measures 

would minimize 

impacts from outfitterguides. Outfitter-guide

activities would meet 

the Aquatic 

Conservation Strategy 

Objectives, and the 

Riparian Management 

Objectives, so isolated 

impacts to wetlands 

would be within 

standards.

Localized impacts to the 

25.2 acres of wetlands 

would continue, but 

mitigation measures 

would minimize impacts 

from outfitter-guides. 

Outfitter-guide activities 

would meet the Aquatic 

Conservation Strategy 

Objectives, and the 

Riparian Management 

Objectives, so isolated 

impacts to wetlands 

would be within 

standards.

Localized impacts to the 

87 acres of wetlands 

would continue, but 

mitigation measures 

would minimize 

impacts from outfitterguides. Outfitter-guide 

activities would meet 

the Aquatic 

Conservation Strategy 

Objectives, and the 

Riparian Management 

Objectives, so isolated 

impacts to wetlands 

would be within 

standards.

c) Determination statements 

for threatened endangered 

and sensitive plant species

Determination 

rating

“No effect” on any listed 

plant species. “No 

impact” on any sensitive 

plant species.

“No effect” on any 

listed plant species. 

“May impact 

individuals, but not 

likely to cause a trend 

toward Federal listing 

or a loss of population 

viability” on sensitive 

species. 

“No effect” on any listed 

plant species. “May 

impact individuals, but 

not likely to cause a 

trend toward Federal 

listing or a loss of 

population viability” on 

sensitive species.

“No effect” on any 

listed plant species. 

“May impact 

individuals, but not 

likely to cause a trend 

toward Federal listing 

or a loss of population 

viability” on sensitive 

species.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-41 February 2013

Okanogan-Wenatchee National Forest

Significant Issue Unit of 

Measure

Alternative 1 Alternative 2 Alternative 3 Alternative 4

d) Effects of stock grazing on 

plant composition

Qualitative 

discussion

No grazing from 

outfitter stock, so no 

impacts on plant 

composition. The 

number of pack and 

saddle stock visitor days

would be reduced by 

15%. Pack and saddle 

stock grazing in and 

around campsites would 

not result in further 

modification of plant 

succession due to the 

limited amount of area 

where the animals 

graze, and the small 

number of animals 

compared to past use.

The number of pack 

and saddle stock visitor 

days would be virtually 

the same as the 

existing, 29,040 visitor 

days. Outfitter-guide 

pack and saddle stock 

grazing in and around 

campsites would not 

result in further 

modification of plant 

succession due to the 

limited amount of area 

where the animals 

graze, and the small 

number of animals 

compared to past use.

The number of pack and 

saddle stock visitor days 

would be reduced by 

6%. Outfitter-guide pack 

and saddle stock grazing 

in and around campsites 

would not result in 

further modification of 

plant succession due to 

the limited amount of 

area where the animals 

graze, and the small 

number of animals 

compared to past use.

The number of pack 

and saddle stock visitor 

days would increase 

8%. Outfitter-guide 

pack and saddle stock 

grazing in and around 

campsites would not 

result in further 

modification of plant 

succession due to the 

limited amount of area 

where the animals 

graze, and the small 

number of animals 

compared to past use.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-42 February 2013

Okanogan-Wenatchee National Forest

Significant Issue Unit of Measure Alternative 1 Alternative 2 Alternative 3 Alternative 4

3. Current outfitted use could 

degrade some habitat for 

threatened, endangered or 

sensitive wildlife species 

through increased encounters 

with people or through habitat 

degradation.

a) Determination statements 

from Biological Assessment 

for threatened, endangered 

or sensitive wildlife species

Determination 

rating

“No Effect” on any 

listed species.

“May affect, not likely 

to adversely affect” 

gray wolf, grizzly bear, 

lynx, northern spotted 

owl. “No effect” on all 

other listed species. 

“May impact 

individuals, but not 

likely to cause a trend 

toward Federal listing 

or a loss of population 

viability” great gray 

owl. “No impact” on all 

other listed species.

