Pack and Saddle Stock Outfitter-Guide Permit Draft EIS 1-1 August 2010

Okanogan-Wenatchee National Forest

Chapter

1 

Purpose and Need

Introduction

Pack and saddle stock outfitters have been operating throughout the analysis area for the past 

20 to 50 years. Some operated under 5-year term permits, while other operated under shortterm permits (lasting less than one year). All the 5-year permits expired around 10 years ago, 

and since that time, all the businesses have been issued short-term permits annually to allow 

them to continue operations while the environmental analysis of the proposal to issue 10-year 

permits was completed. 

This document displays the analysis of issuing 10-year term pack and saddle stock outfitterguide special use permits these businesses, or to other suitable businesses if those listed stop 

operations. The current combined number of actual service days for all existing short-term 

permits represents around 2% of the overall outfitted and non-outfitted visitor days (defined as 

one person for one day) across the analysis area, and approximately 9% of all pack and saddle 

stock use. The analysis area is shown on Map 1-1 in the Map Section of this document.

Document Organization

The Forest Service has prepared this Draft Environmental Impact Statement (DEIS) in compliance 

with the National Environmental Policy Act (NEPA) and other relevant Federal and State laws 

and regulations. The DEIS discloses the direct, indirect, and cumulative environmental effects 

that would result from implementing the proposed action and alternatives to the proposed 

action. The Record of Decision, which is the decision document associated with this EIS, is a 

separate document and is written after public review of the DEIS and completion of the Final 

EIS.

This document contains the following:

Chapter 1. Purpose and Need for Action: Provides information on the background of the 

proposal, the planning framework that guides management of this portion of the National 

Forest, the purpose and need for the project, and the agency proposal (Proposed Action) for 

achieving that purpose and need. This chapter also details how the Forest Service informed 

the public of the proposal and how the public responded. Finally, this chapter lists issues

developed in response to the proposed action.

Chapter 2. Alternatives, including the Proposed Action: A detailed description of the

proposed action as well as alternative methods for achieving the purpose and need. The

alternatives were developed based on significant issues raised by the public. Mitigation 

measures and monitoring are also detailed. Finally, this chapter provides a summary table 
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which compares the components and environmental consequences associated with each 

alternative.

Chapter 3. Affected Environment and Environmental Consequences: Description of the 

affected environment of area resources and the environmental effects of implementing the 

proposed action and alternatives described in Chapter 2. Relevant direction from National 

Forest Land and Resource Management Plans and applicable laws and regulations are also 

detailed.

Chapter 4. List of Preparers: List of individuals who helped prepare the document

Chapter 5 Consultation and Coordination: List of agencies, organizations, and persons to

whom copies of the document were sent.

Map Section: Includes 11 inch by 17 inch copies of the maps referenced throughout the 

document.

Glossary: Definitions of terms used in the document.

Literature Citations: List of citations used in the document.

Index: List of key words and page numbers.

Appendices: Provide more detailed information to support the analysis presented in the 

DEIS, including an index as required by the implementing regulations for NEPA.

Analysis Area

The analysis area is located on the Okanogan-Wenatchee National Forest and a portion of the 

Mt. Baker-Snoqualmie National Forest administered by the Okanogan-Wenatchee. The existing 

outfitter-guide permits include the entire analysis area. Most of the analysis area is on the 

Methow Valley Ranger District with some overlap on the Tonasket and Chelan Ranger Districts. 

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

Highway Corridor, Sawtooth Backcountry, the Bear/Ramsey/Volstead area, and some National 

Forest System land adjacent to these areas. The analysis area has been divided into seven

smaller areas in order to track activities and environmental effects in this analysis:

Pasayten Wilderness

Lake Chelan-Sawtooth Wilderness

North Cascades

Sawtooth Backcountry

Bear/Ramsey/Volstead Area

Middle Methow

Alta Lake

Map 1-2 shows the analysis area and Map 1-3 shows the individual sub units. Both are located 

in the Map Section of this document. Large scale maps are located in the analysis file. The 

following figure shows the number of acres by area, Forest Service District, and acres in the 

analysis area.
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Okanogan-Wenatchee National Forest

Figure 1-1: Analysis Area Acreage

Sub-Unit District Analysis Acres

Pasayten Wilderness Methow Valley and 

Tonasket

531,541

Lake Chelan-Sawtooth Wilderness Methow Valley and 

Chelan

153,129

North Cascades Methow Valley 270,435

Sawtooth Backcountry Methow Valley and 

Chelan

35,149

Bear/Ramsey/Volstead Methow Valley 58,114

Middle Methow Methow Valley 50,550

Alta Lake Chelan 3,958

Total 1,102,876

Pasayten Wilderness

The 531,541 acre Pasayten Wilderness spans parts of both the Methow Valley and Tonasket Ranger 

Districts. The trailheads that access wilderness from the Tonasket District are Irongate, Chewuch, Long 

Swamp, and Fourteen Mile. On the Methow Valley Ranger District, trails from the Thirtymile, Andrews, 

Lake Creek, Crystal Lake, Falls Creek, and Billy Goat trailheads lead into wilderness from the Chewuch 

Watershed. From the Harts Pass area, trails from the Robinson Creek, Monument Creek, Buckskin 

Ridge, Harts Pass, West Fork Pasayten, and Pacific Crest Trail North trailheads lead into wilderness. 

Another trail leaving the Canyon Creek trailhead on Washington State Highway 20 (SH 20) leads to the 

western edge of the Pasayten.

Lake Chelan-Sawtooth Wilderness

The Lake Chelan-Sawtooth Wilderness is divided between the Methow Valley and Chelan Ranger 

Districts, and covers 153,129 acres. On the Methow Valley Ranger District, the Wolf Creek, Slate Creek, 

Scatter Creek, Gilbert, South Creek, Reynolds Creek, Williams Lake, War Creek, Eagle Creek, West Fork 

Buttermilk, East Fork Buttermilk, Scaffold Ridge, and Libby Lake trailheads provide access. On the 

Chelan Ranger District, the Fish Creek and Prince Creek trailheads provide access from the Chelan 

Ranger District; these are along the shores of Lake Chelan accessible only by boat. There is a pack and 

saddle stock outfitter-guide camp at Fish Creek just outside the wilderness boundary.

North Cascades

The North Cascades portion of the analysis area includes the area outside wilderness and north 

of Wolf Creek. There are five major recreation areas in the Upper Methow portion of the 

analysis area.

The North Cascades Scenic Highway (Washington State Route 20) passes through the 

Methow Valley Ranger District for about 40 miles. It is a major travel route between the 

Methow Valley and northern portion of the greater Seattle area during the non-snowbound 

months, and is the most densely used recreation area in the analysis area. The Scenic 

Corridor includes the slopes on either side of the highway, bounded by the upper-most 

ridges as seen from the highway. The highway is not plowed in winter, and is typically open 

to wheeled vehicles from April 30 to December 1. The State Department of Transportation 

stops plowing the highway around the first of December; it usually reopens in time for the 

opening day of fishing season at the end of April. This varies from year to year depending 

on the weather and snowpack.
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The Cedar Creek/Early Winters area is along the North Cascades Scenic Highway. The Cedar 

Creek Trail, and trails and roads around the Early Winters Campground and the nearby 

Freestone Inn receive the most use.

The West Fork Methow area is directly north of the Scenic Corridor. The West Fork Methow 

trail is popular for hikers, mountain bikers, and horseback riders. It begins at the 

Rattlesnake Trailhead northwest of Mazama, and intersects with the Pacific Crest Trail about 

nine miles from the trailhead. The Pacific Crest Trail passes through the middle of this area.

Harts Pass is one of the most popular and frequently visited areas on the Methow Valley 

Ranger District. Over half of the people who visit Harts Pass are driving for pleasure; hiking 

is also a popular activity. There are two trailheads that access the Pacific Crest Trail and a 

trail to the Slate Peak Lookout, in addition to trails that lead into the Pasayten Wilderness.

The Goat Creek area is located northeast of the Methow River. The most popular recreation 

destination in this area is Goat Peak Lookout located at the end of a 21⁄2 mile non-motorized 

trail. There are no other trails or trailheads in the area.

This area also includes a narrow band of land adjacent to the Pasayten Wilderness in the 

Chewuch watershed. The Andrews Creek, Lake Creek, Thirtymile, and Billygoat trailheads are 

located in this area; all are within two miles of the wilderness boundary. Most use at these 

trailheads enters wilderness. There are assigned corrals at the Billygoat and Andrews Creek 

trailheads.

Sawtooth Backcountry

The Sawtooth Backcountry is adjacent to the Lake Chelan-Sawtooth Wilderness and is split 

between the Methow Valley and Chelan Ranger Districts. It includes 35,149 acres and several 

high-elevation lakes. There is a mix of motorized and non-motorized trail use originating at the 

Crater Creek and Foggy Dew trailheads on the Methow Valley District, and the South Navarre 

and Safety Harbor trailheads on the Chelan District. The Summer Blossom trailhead on the 

Chelan District allows only hiker use.