“May affect, not likely to 

adversely affect” gray 

wolf, grizzly bear, lynx, 

northern spotted owl. 

“No effect” on all other 

listed species. “May 

impact individuals, but 

not likely to cause a 

trend toward Federal 

listing or a loss of 

population viability” 

great gray owl. “No 

impact” on all other 

listed species.

“May affect, not likely 

to adversely affect” 

gray wolf, grizzly bear, 

lynx, northern spotted 

owl. “No effect” on all 

other listed species. 

“May impact 

individuals, but not 

likely to cause a trend 

toward Federal listing 

or a loss of population 

viability” great gray 

owl. “No impact” on all 

other listed species.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-43 February 2013

Okanogan-Wenatchee National Forest

Significant Issue Unit of 

Measure

Alternative 1 Alternative 2 Alternative 3 Alternative 4

4. Current pack and saddle 

stock outfitted use could 

degrade water quality and 

aquatic resources.

a) Determination 

Statements from 

Biological Assessment for 

threatened, endangered, 

and sensitive fish 

species.

Determination 

rating

“No effect” on any listed 

species. “No impact” on 

sensitive species.

“May affect, not likely to 

adversely affect” bull 

trout, steelhead, and 

spring Chinook. “No 

effect” on all other listed 

species. “No impact” on 

sensitive species.

“May affect, not likely to 

adversely affect” bull 

trout, steelhead, and 

spring Chinook. “No 

effect” on all other listed 

species. “No impact” on 

sensitive species.

“May affect, not likely to 

adversely affect” bull 

trout, steelhead, and 

spring Chinook. “No 

effect” on all other listed 

species. “No impact” on 

sensitive species.

b) Compliance with 

Northwest Forest Plan 

Aquatic Conservation 

Strategy (ACS) and 

PACFISH Riparian 

Management Objectives 

(RMO)

Qualitative 

discussion

No permits would be 

issued for pack and 

saddle stock outfitterguides, so compliance 

with ACS and RMOs 

would not be applicable. 

Alternative would comply 

with the ACS and RMOs.

Pack and saddle stock 

outfitter-guide activities 

would not retard or 

prevent attainment of 

ACSOs or RMOs. Impacts 

to water quality, 

streambank stability, 

vegetation, and aquatic 

habitat would be minor 

and localized.

Alternative would 

comply with the ACS and 

RMOs. Pack and saddle 

stock outfitter-guide 

activities would not 

retard or prevent 

attainment of ACSOs or 

RMOs. Impacts to water 

quality, streambank 

stability, vegetation, and 

aquatic habitat would be 

minor and localized.

Alternative would comply 

with the ACS and RMOs. 

Pack and saddle stock 

outfitter-guide activities 

would not retard or 

prevent attainment of 

ACSOs or RMOs. Impacts 

to water quality, 

streambank stability, 

vegetation, and aquatic 

habitat would be minor 

and localized..

c) Compliance with state 

water quality standards 

and the Clean Water Act

Qualitative 

discussion

No permits would be 

issued for pack and 

saddle stock outfitterguides, so compliance 

with Clean Water Act

would not be applicable

Alternative would comply 

with the Clean Water Act. 

Pack and saddle stock 

outfitter-guide activities 

would not alter water 

temperature or quality. 

No 303d listed waterways 

near outfitter-guide 

activities.

Alternative would 

comply with the Clean 

Water Act. Pack and 

saddle stock outfitterguide activities would 

not alter water 

temperature or quality. 

No 303d listed 

waterways near 

outfitter-guide activities.

Alternative would comply 

with the Clean Water Act. 

Pack and saddle stock 

outfitter-guide activities 

would not alter water 

temperature or quality. 

No 303d listed waterways 

near outfitter-guide 

activities.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-44 February 2013

Okanogan-Wenatchee National Forest

Significant Issue Unit of 

Measure

Alternative 1 Alternative 2 Alternative 3 Alternative 4

d) Effects of loose grazing 

on riparian areas, 

streams and lakes 

Qualitative 

discussion

Pack and saddle stock 

outfitter-guides would 

have no effect on 

riparian areas, streams, 

or lakes.

Loose grazing would 

disperse impacts, and 

minimize effects on 

riparian areas, streams, 

and lakes.

Loose grazing would 

disperse impacts, and 

minimize effects on 

riparian areas, streams, 

and lakes.

Loose grazing would 

disperse impacts, and 

minimize effects on 

riparian areas, streams, 

and lakes.

e)Stream sedimentation 

from stock grazing.

Qualitative 

discussion

No outfitter stock 

grazing, so no effect on 

stream sedimentation. 

pack and saddle stock 

outfitter-guide stock 

grazing. 

Stream sedimentation 

from stock grazing and 

use would be low. It 

would not be detectable 

compared to ongoing 

channel and hill slope 

erosion, except at the 

point of disturbance in 

the stream channel. 

There would be no 

detectable difference in 

stream sedimentation 

between alternatives 

across the analysis area. 

Stream turbidity is not 

expected to change under 

any of the alternatives, 

because the suspended 

sediment would not 

change.

Stream sedimentation 

from stock grazing and 

use would be low. It 

would not be detectable 

compared to ongoing 

channel and hill slope 

erosion, except at the 

point of disturbance in 

the stream channel. 

There would be no 

detectable difference in 

stream sedimentation 

between alternatives 

across the analysis area. 

Stream turbidity is not 

expected to change 

under any of the 

alternatives, because 

the suspended sediment 

would not change.

Stream sedimentation 

from stock grazing and 

use would be low. It 

would not be detectable 

compared to ongoing 

channel and hill slope 

erosion, except at the 

point of disturbance in 

the stream channel. 

There would be no 

detectable difference in 

stream sedimentation 

between alternatives 

across the analysis area. 

Stream turbidity is not 

expected to change under 

any of the alternatives, 

because the suspended 

sediment would not 

change.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-45 February 2013

Okanogan-Wenatchee National Forest

Significant Issue Unit of 

Measure

Alternative 1 Alternative 2 Alternative 3 Alternative 4

g) Localized impacts 

where trails cross 

streams or where camps 

are located near water

Qualitative 

discussion

No impacts from pack 

and saddle stock 

outfitter-guides at trail 

stream crossings or 

camps near water. 

Overall 15% reduction in 

pack and saddle stock 

use would reduce 

impacts, however 

localized impacts to 

stream banks and other 

water features, including 

damage to riparian 

vegetation and 

reduction in water 

quality would occur 

from non-outfitted use. 

The isolated, localized 

impacts would not 

adversely affect riparian 

habitat conditions or 

water quality beyond 

the immediate areas. 

There would be a 4% 

increase in pack and 

saddle stock outfitterguide service days

compared to current 

number, but only a 0.6% 

increase in all pack and 

saddle stock use. Small 

increase would not 

change conditions from 

current conditions. 

There would localized 

impacts to stream banks 

and other water features, 

including damage to 

riparian vegetation and 

reduction in water 

quality. The isolated, 

localized impacts would 

not adversely affect 

riparian habitat 

conditions or water 

quality beyond the 

immediate areas. 

The 40% reduction in 

the number of pack and 

saddle stock service days 

would reduce impacts

from outfitters. There 

would be an overall 

reduction in pack and 

saddle stock use of 6%. 

Impacts to stream banks 

and other water 

features, including 

damage to riparian 

vegetation and 

reduction in water 

quality would be 

reduced. The isolated, 

localized impacts would 

not adversely affect 

riparian habitat 

conditions or water 

quality beyond the 

immediate areas. 