Bear/Ramsey/Volstead

The Bear/Ramsey/Volstead area is located east of the Methow River. There are no developed 

trailheads or maintained trails in this area, and recreation is based around the road system. This 

area receives most of the use during mule deer general firearm season in October.

Middle Methow

The Middle Methow portion of the analysis area includes the area east of the Lake ChelanSawtooth Wilderness and east of the Sawtooth Backcountry. There are two major recreation 

areas in the Middle Methow portion of the analysis area.

The Twisp River corridor is bounded by the Lake Chelan-Sawtooth Wilderness on the north, 

west, and south sides. Most trails that begin at trailheads in the corridor enter wilderness 

within about one mile. The Twisp River horse camp is a popular campground specifically 

designed for people with horses and mules. This area also includes several campgrounds 

and the Twisp River trail, which follows the Twisp River from War Creek Campground to 

Gilbert trailhead. There is an assigned base camp at the Slate Creek trailhead.

The Libby Creek and Gold Creek areas are located east of the Lake Chelan-Sawtooth 

Wilderness and the Sawtooth Backcountry. The Libby Creek trail begins in the Middle 

Methow and enters wilderness two miles from the trailhead. The Crater Creek and the 
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Okanogan-Wenatchee National Forest

Foggy Dew trailheads are located in this area; both trails enter the Sawtooth Backcountry 

less than a mile from the trailheads. There is an assigned base camp located near the Crater 

Creek trailhead.

Alta Lake

The Alta Lake portion of the analysis area includes the National Forest System (NFS) land around 

Alta Lake. Adjacent lands include Alta Lake State Park located on the north shore of the lake. 

The remainder of the shoreline is about 50% privately owned and 50% NFS land. There are no 

trailheads or campgrounds on NFS land in the area. The privately-owned Whisperin’ Pine 

campground is located at the southwest end of the lake. There are loop trails around the lake 

and to areas south of the lake. About 50% of these trails are on NFS land. The county road

leading to private properties at the end of the lake crosses over one-quarter mile of NFS land.

Outfitter-Guide Background

The current pack and saddle stock outfitter-guides are described below. Outfitter-guide special 

use permits specify a number of service days. A service day is defined as a day, or part of a day 

on National Forest System lands for which an outfitter-guide provides goods or services, 

including transportation, to a client. When a permit is issued, the number of assigned service 

days is the highest number of service days an outfitter-guide reported over the previous five 

years. 

Backcountry Burro Treks has been operating under a special use permit for burro outfitting and 

guiding since 1983. The current permit includes 235 service days in the Pasayten Wilderness 

and North Cascades analysis area sub-units.

Cascade Corrals has been operating under a special use permit since 1950. The current permit is 

for 209 service days in the Lake Chelan-Sawtooth Wilderness and Sawtooth Backcountry.

Cascade Wilderness Outfitters has been operating under a special use permit since 1960. The 

current permit is for 621 service days in the Pasayten Wilderness, Lake Chelan-Sawtooth 

Wilderness, Sawtooth Backcountry, and North Cascade sub-units. 

Deli Llama Wilderness Adventures has been operating under a special use permit for llama 

outfitting and guiding since 1993. The current permit is for 151 service days in the Pasayten 

Wilderness and North Cascades sub-units. 

Early Winters Outfitting has been operating under a special use permit since 1983. The current 

permit is for 537 service days in the Pasayten Wilderness, North Cascades, and 

Bear/Ramsey/Volstead sub-units. The permit also includes 355 service days for day-rides in the 

North Cascades area. Day rides leave from the permittee’s property, the Early Winters Ranch, 

continue on National Forest System land, and end back at the ranch.

North Cascade Outfitters has been operating under a special use permit since 1980. The current 

permit is for 200 service days in the Pasayten Wilderness and North Cascades sub-units.
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North Cascade Safaris has been operating under a special use permit since 1970. The current 

permit is for 431 service days in the Pasayten Wilderness, Lake Chelan-Sawtooth Wilderness, 

Sawtooth Backcountry, and North Cascades sub-units. 

Sawtooth Outfitters has operated under a special use permit since 1982. The current permit 

includes 343 service days in the Pasayten Wilderness, Lake Chelan-Sawtooth Wilderness, and 

Sawtooth Backcountry sub-units. The permit also includes 585 service days for day-rides in the 

Alta Lake area. Day rides leave from the permittee’s property, the Whistlin’ Pine Ranch, 

continue on National Forest System land, and end at the ranch.

Description of Trip Types

Pack and saddle stock outfitter-guides offer clients a variety of trip types to meet needs, 

expectations, and budgets.

Full-service Pack Trips: Guided horseback riding trips with meals, cook, and most or all 

camping gear provided. Trips may be progressive or base camp type. Progressive trips have 

a series of camps during the trip, while base camp trips stay at one camp for the entire trip 

and take day rides to local attractions. Trips vary from 2 to 10 days or more.

Standard Pack Trip: Same as full-service, except clients provide and prepare their own food.

Full-service Hiking Trips: Guided trips with meals, cook, and most or all camping gear. The 

trips may be progressive or base camp type; clients hike.

Standard Hiking Trips: Same as full-service except clients provide and prepare their own 

food.

Drop Camps: Clients and gear are transported to a location and dropped off. The outfitter 

returns for pick-up on a prearranged day. No guiding services are provided. Most drop 

camps occur during high and general hunting seasons.

Re-supply/Supply Trips: Outfitter transports only supplies to a prearranged location.

Day Rides/Hike: Horseback riding or hiking with pack support for a portion of one day with 

no overnight use. Day rides range from 1⁄2 hour to all day, with the majority lasting one hour.

Regulatory Framework

APPLICABLE LAWS AND EXECUTIVE ORDERS

The following laws and executive orders, with implementing regulations as appropriate, apply to 

the analysis and implementation of the outfitter-guide special use permit issuance:

Wilderness Act of September 3, 1964

The Wilderness Act established a National Wilderness Preservation System to be composed of 

federally owned areas designated by Congress as ''wilderness areas'' and administered for the 
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use and enjoyment of the American people in such manner as will leave them unimpaired for 

future use and enjoyment as Wilderness. The Act provides for the protection of these areas, the 

preservation of wilderness character, and for the gathering and dissemination of information 

regarding use and enjoyment as wilderness.

The Wilderness Act defines wilderness as:

...an area where the earth and community of life are untrammeled by man, where man 

himself is a visitor who does not remain.

The Act goes on to state that wilderness is protected and managed:

...so as to preserve its natural conditions and which (1) generally appears to have been 

affected primarily by the forces of nature, with the imprint of man’s work substantially 

unnoticeable; (2) has outstanding opportunities for solitude or a primitive and unconfined 

type of recreation. Section 1 (c)

The role of the Forest Service, as directed by the Act, is to:

...be responsible for preserving the wilderness character of the area...wilderness areas shall 

be devoted to the public purposes or recreational, scenic, scientific, educational, 

conservation, and historical use. Section 4 (b)

The Act states that “there shall be no commercial enterprise” within wilderness areas. 

However, the Act includes the following special provision:

Commercial services may be performed within the wilderness areas designated by the Act to 

the extent necessary for activities which are proper for realizing the recreational or other 

wilderness purposes of the areas. Section 4 (d)(6)

The Pasayten was designated as a wilderness by Public Law 90-544, dated October 2, 1968. 

Additional area was added to the Pasayten and the Lake Chelan-Sawtooth was designated by 

Public Law 98-339, dated July 3, 1984.

For this analysis, use of the word ‘wilderness’ refers to Congressionally-designated land as part 

of the National Wilderness Preservation System.

National Environmental Policy Act (NEPA) of January 1, 1970

The Act directs all federal agencies to consider and report the potential environmental impacts 

of proposed federal actions and established the Council on Environmental Quality. The Council 

on Environmental Quality implementing regulations at 40 CFR Parts 1500-1508 and Forest 

Service implementing policy and procedures issued in Forest Service Manual 1950 and Forest 

Service Handbook 1909.15 establish the basic process for conducting and documenting

environmental analyses, including public participation. Before a decision to authorize outfitterguide permit issuance is made, the site-specific impacts of outfitter-guide use must be assessed.

National Forest Management Act of October 22, 1976 (as amended)

The National Forest Management Act reorganized, expanded, and otherwise amended the 

Forest and Rangeland Renewable Resources Planning Act of 1974, which called for the 

management of renewable resources on National Forest System lands. The National Forest 

Management Act of 1976 (NFMA) requires each National Forest unit to have a land and resource 

management plan (LRMP). Section 6(i) of NFMA [16 USC 1604(i)] requires that resource plans 

for the use of National Forest System lands must be consistent with the LRMP for the National 

Forest unit on which that use occurs. NFMA requirements are carried out through 

implementation of the Forest Land and Resource Management Plans. This analysis is guided by 
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the Okanogan National Forest Land and Resource Management Plan and Wenatchee National 

Forest Land and Resource Management Plan.

Clean Water Act (CWA) of 1977 and 1982 (as amended)

This Act places primary responsibility for protecting water quality with the States. Section 313 

of the Act (33 USC 1323) requires Federal agencies to comply with all substantive and 

procedural State water quality requirements to the same extent as a non-governmental entity. 

This Act establishes a non-degradation policy for all federally proposed projects. Public 

concerns have been raised that water quality in isolated areas could be degraded by the 

outfitter-guide proposal.

Endangered Species Act (ESA) of 1973 (as amended)

This Act requires the Forest Service to manage for the recovery of endangered and threatened 

species and the ecosystems on which they depend. Implementing regulations are found in 50 

CFR Part 402. The policy and process for Forest Service compliance with the ESA are found in 

Forest Service Manual 2670.31. Section 7 of the ESA requires consultation with the Fish and 

Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) on Federal projects that 

may affect listed species.

National Historic Preservation Act of 1966 (as amended)

This Act requires Federal agencies to consult with American Indian Tribes, State, and local 

groups regarding non-renewable cultural resources, such as archaeological and historic 

structures. Section 106 of the Act requires Federal agencies to review the effects project 

proposals may have on cultural resources in the analysis area.

Executive Order 13112 (invasive species)

This 1999 order requires Federal agencies whose actions may affect the status of invasive 

species to identify those actions and within budgetary limits, “(i) prevent the introduction of 

invasive species; (ii) detect and respond rapidly to and control populations of such species... (iii) 

Monitor invasive species populations... (iv) provide for restoration of native species and habitat 

conditions in ecosystems that have been invaded;...(vi) promote public education on invasive 

species... and (3) not authorize, fund, or carry out actions that it believes are likely to cause or 

promote the introduction of spread of invasive species...unless, pursuant to guidelines that it 

has prescribed, the agency had determined and made public... that the benefits of such actions 

clearly outweigh the potential harm caused by invasive species; and that all feasible and prudent 

measures to minimize risk of harm will be taken in conjunction with the actions.

Other applicable laws and regulations include:

Clean Air Act of August 7, 1977, as amended in 1990

American Antiquities Act of 1906

Bald and Golden Eagle Protection Act of 1940 (as amended)

Migratory Bird Treaty Act of 1918

Federal Noxious Weed Control Act of 1974 (as amended)

American Indian Religious Freedom Act of 1978

Archeological Resource Protection Act of 1980

Native American Graves Protection and Repatriation Act of 1990

Executive Order 11593 (cultural resources)

Executive Order 11988 (floodplains)
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Executive Order 11990 (wetlands)

Executive Order 12898 (environmental justice)

Executive Order 13007 (Indian sacred sites)

Executive Order 13175 (Coordination with Indian Tribal Governments)

Executive Order 13186 (migratory birds)

MANAGEMENT DIRECTION

Management direction for the analysis area has been established by the following 

environmental documents to which this document is tiered.

Forest Service Handbooks and Manuals

Forest Service Handbook 2709.11, Chapter 40, includes direction for administering permits for 

outfitting and guiding. The Forest Service Manual Chapter 2320.2 gives direction for 

wilderness management. Refer to these for detailed information. 

Forest Plans

This analysis and document are tiered to the Okanogan National Forest Land and Resource 

Management Plan Final Environmental Impact Statement (USDA Forest Service 1989a) and its 

accompanying Land and Resource Management Plan (Okanogan Forest Plan, USDA Forest 

Service 1989b), and the Wenatchee National Forest Land and Resource Management Plan Final 

Environmental Impact Statement and its accompanying Land and Resource Management Plan

(Wenatchee Forest Plan, USDA Forest Service 1990). Forest Plan standards and guidelines 

provide general direction for the administration of National Forest System land. The Okanogan 

and Wenatchee Forest Plans have been amended by the following:

The Record of Decision for Amendments to Forest Service and Bureau of Land Management 

Planning Documents within the Range of the Northern Spotted Owl (Northwest Forest Plan, 

USDA and USDI 1994). Northwest Forest Plan allocations pertinent to the analysis area are 

identified below.

o Key Watersheds: a system of large refugia comprising watersheds that serve as refugia 

that are “crucial for maintaining and recovering habitat for at-risk stocks of anadromous 

salmonids and resident fish species” (USDA and USDI 1994: B-18). Much of the area

proposed for permit issuance is located in Northwest Forest Plan Key Watersheds. 

Watershed analyses are complete on all Key Watersheds in the analysis area as is 

required prior to management activities (USDA and USDI 1994: C-7).

o Late-Successional Reserves (LSR): The objective of LSRs is to protect and enhance 

conditions of late-successional and old-growth forest ecosystems, which serve as habitat 

for late-successional and old-growth related species, including the northern spotted 

owl. Management assessments of LSRs within the analysis area have been completed as 

required before any habitat manipulation can occur (USDA and USDI 1994: C-11). Under 

the Northwest Forest Plan, special use permits in LSRs must be designed to have the 

least impact on LSR habitat (USDA and USDI 1994: C-19).

o Riparian Reserves: administrative areas where conservation of aquatic or ripariandependent terrestrial resources receives primary emphasis. Riparian Reserves bound all 

streams and wetlands, regardless of surrounding land allocations. The Northwest Forest 
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Plan and Riparian Reserves are discussed in the Aquatic Section, beginning on page 3-

162. Special use permits in riparian reserves must be adjusted, if needed, to eliminate 

adverse effects that retard or prevent the attainment of the Aquatic Conservation 

Strategy objectives (USDA and USDI 1994: C-37).

Final Environmental Impact Statement for the Pacific Northwest Region Invasive Plant 

Program (USDA Forest Service 2005a), which culminated in a Record of Decision that 

amended the Forest Plan by adding management direction relative to invasive plants. (This 

decision replaces the 1988 “Managing Competing and Unwanted Vegetation” decision, 

although the Courts have not yet vacated the subsequent Mediated Agreement for the 1988 

decision. A crosswalk describing how the Mediated Agreement is met by implementation of 

the new 2005 decision is in the analysis file).

The Okanogan Forest Plan has also been amended by:

The Decision Notice/Decision Record for the Interim Strategies for Managing Anadromous 

Fish-producing Watershed in Eastern Oregon and Washington, Idaho, and Portions of 

California, (PACFISH, USDA and USDI 1995). PACFISH guides management in riparian areas 

east of the area covered by the Northwest Forest Plan, and requires that implementation of 

permits avoid effects that would retard or prevent attainment of the Riparian Management 

Objectives and avoid adverse effects on listed anadromous fish (USDA and USDI 1995: C-16). 

PACFISH also identifies Key Watersheds and provides for completion of watershed analyses 

with a process similar to that in the Northwest Forest Plan. 

The Revised continuation of Interim Management Direction Establishing Riparian, Ecosystem 

and Wildlife Standards for Timber Sales, Appendix B, Regional Forester’s Forest Plan 

Amendment #2 (USDA Forest Service 1995a) commonly known as the Eastside Screens. The 

Eastside Screens focus on the potential impact of timber sales on riparian habitat, historical 

vegetation patterns, and wildlife fragmentation and connectivity, consequently its 

requirements are not relevant to this analysis and will not be discussed further. 

The Okanogan Forest Plan gives priority to special use authorizations that provide a public 

service (USDA Forest Service 1989b: 4-47). The Wenatchee Forest Plan recognizes that outfitterguides provide valuable recreation opportunities for a segment of the public who do not have 

the expertise, equipment, or physical capabilities to enjoy these experiences on their own. The 

Plan states that permits should be issued when there is a demonstrated public need or demand 

for the service, when permitted use is compatible with general public use, and when use can 

occur without exceeding carrying capacities, causing unacceptable impacts, or causing changes 

that approach limits of acceptable change (USDA Forest Service 1990: E-11).

Forest-wide Standards and Guidelines

The Okanogan and Wenatchee National Forest Plans include Forest-wide standards and 

guidelines that apply to all areas within the analysis area, however only the Okanogan Forest 

Plan includes items that specifically pertain to outfitter-guide permits.

“Recreation services partnerships to provide recreation facilities and services shall 

be used where feasible.” Forest-wide Standard and Guideline 8-2;
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“Recreation special use authorizations shall conform to the goals of the MA.” 

Forest-wide standard and guideline 8-11.