The 50% increase in pack 

and saddle stock visitor 

days would increase 

localized impacts to 

stream banks and other 

water features, including 

damage to riparian 

vegetation and reduction 

in water quality compared 

to the existing condition 

or Alternative 2. There 

would be an overall 8% 

increase in pack and 

saddle stock use. The 

isolated, localized impacts 

would not adversely 

affect riparian habitat 

conditions or water 

quality beyond the 

immediate areas. 

h. Fecal coliform levels Qualitative 

discussion

Outfitters would not 

operate, so stock would 

not contribute to 

background fecal 

coliform levels. Nonoutfitted recreationists 

and stock, in addition to 

wildlife would result in 

fecal coliform in all 

waterways.

Short-term increases in 

fecal coliform levels at 

trail crossings and 

watering spots when 

stock are present. Fecal 

coliform would be quickly 

dissipated by rapidly 

moving water in streams. 

Clean Water Act 

standards for surface 

water would not be 

violated.

Short-term increases in 

fecal coliform levels at 

trail crossings and 

watering spots when 

stock are present . Fecal 

coliform would be 

quickly dissipated by 

rapidly moving water in 

streams. Clean Water 

Act standards for surface 

water would not be 

violated.. 

Short-term increases in 

fecal coliform levels at 

trail crossings and 

watering spots when 

stock are present . Fecal 

coliform would be quickly 

dissipated by rapidly 

moving water in streams. 

Clean Water Act 

standards for surface 

water would not be 

violated..
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-46 February 2013

Okanogan-Wenatchee National Forest

Significant Issue Unit of 

Measure

Alternative 1 Alternative 2 Alternative 3 Alternative 4

5. Barren core limitations in 

Alternative 2 would not be 

large enough for a party of 

12 people and 18 head of 

stock, and the number of 

service days in that 

alternative would not allow 

the businesses to respond 

to increases in demand for 

pack and saddle stock 

outfitter-guide services. 

a) amount of area 

needed for a party of 12 

people and 18 head of 

stock

Qualitative 

discussion

No pack and saddle 

stock outfitter-guides 

would operate on 

National Forest System 

Land.

Approximately 95% of 

campsites used by 

outfitter-guides have less 

than 5,250 square feet of 

barren core. The 8

campsites exceeding 

5,250 are some of the 

most frequently used 

sites, including 3 assigned 

sites. Altering use 

patterns in the large 

camps could be difficult 

and reduce the quality of 

the camping experience 

for the clients.

Approximately 85% of 

the campsites used by 

the outfitter-guides have 

less than 2,800 square 

feet of barren core. All 

the campsites most 

regularly used, including 

all the assigned sites, 

have more than 2,800 

square feet of barren 

core. The reduced 

party size in Alternative 

3 would help prevent 

creation of additional 

barren core.

Outfitters would be able 

to use existing barren 

core in established 

campsites. This would 

allow enough room for 12 

people and 18 head of 

stock in every camp 

without changing the use 

patterns, or impacting the 

quality of the camping 

experience for clients.

b) impacts to the 

businesses from the 

number of service days

Qualitative 

discussion

No pack and saddle 

stock outfitter-guides 

would operate on 

National Forest System 

Land.

Each outfitter would have 

enough days to match the 

highest actual use in the 

past 5 years plus 25%. If 

demand increases to 

levels seen 10 years ago, 

the outfitters would not 

be able to meet the 

demand.

Each outfitter would 

have the number of 

service days equal to the 

average amount of 

annual use in the past 5 

years. This would be a 

40% reduction 

compared to current, 

and would substantially 

reduce business profits. .

Each outfitter would have 

enough service days to 

match the highest annual 

use in the past 10 years 

plus 25%. If demand 

increases to levels seen 

10 years ago, the 

outfitters would be able 

to meet those demands, 

increasing profits.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-47 February 2013

Okanogan-Wenatchee National Forest

Other Issues Unit of Measure Alternative 1 Alternative 2 Alternative 3 Alternative 4

Pack and saddle stock 

outfitter-guides could 

introduce noxious weeds 

into currently weed-free 

areas, such as wilderness, in 

stock manure.