Forest Plan Direction for Each Area within the Analysis Area

Both Forest Plans describe management areas (MA) that have goals, desired future conditions, 

and standards and guidelines specific to the areas. Standards and guidelines relevant to 

individual resources are identified in each resource section of Chapter 3. All of the analysis area 

sub-units include either Riparian Reserves (the western portion of the analysis area covered by 

the Northwest Forest Plan) or Riparian Habitat Conservation Areas (the eastern portion of the 

analysis area covered by PACFISH). Each sub-unit of the analysis area is addressed below.

Pasayten and Lake Chelan-Sawtooth Wilderness Areas

Much of the proposed permit areas are in the Pasayten and Lake Chelan-Sawtooth Wilderness 

Areas, and designated as Congressionally Reserved in the Northwest Forest Plan. Wilderness is 

designated MA 15A or MA 15B in the Okanogan Forest Plan, and Pristine, Primitive, SemiPrimitive, or Transition Wilderness Recreation Opportunity Spectrum Classes in the Wenatchee 

Forest Plan. Pack and saddle stock outfitters are not allowed to operate in MA 15A or in the 

Pristine or Transition Spectrum Class areas in the Lake Chelan-Sawtooth Wilderness. Map 1-4

and Map 1-5 in the Map Section of this document show wilderness management areas.

The goal of MA 15B is to maintain a predominately unmodified primitive environment within 

designated wilderness with a variety of trail opportunities. The standards and guidelines for this 

management area are located on pages 4-91 through 4-97 in the Okanogan Forest Plan. The 

desired future condition is:

“*a+n area with a minimum of on-site controls and restrictions, and where the 

presence of controls would be subtle. Facilities would only be provided for 

protection of wilderness resource values. Materials should be native where possible 

and in all cases would be natural appearing. The area would provide a high to 

moderate opportunity for exploring and experiencing isolation and solitude, 

independence, closeness to nature, tranquility, and self-reliance through the 

application of primitive skills in an environment that offers a high to moderate 

degree of challenge and risk.” (USDA Forest Service 1989b: 4-91)

The standards and guidelines for Primitive Wilderness Recreation Opportunity Spectrum (WROS) 

are located on pages IV-71 and IV-72 in the Wenatchee Forest Plan. Primitive WROS Class is:

“*c+haracterized by an essentially un-modified, natural environment. 

Concentrations of visitors are low and evidence of human use is minimal. The area 

has high opportunity for isolation, solitude, exploration, risk, and challenge (USDA 

Forest Service 1990: IV-71).

The standards and guidelines for Semi-Primitive WROS are located on pages IV-73 and IV-74 in 

the Wenatchee Forest Plan. Semi-Primitive WROS Class is:

“*c+haracterized by a predominantly unmodified environment of at least moderate 

size. System trails and campsites are present and there is evidence of other uses. A 

minimum of on-site controls and restrictions are implemented to protect physical, 

biological, and social resources. Some facilities may be present to reduce visitor 

impact. (USDA Forest Service 1990: IV-73).
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Okanogan-Wenatchee National Forest

The standards and guidelines for Transition WROS are located on pages IV-75 and IV-76 in the 

Wenatchee Forest Plan. Transition WROS Class is:

[c]haracterized by a predominately unmodified environment, however, the 

concentrations of visitors may be moderate to high at various times. The area is 

characterized as having a large number of day users who are often mixed with 

overnight and long-distance travelers on trails near trailheads and wilderness 

boundaries.

North Cascades

This sub-unit includes the North Cascades Scenic Corridor, the Harts Pass area, and the land in 

between. 

The North Cascades Scenic Corridor is in MA 7 in the Okanogan Forest Plan. Standards and 

guidelines for this management area are located on pages 4-70 through 4-72 in the Okanogan 

Forest Plan. The desired future condition of this management area is:

“*t+he existing scenic values of the area would be preserved while allowing for 

moderate expansion of recreation facilities with an emphasis on day use and short 

duration stay opportunities....Easy Pass, Rainy Lake, Lake Ann, Blue Lake, and 

Washington Pass Trails shall be closed to horse use.” (USDA Forest Service 1989b: 

4-70)

The remainder of this sub-unit includes MAs 4, 5, 8, 10, 14, 17, 24, and 25 in the Okanogan 

Forest Plan. MAs 4 and 24 are managed for semi-primitive non-motorized recreation, MA 5 for 

recreation and scenery, MA 8 as a research natural area, MA 10 for mountain goats, MA 14 for 

deer winter range, MA 17 for developed recreation, and MA 24 for timber and range resources. 

The desired future conditions, and standards and guidelines for these management areas are 

described on pages 4-61, 4-65, 4-73, 4-76, 4-83, 4-98, 4-101, and 4-103, respectively. Portions 

of this sub-unit lie within the Upper Methow Late-Successional Reserve. Map 1-6 in the Map 

Section of this document shows the Upper Methow management areas.

Sawtooth Backcountry

The Sawtooth Backcountry is divided between the Methow Valley and Chelan Ranger Districts.

The Methow portion is in MA 4M of the Okanogan Forest Plan, which is managed for year-round 

semi-primitive motorized recreation. The standards and guidelines for this management area 

are located on pages 4-63 through 4-64 in the Okanogan Forest Plan. The desired future 

condition is:

“*r}ecreation opportunities would be provided in areas characterized by a 

predominately natural or naturally appearing environment. Users would have a 

moderate probability of experiencing isolation from the sights and sounds of 

humans, independence, closeness to nature, tranquility, and self-reliance through 

the application of outdoor skills in an environment that offers challenge and risk. 

Concentrations of users would generally be low. Areas would be managed with 

subtle on site controls and restrictions.” (USDA Forest Service 1989b: 4-63)
Pack and Saddle Stock Outfitter-Guide Permit Draft EIS 1-13 August 2010

Okanogan-Wenatchee National Forest

The Chelan portion is in MA RE2a in the Wenatchee Forest Plan. The standards and guidelines 

for this management area can be found on pages IV-165 through IV-169. The goal for this 

management area is to:

[p]rovide dispersed, unroaded recreation in a semi-primitive motorized recreation 

opportunity setting (USDA Forest Service 1990: IV-165).

The description of the area is:

[t]his prescription is for application to unroaded areas in which trails are evident 

and maintained for...existing or potential trails for motorbikes, hikers and horseback 

riders (USDA Forest Service 1990: IV-165).

Portions of this sub-unit are in the Sawtooth Late-Successional Reserve. Map 1-7 in the 

Map Section of this document shows the Sawtooth Backcountry management areas.

Bear/Ramsey/Volstead

The Bear/Ramsey/Volstead area is divided between MAs 14, 25, and 26 in the Okanogan Forest 

Plan. MAs 14 and 26 are managed primarily for deer winter range and MA 25 is managed 

primarily for timber and range resources. The desired future conditions, and standards and 

guidelines for these management areas are described on pages 4-83, 4-103, and 4-107, 

respectively. Map 1-8 in the Map Section of this document shows the Bear/Ramsey/Volstead

management areas.

Middle Methow

The Middle Methow portion of the analysis area includes MAs 5, 8, 10, 14, 25, and 26 in the 

Okanogan Forest Plan. Management in these areas is described above. The desired future 

conditions, and standards and guidelines for these management areas are described on pages 4-

65, 4-73, 4-76, 4-83, 4-103, and 4-107, respectively. Portions of this sub-unit lie within the Twisp 

River and Sawtooth Late-Successional Reserves. Map 1-9 in the Map Section of this document

shows the Middle Methow management areas.

Alta Lake

The Alta Lake portion includes MAs 5 and 14. Management of these areas is described above. 

These management areas are founds in the Okanogan Forest Plan, beginning on pages 4-65 and 

4-83, respectively. Map 1-10 in the Map Section of this document shows the Alta Lake

management areas.

Other Policy and Analyses Considered and Incorporated by Reference

Other policy and landscape-level assessments were utilized in the analysis. These include the 

following, which are incorporated into this EIS by reference.

An Assessment of the Northeastern Cascades Late-Successional Reserves (USDA Forest Service 

1998a) 

The LSR Assessment discusses the current condition and management implications for latesuccessional reserves (LSR). The Twisp River, Upper Methow, and Sawtooth LSRs lie partially 

within the analysis area. Pack and saddle stock activities were not specifically addressed in

these LSRs, although the Twisp River and Upper Methow were identified as LSRs with increasing 

levels of recreational use and concurrent recommendations to carefully consider effects of 
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Okanogan-Wenatchee National Forest

increasing use. The LSR Assessment was reviewed by the Regional Ecosystem Office (REO) and

found to provide a sufficient framework and context for future projects. In a memorandum of 

April 7, 1998, REO provided an exemption of project-level REO review.