Qualitative 

discussion

There would be no 

outfitter-guide pack 

and saddle stock that 

could potentially 

introduce weeds. The 

requirement for 

certified weed-free 

hay at Wilderness 

trailheads began in 

2007, and everywhere 

on National Forest 

System Land in 2009 

which substantially 

reduced the 

possibility of weeds 

being spread by nonoutfitted pack and 

saddle stock users. 

Outfitters would help 

identify and locate 

newly established weed 

populations, aiding in 

early treatment. The 

requirement for certified 

weed-free hay at 

Wilderness trailheads 

began in 2007, and 

everywhere on National 

Forest System Land in 

2009 which substantially 

reduced the possibility 

of weeds being spread 

by non-outfitted pack 

and saddle stock users.

Outfitters would help 

identify and locate 

newly established weed

populations, aiding in 

early treatment. The 

requirement for certified 

weed-free hay at 

Wilderness trailheads 

began in 2007, and 

everywhere on National 

Forest System Land in 

2009 which substantially 

reduced the possibility 

of weeds being spread 

by non-outfitted pack 

and saddle stock users.

Outfitters would help 

identify and locate 

newly established weed 

populations, aiding in 

early treatment. The 

requirement for 

certified weed-free hay 

at Wilderness 

trailheads began in 

2007, and everywhere 

on National Forest 

System Land in 2009 

which substantially 

reduced the possibility 

of weeds being spread 

by non-outfitted pack 

and saddle stock users.

Pack and saddle stock 

outfitter-guides could 

degrade air quality with 

smoke from campfires.

Qualitative 

discussion

The Pasayten 

Wilderness is the only 

Class I Airshed in 

analysis area. There 

would be no pack and 

saddle stock outfitterguide campfires, 

therefore no impact 

on air quality. 

The Pasayten Wilderness 

is the only Class I 

Airshed in analysis area. 

It is unlikely that smoke 

from campfires would 

degrade air quality. 

Campfires are built with 

dry fuel, and burn 

rapidly, ventilating 

upwards. In addition, 

there would not be a 

large enough 

concentration of smoke 

given the dispersed 

location of campsites. 

The Pasayten Wilderness 

is the only Class I 

Airshed in analysis area. 

It is unlikely that smoke 

from campfires would 

degrade air quality. 

Campfires are built with 

dry fuel, and burn 

rapidly, ventilating 

upwards. In addition, 

there would not be a 

large enough 

concentration of smoke 

given the dispersed 

location of campsites.

The Pasayten 

Wilderness is the only 

Class I Airshed in 

analysis area. It is 

unlikely that smoke 

from campfires would 

degrade air quality. 

Campfires are built with 

dry fuel, and burn 

rapidly, ventilating 

upwards. In addition, 

there would not be a 

large enough 

concentration of smoke 

given the dispersed 

location of campsites.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-48 February 2013

Okanogan-Wenatchee National Forest

Other Issues Unit of Measure Alternative 1 Alternative 2 Alternative 3 Alternative 4

Firewood gathering by pack 

and saddle stock outfitterguides could degrade the 

environment by removing 

down woody debris and 

limiting or eliminating this 

habitat component.

Qualitative 

discussion

No firewood would be 

gathered by pack and 

saddle stock outfitterguides. Non-outfitted 

recreationists would 

continue gathering 

firewood on less than 

one tenth of one 

percent of the analysis 

area. There would be 

some loss of habitat, but 

abundant habitat exists 

away from these 

isolated spots.

Less than one tenth of 

one percent of the 

analysis area would be 

affected by firewood 

gathering. There would 

be some loss of habitat, 

but abundant habitat 

exists away from these 

isolated spots.

Less than one tenth of 

one percent of the 

analysis area would be 

affected by firewood 

gathering. There would 

be some loss of habitat, 

but abundant habitat 

exists away from these 

isolated spots.

Less than one tenth of 

one percent of the 

analysis area would be 

affected by firewood 

gathering. There would 

be some loss of habitat, 

but abundant habitat 

exists away from these 

isolated spots.