Grizzly Bear Core Habitat Policy

The Forest Supervisor developed a policy in the August 12, 1997 “Grizzly Bear Recovery – North 

Cascades Ecosystem” letter (USDA Forest Service 1997b), signed jointly by Forest Supervisors for 

the Wenatchee, Okanogan, and Mt. Baker-Snoqualmie National Forests, required an interim 

standard of “no net loss of existing core habitat”. The interim standard will be updated during 

the Forest Plan revision process. Grizzly bear core habitat was defined as the area greater than 

0.3 miles from any motorized-access route or high-use non-motorized access route. The Grizzly 

Bear Core Habitat policy is incorporated by reference. The effects on this habitat are described 

in the Wildlife section of Chapter 3.

Watershed Analyses

Completion of watershed analyses within Key watersheds has been completed, as discussed in

both the Northwest Forest Plan and PACFISH (USDA and USDI 1994 and 1995). Watershed 

analysis is a systematic procedure for evaluating the geomorphic and ecologic processes 

operating in a specific watershed. Watershed analysis serves as the basis for developing 

project-specific proposals and determining monitoring and restoration needs for a watershed. 

In all of the watershed analyses completed within the analysis area, information needed for 

making sound management decisions was collected and compiled. Pack and saddle stock or 

outfitter-guide activities were not identified as a substantial use affecting ecosystem function

and were not discussed in depth in any of the analyses. Limited discussions of issues that may 

have a relationship to outfitter-guide use occur in the Upper Methow and Toats Coulee analyses 

and are discussed below. A complete list of the watershed analyses for the analysis area is 

shown in Figure 3.6-1 under Aquatic Resources. The following watershed analyses include areas 

within the analysis area:

Chewuch River Watershed Analysis (USDA Forest Service 1994)

The Chewuch River is a Key Watershed in both the Northwest Forest Plan (in the portion of the 

drainage west of the river) and PACFISH (in the portion east of the river).

Early Winters Creek Watershed Analysis (USDA Forest Service 1996b)

Early Winters Creek is designated as a Key Watershed in the Northwest Forest Plan and contains 

a portion of the Upper Methow Late-Successional Reserve.

Toats Coulee Watershed Analysis (USDA Forest Service 1995b)

Toats Coulee is not a Key Watershed. Within the watershed analysis, pack animal damage to 

stream banks in certain places used to access water was identified as a riparian and aquatic 

habitat issue.

Lost River and Robinson Creek Watershed Analysis (USDA Forest Service 1996c)

The Lost River is designated as a Key Watershed in the Northwest Forest Plan and includes a 

portion of the Upper Methow Late-Successional Reserve. The analysis was focused on 

examining the potential for re-introduction of natural fire into the ecosystem in relationship to 

the Pasayten Wilderness Prescribed Natural Fire Plan.
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Okanogan-Wenatchee National Forest

Twisp River Watershed Analysis (USDA Forest Service 1995c)

The Twisp River is designated as a Key Watershed in the Northwest Forest Plan and contains the 

Twisp River Late-Successional Reserve.

Middle Methow Watershed Assessment (USDA Forest Service 1997c)

The Middle Methow watershed is a Key Watershed under the Northwest Forest Plan and 

PACFISH. It contains a portion of the Sawtooth Late-Successional Reserve.

Salmon Watershed Assessment (USDA Forest Service 1997d)

Salmon Creek is not designated as a Key Watershed.

Upper Methow Watershed Analysis (USDA Forest Service 1998b)

The Upper Methow watershed is a designated as a Key Watershed under the Northwest Forest 

Plan. Most of the Upper Methow Late-Successional Reserve lies within the watershed. Two 

management activities were identified that have influenced aquatic habitat: recreational fishing 

that could increase bull trout mortality, and recreational use on portions of Riparian Reserves 

near Hidden Lakes (see mitigation measures).

Lower Methow Watershed Analysis (USDA Forest Service 1999c)

The Lower Methow River is designated as a Key Watershed under the Northwest Forest Plan 

and PACFISH.

Middle Lake Chelan Watershed Assessment (USDA Forest Service 1999d)

Lower Lake Chelan is not designated as a Key Watershed.

Upper Lake Chelan Watershed Assessment (USDA Forest Service 2000b)

Upper Lake Chelan is not designated as a Key Watershed.

Upper Skagit River Watershed Analysis (USDA Forest Service 2001)

The Upper Skagit River is not designated as a Key Watershed.

Guidance

Determination of Need and Extent Necessary for Commercial Services (Outfitters and Guides) 

in the Pasayten Wilderness and Lake Chelan-Sawtooth Wilderness, 2010 (USDA Forest Service, 

2010)

The Forest Service found that there is a need for pack and saddle stock outfitter-guide 

operations in wilderness to meet recreational purposes. This analysis is documented in the 

Determination of Need and Extent Necessary for Commercial Services (Outfitters and Guides) in 

the Pasayten Wilderness and Lake Chelan-Sawtooth Wilderness, 2010 (USDA Forest Service, 

2010), hereafter called the “Needs Assessment”. The Needs Assessment used a criteria-based 

perspective to determine the need for outfitter-guides. Commercial services for pack and 

saddle stock activities were found to be allowed under the Wilderness Act, to educate clients 

about wilderness, and that solitude or primitive and unconfined recreation were central to the 

activity. The assessment also determined the commercial services would provide a public 

purpose that met the specifications in the wilderness act, and that an element of the population 

did not have the skill, knowledge, and equipment needed for pack and saddle stock trips. 

Novice pack and saddle stock users are also at a higher risk of injury or death compared to 
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Okanogan-Wenatchee National Forest

experienced handlers. There is also consistent, demonstrated demand for the service by a 

portion of the recreationists on the forests. 

The Needs Assessment also determined that the minimum extent necessary for providing 

commercial services was to provide 2,000 service days in the Pasayten and 720 service days in 

the Lake Chelan-Sawtooth. The Needs Assessment provides more information and is available in 

the analysis file.

Purpose and Need for the Proposed Action

The purpose and need is the objectives of the analysis. It provides the underlying reasons for 

the Forest Service in developing the Proposed Action. The purpose and need for action of this 

analysis is three-fold:

respond to special use permit applications from current pack and saddle stock outfitterguides,

protect wilderness character in the Pasayten and Lake Chelan-Sawtooth Wilderness Areas 

while providing necessary pack and saddle stock outfitter-guide commercial services,

amend forest plan standards and guidelines for campsite barren core (see Glossary) in 

wilderness to be consistent with the designated party size for pack and saddle stock 

outfitter-guides (12 people and 18 head of stock).

Respond to Permit Applications

Previously-issued term special use permits for the outfitter-guides listed at the beginning of this 

chapter have expired and each of the outfitter-guides has submitted an application for 10-year 

term permits. A purpose and need for action is to respond to these applications. 

The Forest Service Special Uses Handbook (FSH 2709.11, USDA Forest Service 2004a) specifies 

the steps to follow for proposals (applications) that have been accepted. Section 12.5 states a 

“proposal is considered a proposed action for the purposes of NEPA when it is accepted as a 

formal written application”. The Forest Plans either give priority to authorizations that provide 

a public service (Okanogan Forest Plan, page 4-47), or where there is a demonstrated public 

need or demand for recreation service (Wenatchee Forest Plan, page E-11). The Okanogan 

Forest Plan encourages the use of recreation service partnerships and special use authorizations 

where they are compatible with the goals of the management area (Okanogan Forest Plan, 

pages 4-38 to 4-39). The Wenatchee Forest Plan also recognizes that outfitter-guides provide 

valuable recreational opportunities for the segment of the public who do not have the expertise, 

equipment or physical capabilities to enjoy these experiences on their own (Wenatchee Forest 

Plan, page E-11).

Protect Wilderness Character While Allowing Minimum Commercial Services

The current permit areas include the Pasayten and Lake Chelan-Sawtooth wilderness areas. The 

general purpose and need for commercial services in wilderness is to preserve the wilderness 

character and provide commercial services “to the extent necessary for activities which are 

proper for realizing recreational or other wilderness purposes” (Wilderness Act). There is a 

need to protect wilderness character while providing necessary pack and saddle stock outfitterguide commercial services. 
Pack and Saddle Stock Outfitter-Guide Permit Draft EIS 1-17 August 2010

Okanogan-Wenatchee National Forest

The Forest Service completed the analysis for both the need and extent necessary, and 

documented the findings in a paper titled “Determination of Need and Extent Necessary for 

Commercial Services (Outfitters and Guides) in the Pasayten Wilderness and Lake ChelanSawtooth Wilderness”, June 2010 (USDA Forest Service, 2010). This paper is referred to as the 

“Needs Assessment” in this document. 

The analysis found there is a need for pack and saddle stock outfitter guides in wilderness. The 

criteria used for the evaluation included:

Is the activity allowed in wilderness?

Does the activity educate clients about the wilderness resource?

Does the activity promote solitude, or primitive and unconfined recreation?

Does the activity provide a public purpose, and does the level of skill, knowledge, 

equipment, and safety required for the activity support the need for commercial 

services?

Pack and saddle stock use is an appropriate mode of transportation in wilderness, since it does 

not include any mechanized or motorized equipment. Outfitter-guides teach their clients about 

wilderness directly in conservations about wilderness, and indirectly through demonstrating 

how to travel and stay in the wilderness without modern conveniences. Pack and saddle stock 

outfitter-guides trips promote solitude by taking clients to remote locations within wilderness, 

and letting them experience primitive and unconfined recreation. The outfitters also serve a 

public purpose by offering trips for recreation, scenic viewing, and historic use to the public. 

Their services are needed by an element of the public due to the fact that many people are not 

skilled in stock handling, do not own stock and equipment, do not have the knowledge of stock 

handling techniques that minimize resource damage, and would be endangering their lives of 

the lives of others because of the hazards associated with stock.

The minimum amount of commercial services needed to provide for recreation is not a number 

that can be precisely calculated. The analysis of the impact of existing recreation use (including 

outfitter-guides) on wilderness character has shown that there are localized impacts to the 

opportunities for solitude, but these are not interfering with the current upward trend in 

wilderness character for the Pasayten or Lake Chelan-Sawtooth wildernesses. Current 

conditions meet or exceed the expectations of the vast majority of wilderness visitors (Burns, et 

al, 2010). The current recreation use, including the outfitter-guides complies with nearly all the 

existing Forest Plan standards and guidelines. 

The Forest Service has a need for commercial pack and saddle stock outfitter-guides in order to 

provide for wilderness appropriate recreation, based on the analysis of need discussed above. 

Approximately 11% of the pack and saddle stock users in the Pasayten Wilderness have been 

outfitted annually, over the past 10 years; with approximately 3% in the Lake Chelan-Sawtooth 

Wilderness. This is the minimum extent necessary for these commercial services. This number 

is at or very near the minimum number required for businesses to stay in operation. If the level 

was reduced, there is a high likelihood that some businesses would fail. This would create a 

high probability of unpredictable changes in the types of services available, and a risk to the 

Forest Service’s ability to meet the identified needs. 

The use levels in both wildernesses is within the social and biophysical capacity, and allocating 

11% of the anticipated 2020 use pack and saddle stock use levels in the Pasayten and 3% of the 
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Okanogan-Wenatchee National Forest

use in the Lake Chelan-Sawtooth will not exceed capacity. Therefore, the minimum number of 

service days needed for pack and saddle stock outfitter guides is 2,000 in the Pasayten and 720 

in the Lake Chelan-Sawtooth.

Revise Wilderness Barren Core Campsite Standards

Currently both the Okanogan and Wenatchee Forest Plans have inconsistent management 

direction regarding party sizes and maximum vegetation loss sizes (USDA, 1989a and USDA, 

1990). Wilderness standards and guidelines allow for a party size of 12 people and 18 head of 

stock (standard and guideline MA 15B-21N in the Okanogan Forest Plan, and Table IV-15, page 

IV-77, Wenatchee Forest Plan), yet campsites can have no more than 400 to 1,000 square feet of 

vegetation loss or barren core, depending on the Management Area or Wilderness Recreation 

Opportunity Spectrum Class (MA 15B-22b, Okanogan Forest Plan, and Table IV-5, page IV-77, 

Wenatchee Forest Plan). 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. 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.

When the Forest Plans were adopted in 1989 and 1990, standards regarding acceptable 

campsite impacts were incorporated. Those standards were based on the science and literature 

available at the time, with the awareness that there were some long-standing existing campsites 

that exceeded the Forest Plans standards for acceptable size. These same campsites still exist 

and are currently used by outfitter-guides and the non-outfitted public. 

In the time between when the Forest Plans were published and the present (nearly two 

decades), substantial research on recreation impacts in wilderness has been conducted, and the 

results have consistently suggested that utilizing campsites where impacts already exist is far 

preferable to and more likely to comply with the non-degradation principle than is excluding use 

from these existing sites if the likely result is creation of new, additional impacts (new 

campsites) as people are displaced from the closed sites (Cole and Hall, 1992). Many of the sites 

that were not within standards at the time the plan was adopted are in improved or stable 

condition, although they remain outside Forest Plan standards. 

Even though wilderness condition has been on an upward or stable trend since designation, 

groups of 12 people and 18 head of stock perpetuate camps with a barren core in some areas. 

Generally, groups of 12 people and 18 head of stock could perpetuate barren core conditions up 

to 5,250 square feet (see Appendix A for calculations). Amendment of the Forest Plans is a 

mechanism to create compatibility between barren core standards and party size allowances for 

pack and saddle stock outfitter-guide camps in wilderness that would not increase current levels 

of barren core and would allow these needed commercial services to continue.

Proposed Action

The proposed action is developed early in the process to authorize, recommend, or implement 

an action to meet stated purposes, needs, and goals based on the best known information. It is 

used to generate issues for further study. Alternative 2 described below and in Chapter 2 is, in 

large part, the proposed action that was mailed to interested parties during public scoping. The 
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Okanogan-Wenatchee National Forest

number of service days was modified to meet current manual direction for determining service 

days (FSH 2709.11, Chapter 40). 

The Okanogan-Wenatchee National Forest Supervisor proposes to issue ten-year, term special 

use permits to the following pack and saddle stock outfitter-guide companies in the Pasayten 

Wilderness, Lake Chelan-Sawtooth Wilderness, Sawtooth Backcountry, North Cascades, Middle 

Methow, Bear/Ramsey/Volstead, and Alta Lake areas following completion of the analysis 

process (likely spring 2011):

Backcountry Burros

Cascade Wilderness Outfitters

Deli Llama Wilderness Adventures

Early Winters Outfitting

North Cascade Outfitters

North Cascade Safaris

Sawtooth Outfitters

Permits could also be issued to other acceptable businesses if any of the above businesses cease 

operations, or have permits revoked, as long as the maximum annual services days presented 

below are not exceeded.

A maximum of 4,620 annual priority use service days would be assigned to the outfitters, or 

replacements. A service day is defined as one outfitter-guide client for one day. Each ten-year 

permit would include a specific number of priority use service days that would equal the highest 

amount of actual use each has had in the five years prior to the issuance date. Any days not 

assigned would be held in a pool that could be accessed by the outfitter-guides to cover days 

that exceed the number of assigned day (FSH 2709.11). 

Permit areas include all MA 15B areas in the Pasayten and Lake Chelan-Sawtooth Wilderness 

Areas on the Okanogan National Forest, and the portion of the Lake Chelan-Sawtooth 

Wilderness on the Wenatchee National Forest allocated to Transition, Primitive, and SemiPrimitive, and the North Cascades, Sawtooth Backcountry, Bear/Ramsey/Volstead, Middle 

Methow, and Alta Lake areas. These areas are shown on Map 1-3 in the Map Section of this 

document.

The proposed action includes assigned site locations for camps at Bald Mountain, Sheep 

Mountain, Crow Lake, and Beaver Creek. An existing camp at Whistler would be designated as

an additional assigned site. Assigned sites are locations authorized for occupancy and use for 

which a fee is paid by the permit holder (also called ‘designated’ or ‘reserved’ sites). The listed 

sites are in the Pasayten Wilderness (refer to Map 1-11 in the Map Section of this document). 

Assigned sites are primarily used for guided horseback trips with cooked meals and most or all 

camping gear provided. Outfitter-guides can set up camps at these locations for the entire 

season. All camp equipment except hitch rails, corrals, and tent poles are removed from the 

campsite at season end and not cached over winter. Camp locations for all other trips are 

limited to existing camp locations. Equipment and supplies are not left at these locations for 

more than 24 hours when camp is not occupied. Assigned site locations allow better monitoring 

because use impacts would be solely from outfitter-guide activity. Additional assigned sites 
Pack and Saddle Stock Outfitter-Guide Permit Draft EIS 1-20 August 2010

Okanogan-Wenatchee National Forest

could be designated to allow for closer monitoring and subsequent modification of use to 

address resource concerns and assist in outfitter-guide operations.

The proposed action includes assigned sites for base camps at the Andrews Creek, Billygoat, 

Slate Creek, and Crater Creek trailheads; Fish Creek camp (Chelan) would also be used. These 

locations are outside wilderness. Each location has corrals, watering troughs, and other 

improvements necessary to protect resources. The assigned camps and base camps are shown 

on Map 1-11 in the Map Section of this document.

Forest Plan Amendment

The following standard and guideline would be added to the Okanogan and Wenatchee Forest 

Plans. It would pertain only to pack and saddle stock outfitter-guide operations in wilderness.

“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 us 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.”

Decision Framework

The District Ranger of the Methow Valley Ranger District, Okanogan-Wenatchee National Forest

is the Responsible Official and will decide whether or not to issue term special use permits to 

the outfitter-guides described in the proposed action. The District Ranger will also decide what, 

if any, mitigation measures and monitoring are needed. The decision will be made based upon 

the analysis made in the EIS and considering comments to the Draft EIS. It will be documented 

in a Record of Decision, a companion document to the Final EIS.