Reducing the number of 

service days allowed could 

lead to some existing pack 

and saddle stock outfitters 

going out of business 

because of reduced 

revenues.

Qualitative 

discussion

No pack and saddle 

stock outfitter-guide 

permits would be 

issued, so the existing 

companies would no 

longer be able to offer 

trips into the 

backcountry or 

wilderness. Most would 

likely go out of business.

Enough service days 

would be authorized to 

allow the existing 

businesses, or suitable 

replacements, to 

continue roughly the 

same amount of 

revenue as they have 

over the past 5 years, 

with an additional 25% 

available for a modest 

amount of growth.

The reduction in 

allowable service days 

and party size could 

force some businesses

to close because of 

increased operating 

costs, and decreased 

opportunities to 

generate revenue.

The number of 

authorized service days 

would allow the 

existing businesses, or 

suitable replacements, 

to increase business to 

approximately 25% 

over levels from 

experienced 10 years 

ago. This alternative 

could lead to increased 

revenues if demand 

increases over current 

levels. 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-49 February 2013

Okanogan-Wenatchee National Forest

Pack and saddle stock 

outfitter-guides could 

degrade the experience of 

other recreation users 

outside wilderness.

Qualitative 

discussion

There would be no pack 

and saddle stock 

outfitter-guides, so no 

impact on the 

experience of other 

recreation users outside 

wilderness

Approximately 2% of 

the recreation use in 

the analysis area 

outside wilderness 

would be associated 

with outfitted pack and 

saddle stock use. Some 

conflict exists between 

outfitted and nonoutfitted users, but the 

relatively small amount 

of outfitted use 

compared to nonoutfitted use minimizes 

the frequency of 

conflict and contact. 

Approximately 1% of 

the recreation use in 

the analysis area 

outside wilderness 

would be associated 

with outfitted pack and 

saddle stock use. Some 

conflict exists between 

outfitted and nonoutfitted users, but the 

relatively small amount 

of outfitted use 

compared to nonoutfitted use minimizes 

the frequency of 

conflict and contact.

Approximately 3% of 

the recreation use in 

the analysis area 

outside wilderness 

would be associated 

with outfitted pack and 

saddle stock use. Some 

conflict exists between 

outfitted and nonoutfitted users, but the 

relatively small amount 

of outfitted use 

compared to nonoutfitted use minimizes 

the frequency of 

conflict and contact.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-50 February 2013

Okanogan-Wenatchee National Forest

Other Issues Unit of 

Measure

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Pack and saddle stock 

outfitter-guide activities 

could lead to soil damage 

and displacement in 

meadows and other areas 

by stock trampling, grazing, 

and crossing wet areas.

Qualitative 

discussion

Most existing detrimental 

soil damage occurred 

prior to implementation 

of the Forest Plans. 

There would be no 

impact to soils from pack 

and saddle stock 

outfitter-guide activities. 

There would be 

approximately 15% fewer 

pack and saddle stock in 

the analysis area with this 

alternative, but the 

existing areas of damage 

would continue to be 

used by non-outfitted 

pack and saddle stock, so 

the amount of area with 

damaged soil would likely 

not change. The vast 

majority of the analysis 

area is completely 

unaffected by recreation 

activities, so the isolated 

areas of soil damage are 

not resulting in 

unacceptable amounts of 

detrimental soil damage.

Most existing 

detrimental soil 

damage occurred prior 

to implementation of 

the Forest Plans. Pack 

and saddle stock 

outfitter-guides would 

continue to use 

campsites, trails, and 

grazing areas. There 

would be a small 

reduction in total 

barren core with the 

5,250 square foot 

limitation on barren 

core, but when viewed 

at a landscape scale 

this reduction would be 

inconsequential. Soil in 

and around campsites, 

at stock watering areas, 

and trail crossings 

would continue to be 

compacted and 

displaced by outfitterguides, but the vast 

majority of the analysis 

area is completely 

unaffected by 

recreation activities, so

the isolated areas of 

soil damage are not 

resulting in 

unacceptable amounts 

of detrimental soil 

damage.