DECISION FACTORS

The Responsible Official will determine if the selected alternative is consistent with 

management direction. The decision regarding which action to implement will be determined 

by comparing how each factor of the purpose and need is met by each of the alternatives and 

the manner in which each alternative responds to Key Issues. Concerns of particular relevance 

to this decision are:

to what extent each alternative responds to applications for special use permits in a manner 

that provides stability to outfitter-guide businesses to allow financial commitments 

necessary to continue to provide public service;

the extent to which each alternative the meets the minimum extent necessary for 

commercial services in Wilderness, to provide for wilderness appropriate activities, and 

protect wilderness character while providing pack and saddle stock outfitter-guide 

commercial services in the Pasayten and Lake Chelan-Sawtooth Wilderness Areas,

the extent to which each alternative designates an amount of campsite barren core in 

wilderness used by the pack and saddle stock outfitter-guides that is compatible with party 

size, and
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Okanogan-Wenatchee National Forest

the effects of each alternative on the environment, particularly those aspects of the 

environment identified as Key Issues.

Public Involvement

In the late 1990s, the Methow Valley Ranger District started receiving comments and concerns 

from a few individuals and groups about pack and saddle stock outfitter-guide activities in the 

Pasayten Wilderness. Field observations from some people indicated that recreation activities 

in general, and outfitter-guide activities in particular, did not meet Forest Plan standards and 

guidelines. In response to the concerns, the District developed a “Wilderness Recreation, Stock, 

and Outfitter Use Strategy and Action Plan”, signed by the Forest Supervisor on April 24, 2000

(USDA Forest Service 2000e). This plan, and subsequent accomplishment reports and action 

plans were mailed to everyone who expressed concern or interest in the topic, inviting further 

comments on the situation.

A scoping letter requesting comments on the proposed action to issue pack and saddle stock 

outfitter-guide special use permits was mailed to persons and organizations on the District 

mailing list on November 15, 2000. The proposed action included a non-significant amendment 

to standard and guideline MA15B-22B to allow outfitter campsites in wilderness to exceed 400 

square feet of vegetation loss. A total of 110 letters were received in response to the 

Wilderness Action Plan and the scoping letter.

Following publication of a notice of intent to file an environmental impact statement in the 

Federal Register on June 22, 2005, an updated scoping letter was mailed on June 23, 2005 to 

those who provided input on the Wilderness Action Plan or responded to the November 15, 

2000 scoping letter, in addition to those on the Tonasket, Chelan, and Methow Valley Ranger 

District mailing lists. The proposal had changed to increase the number of service days, and to 

eliminate the Forest Plan amendment. Eleven letters were received in response to the scoping 

letter and Notice of Intent.

The proposed action was refined to the current version after publishing of the Forest Service 

Handbook 2709.11, with gave specific direction on calculating service days, and upon further 

analysis of compliance with forest plan standards and guidelines. The Forest Service determined 

that an amendment would be needed to implement the proposed action. An updated Notice of 

Intent was published in the Federal Register on July 21, 2010, correcting the estimated 

publication date and number of service days, and including specifics about the proposed forest 

plan amendment. A letter was also sent on July 30, 2010 to those on the project mailing list 

updating the DEIS release date, and explaining the proposed forest plan amendment.

The Issue Tracking Form in the analysis file summarizes and responds to each comment. All 

letters are included in the Responses to Scoping folder in the analysis file.

Government-to-government letters were mailed to the Yakama Indian Nation and the 

Confederated Tribes of the Colville Reservation in June, 2005, requesting consultation on the 

proposal. Neither tribe identified concerns about the proposal.
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Issues

Issues are points of concern about environmental effects that may occur as a result of 

implementing the proposed action. Issues provide focus for the analysis of environmental 

effects and influence alternative development, including development of mitigation measures.

Key Issues (also known as significant issues) are used to formulate alternatives to the proposed 

action, prescribe mitigation measures, and analyze environmental effects. They are used to 

compare the alternatives in the Comparison of Alternatives Table in Chapter 2. Key Issues are 

referred to by the Council on Environmental Quality (CEQ) as significant because of the potential 

extent of their geographic distribution, duration of their effects, or intensity of interest or 

resource conflict, if not mitigated or otherwise addressed. Key Issues were identified by the 

Interdisciplinary (ID) Team and approved by the Responsible Official.

In addition to “Key Issues,” “other” issues were raised. They were considered as this project was 

developed, analyzed and may have generated mitigation measures. However, they are less 

focused on the elements of the Purpose and Need and did not influence formulation of 

alternatives. They are addressed in the effects analysis (Chapter 3).

Finally some issues were; 1) outside the scope of the proposed action, 2) already decided by law 

or regulation, Forest Plan, or other higher level decision, 3) irrelevant to the decision to be 

made, or 4) conjectural and not supported by scientific or factual evidence. The Council on 

Environmental Quality NEPA regulations require identification and elimination from detailed 

study the issues which are not significant or which have been covered by prior environmental 

review (Sec. 1506.3). A summary of all public issues and their disposition is available in the 

project analysis file.

KEY ISSUES

Key Issue 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.

Some respondents considered conditions in the Pasayten and Lake Chelan-Sawtooth Wilderness 

Areas to be out of compliance with Forest Plan standards and guidelines and the Wilderness Act. 

Some felt that problems were created by the amount of pack and saddle stock outfitter-guide 

activity. Some were concerned about the number of hiker encounters with pack strings. Others 

commented on the size of the areas of vegetation loss and bare compacted soil, number of trees 

with exposed roots in campsites, number of trees damaged by recreation activities, and other 

standards and guidelines. Some comments described conflict between different user groups, 

and between outfitted and non-outfitted groups. Some expressed concern about wilderness 

degradation.
Pack and Saddle Stock Outfitter-Guide Permit Draft EIS 1-23 August 2010

Okanogan-Wenatchee National Forest

The effects are measured by:

qualitative discussion about 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 discussions about the standards and guidelines, focusing on those not being met, 

and the effect the proposed Forest Plan amendment will have on wilderness character. 

These effects were analyzed, and are disclosed in the Wilderness section of Chapter 3.

Key Issue 2: Current and proposed pack and saddle stock outfitted use could degrade 

wetlands and habitat for native plant species when pack and saddle stock trample wetland 

and riparian vegetation and graze in wetlands and other areas.

People expressed concern about the effect pack and saddle stock outfitter-guides are having on 

plants; that the current number of service days was leading to damaged wetlands. People were

concerned that stock grazing was leading to changes in plant communities and loss of vegetative 

cover in wetlands and other areas. Some expressed concern about the effects of livestock 

manure and urine on plant species; these people generally felt that the proposed number of 

service days was too high.

The effects are measured by:

estimated number of acres of wetland within 500 feet of pack and saddle stock camps;

qualitative discussion about the effects of activities on the wetlands;

effects determination statements for threatened, endangered, and sensitive plant species;

qualitative discussion of the effects of grazing on plant composition.

These effects were analyzed, and are disclosed in the Botany section of Chapter 3.

Key Issue 3: Current and proposed pack and saddle stock outfitted use could degrade some 

habitat for threatened, endangered, or sensitive wildlife species through increased encounters 

between people and animals, or through habitat degradation.

Comments expressed concern over the outfitter-guide effects on wildlife, specifically 

threatened, endangered, or sensitive species. These people generally felt that the proposed

number of service days was too high.

The effects are measured by:

effects determination statements for threatened and endangered wildlife species;

The effects are disclosed in the Wildlife section of Chapter 3. A biological assessment (BA) was

completed for the analysis; the US Fish and Wildlife Service (USFWS) concurred with the 

findings.

Key Issue 4: Current and proposed pack and saddle stock outfitted use could degrade water 

quality and aquatic resources when pack and saddle stock cross streams on trails, or access 

water sources and damage riparian vegetation, break down stream banks, and degrade water 

quality.
Pack and Saddle Stock Outfitter-Guide Permit Draft EIS 1-24 August 2010

Okanogan-Wenatchee National Forest

Concern was expressed about the effects of outfitter-guide activities, specifically impacts from 

stock on water quality and aquatic resources. It was suggested that the number of service days 

be reduced to reduce the impact.

The effects on water quality and riparian habitat are measured by: 

effects determination statements from Biological Assessment for threatened and 

endangered fish species;

qualitative discussion of compliance with Northwest Forest Plan Aquatic Conservation 

Strategy (ACS) and PACFISH Riparian Management (RMO) Objectives;

qualitative discussion on compliance with state water quality standards and the Clean Water 

Act;

effects of open grazing on riparian areas, streams, and lakes,

qualitative discussion about stream sedimentation;

qualitative discussion of stream flow

qualitative discussion of sediment from trails

qualitative discussion of fecal coliform levels.