Most existing 

detrimental soil 

damage occurred prior 

to implementation of 

the Forest Plans. Pack 

and saddle stock 

outfitter-guides would 

continue to use 

campsites, trails, and 

grazing areas. There 

would be a small 

reduction in total 

barren core with the 

2,800 square foot 

limitation on barren 

core, but when viewed 

at a landscape scale 

this reduction would be 

inconsequential. Soil in 

and around campsites, 

at stock watering areas, 

and trail crossings 

would continue to be 

compacted and 

displaced by outfitterguides, but the vast 

majority of the analysis 

area is completely 

unaffected by 

recreation activities, so 

the isolated areas of 

soil damage are not 

resulting in 

unacceptable amounts 

of detrimental soil 

damage.

Most existing 

detrimental soil damage 

occurred prior to 

implementation of the 

Forest Plans. Pack and 

saddle stock outfitterguides would continue 

to use campsites, trails, 

and grazing areas. There 

would no increase in 

barren core as a result of 

outfitter-guide activities. 

Soil in and around 

campsites, at stock 

watering areas, and trail 

crossings would 

continue to be 

compacted and 

displaced by outfitterguides, but the vast 

majority of the analysis 

area is completely 

unaffected by recreation 

activities, so the isolated 

areas of soil damage are 

not resulting in 

unacceptable amounts 

of detrimental soil 

damage.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-51 February 2013

Okanogan-Wenatchee National Forest

Other Issues Unit of Measure Alternative 1 Alternative 2 Alternative 3 Alternative 4

Pack and saddle stock 

outfitter-guide grazing could 

exceed Forest Plan 

standards and guidelines 

pertaining to forage 

utilization.

Qualitative 

discussion

There would be no 

outfitter-guide stock 

forage use with this 

alternative. Nonoutfitted stock would 

continue to graze 

around campsites. 

Stock forage utilization 

would be well within 

allowable use standards 

and consistent with all 

standards and 

guidelines. There would 

continue to be localized 

areas of concentrated 

use associated with 

camps. With the closing 

of the wilderness 

livestock permits, forage 

use and resource 

impacts are still very far 

below the use and 

impacts under the old 

grazing allotment 

stocking rates.

Outfitter-guide stock 

forage utilization would 

be well within allowable 

use standards and 

consistent with all 

standards and 

guidelines. There would 

be localized areas of 

concentrated use 

associated with camps. 

With the closing of the 

wilderness livestock 

permits, even with 

outfitter-guide grazing, 

the forage use and 

resource impacts are 

still very far below the 

use and impacts under 

the old grazing 

allotment stocking rates.

Outfitter-guide stock 

forage utilization would 

be well within allowable 

use standards and 

consistent with all 

standards and 

guidelines. There would 

be localized areas of

concentrated use 

associated with camps. 

With the closing of the 

wilderness livestock 

permits, even with 

outfitter-guide grazing, 

the forage use and 

resource impacts are 

still very far below the 

use and impacts under 

the old grazing 

allotment stocking rates.

Outfitter-guide stock 

forage utilization 

would be well within 

allowable use 

standards and 

consistent with all 

standards and 

guidelines. There 

would be localized 

areas of concentrated 

use associated with 

camps. With the 

closing of the 

wilderness livestock 

permits, even with 

outfitter-guide 

grazing, the forage 

use and resource 

impacts are still very 

far below the use and 

impacts under the old 

grazing allotment 

stocking rates.

Pack and saddle stock 

outfitter-guides are 

important to the local 

economy. 

Number of Jobs

Labor Income

Total Sales

0

$0

$0

27.6 jobs

$922,451

$1,340,359

15.9 jobs

$531,108

$771,722

40 jobs

$1,337,753

$1,943,811
Pack and Saddle Stock Outfitter-Guide Permit FEIS 2-52 February 2013

Okanogan-Wenatchee National Forest

PREFERRED ALTERNATIVE

The Preferred Alternative is Alternative 4.