The effects were analyzed, and are disclosed in the Hydrology and Aquatics sections of Chapter 

3.

OTHER ISSUES

In addition to resources associated with the Key Issues, the public identified other concerns 

about the effects of the proposed action on a variety of other resources. These concerns were 

addressed through mitigation measures and were not used in alternative formulation. The 

effects on them are described in Chapter 3 of this document. The issues include:

Pack and saddle stock outfitter-guides could introduce noxious weeds into currently weedfree areas, such as wilderness, in stock manure.

Pack and saddle stock outfitter-guides could degrade air quality with smoke from campfires.

Firewood gathering by outfitter-guides could degrade the environment by removing down 

woody debris and limiting or eliminating this habitat component.

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.

Pack and saddle stock outfitter-guides could degrade the experience of other recreation 

users outside of wilderness by perpetuating conflicts between outfitted and non-outfitted 

user groups, increasing the number of people recreating in any given area, and adding to 

conflicts between user groups.

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.

Pack and saddle stock outfitter-guide grazing could exceed Forest Plan standards and 

guidelines pertaining to forage utilization when stock are allowed to graze unconfined 

around campsites.
Pack and Saddle Stock Outfitter-Guide Permit Draft EIS 1-25 August 2010

Okanogan-Wenatchee National Forest

ELIMINATED ISSUES

The following comments and issues were raised during scoping, but are eliminated because they 

were; 1) outside the scope of the proposed action, 2) already decided by law or regulation, 

Forest Plan, or other higher level decision, 3) irrelevant to the decision to be made, or 4) 

conjectural and not supported by scientific or factual evidence. The justification for this 

determination is included. 

1. Outfitter-guides should be required to pay fees adequate to cover costs of monitoring 

and trail maintenance. This has been determined by a higher level decision. 

2. Snowmobile tracks have been seen in the wilderness. This issue is outside the scope 

since this proposed action does not include winter-time outfitter-guide activities, such as 

snowmobiles.

3. There is a trend to use trail fees to make access easier for everyone. The use of 

Recreation Enhancement Act funds (“Trail fees”) is irrelevant to the decision of this 

analysis. Determining the use of fees, and the accessibility of sites is not part of the 

purpose and need.

4. For greater protection of wolves, grizzly, wolverine, fisher and lynx, the Forest Service 

needs greater buffers around the wilderness. This issue is irrelevant to this decision, 

and not supported by scientific or factual evidence. Refer to wildlife analysis in this 

document.

5. End road building, increase road obliteration, and stop resource extraction, especially 

old growth. This issue is irrelevant to the decision since the proposed action and 

purpose and need to not include any changes to the road network or resource extraction.

6. All existing regulations should be enforced for all users, e.g. protecting trees from 

stock and woodcutting, protecting lakeshores, riparian areas. The portion of this issue 

pertaining to non-outfitted people is outside the scope since the purposed action

pertains to pack and saddle stock outfitter-guide permits. The effects of pack and saddle 

stock outfitter-guides on trees, lakeshores, and riparian areas are included in Chapter 3.

7. Hannegan Pass has experienced significant bear problems because of careless food 

storage. Immediate requirements for proper storage should be implemented. 

Hannegan Pass is not within the analysis area, so this issue is irrelevant to the decision.

8. Set up a permit system to track usage of area and monitor impacts. This issue is 

outside the scope because the purposed action does not include establishing a permit 

system for non-outfitted recreationists.

9. We need an EA or EIS on all recreational use. This issue is outside the scope of the 

proposed action, which specifically addresses pack and saddle stock outfitter-guides. 

Other recreational use in considered in the cumulative effects analysis.
Pack and Saddle Stock Outfitter-Guide Permit Draft EIS 1-26 August 2010

Okanogan-Wenatchee National Forest

10. The total number of people and stock should be limited. This issue is outside the scope 

of the proposed action because non-outfitted recreationists are not part of the purpose 

and need for action.

11. Eliminate sheep grazing. This issue is irrelevant to the decision because sheep grazing is 

not part of the purpose and need.

12. The Forest Service is considering banning horses and outfitters from the Pasayten. 

This issue is conjectural and not supported by factual evidence because it is not accurate. 

Alternative 1, the No-Action alternative, examines the effects of not issuing pack and 

saddle stock outfitter-guide permits.

13. The Forest Service is eroding public liberties in the Pasayten Wilderness. This is 

irrelevant to the decision because the treatment of the public by the Forest Service is not 

part of the purpose and need.

14. We request that you develop a long-term monitoring plan for condition of resources. 

Monitoring trail use, campsite use, and other recreation factors would be useful. This 

is outside the scope of the proposed action. Wilderness monitoring is an ongoing 

activity. Monitoring of pack and saddle stock outfitter-guide activities is included in the 

alternatives, and in the monitoring plan in this document.

15. Make certain areas such as fragile meadows, lakes, and riparian areas are off limits to 

horsepackers. This issue is outside the scope of the proposed action because any 

limitations on non-outfitted pack and saddle stock users is not part of the purpose and 

need. The effects of pack and saddle stock outfitter-guides on these resources in 

included in the specialist reports, and in this document.

16. Private users with stock are causing serious impacts also, and an EA should be none on 

that, too. This is outside the scope of the proposed action, which only include pack and

saddle stock outfitter-guides, not private users.

17. I am very much opposed to closing horse camping around Remmel Lake and in the 

meadow about Middle Oval Lake. This issue is conjectural and not supported by factual 

evidence because it is not accurate – it is not part of the proposed action.

18. Three immediate threats to this important habitat: use by commercial backpack 

groups like Outward Bound, the Pacific Northwest Trail designation, and increased 

recreational use of the Boundary Trail from Castle Pass to Ross Lake. Non-outfitted 

recreation and commercial backpacking groups are outside the scope of the purposed 

action. The effects of their activities are included in the cumulative effects analysis.

19. Designating the Pacific Northwest Trail would degrade habitat. Designation of the 

Pacific Northwest Trail is irrelevant to the decision because it is not part of the purpose 

and need.

20. Propose protecting key habitat from extensive recreational use other than that of 

commercial use. The activities of non-outfitted users are outside the scope of the 
Pack and Saddle Stock Outfitter-Guide Permit Draft EIS 1-27 August 2010

Okanogan-Wenatchee National Forest

purposed action. The overall effects of recreation use are included in the cumulative 

effects analysis.

21. The issues to address in a Conservation Assessment for Spanish Camp should include 

habitat in addition to occurrence, distribution and status of TES species. The proposed 

action does not include completing a Conservation Assessment for Spanish Camp, so this 

comment is outside the scope. 

22. The Chinook Pass Wilderness has been impacted by pack and saddle stock. This issue 

is irrelevant to the decision because the Chinook Pass Wilderness is not within the 

analysis area.

23. The distance people should be allowed to penetrate the wilderness should be limited 

to a maximum of 20 miles from any designated trailhead. This issue is irrelevant to the 

decision because the purpose and need does not include changing the activities of nonoutfitted recreationists.

24. Protect trails from overuse by stock and ensure trails are better maintained. Trail 

maintenance is irrelevant to the decision because it is not within the purpose and need.

25. Consider ways to limit use when necessary, perhaps with extended seasonal closures. 

There are no existing seasonal closures in wilderness. Proposal for new closures is

outside the scope of the proposed action and purpose and need.

26. Outward Bound is causing resource damage, in addition to other concerns. This issue 

is irrelevant to the decision because Outward Bound is not a pack and saddle stock 

outfitter-guide.

27. One or more of the current permittees have attempted, through litigation, to restrict 

certain members of the public access to areas in the Pasayten. This is a violation of 

their special use permits. This issue is a legal matter, and irrelevant to the decision. A 

restraining order was granted by an Okanogan Country judge.

28. I do hope the Forest Service will call more attention to the budgetary needs for 

accomplishing protection goals. Forest Service budget levels are irrelevant to the 

decision, and determined by a higher level decision. 

29. No guided trips for killing wildlife should ever be permitted in this area. The following 

should be banned in this area: hunting, trapping, new roads, all two stoke vehicles, 

grazing, mining, logging, drilling, and prescribed burning. These issues are irrelevant to 

the decision. Hunting regulations are determined by Washington State Department of 

Fish and Wildlife. All other activities are not associated with pack and saddle stock 

outfitter-guides.
Pack and Saddle Stock Outfitter-Guide Permit Draft EIS 1-28 August 2010

Okanogan-Wenatchee National Forest

30. I suggest that you start managing your wildernesses by establishing use capacities and 

issuing permits to the number of recreationists that fall within those capacities. A 

capacity analysis that results in a specific numerical capacity for the wilderness is outside 

the scope of the purpose and need and proposed action, as is any type of limitation on 

the number of non-outfitted users.