United States

Department of

Agriculture

Forest Service

Pacific

Northwest

Region

Okanogan-Wenatchee 

National Forest

Methow Valley, Chelan, and 

Tonasket Ranger Districts

Chelan, Okanogan, 

Whatcom, and Skagit 

Counties, Washington

March 2013

Pack and Saddle Stock

Outfitter-Guide Special

Use Permit Issuance

Record of Decision
The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs 

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political beliefs, sexual orientation, or marital or family status. (Not all prohibited bases 

apply to all programs.) Persons with disabilities who require alternative means for 

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contact USDA's TARGET Center at (202) 720-2600 (voice and TDD). To file a complaint of 

discrimination, write USDA, Director, Office of Civil Rights, Room 326-W, Whitten 

Building, 14th and Independence Avenue, SW, Washington, DC 20250-9410 or call (202) 

720-5964 (voice and TDD). USDA is an equal opportunity provider and employer.
Pack and Saddle Stock Outfitter-Guide Permit ROD 1 March 2013

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RECORD OF DECISION

Pack and Saddle Stock Outfitter-Guide Special Use Permit Issuance

Okanogan National Forest Plan Amendment #47

Wenatchee National Forest Plan Amendment #28

United Sates Department of Agriculture, Forest Service

Okanogan-Wenatchee National Forest

Chelan, Okanogan, Skagit, and Whatcom Counties, Washington

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 others operated under short-term 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. All the current businesses have applied 

for 10-year special use permits and the Forest Service has determined there is a need for the outfittingguiding. 

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 outfitterguide 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, Sawtooth Backcountry, the 

Bear/Ramsey/Volstead area, Alta Lake, and some National Forest System land adjacent to these areas. 

This Record of Decision documents my decision for the Pack and Saddle Stock Outfitter-Guide Special 

Use Permit Issuance and approval of Okanogan National Forest Plan Amendment #47 and Wenatchee 

National Forest Plan Amendment #28.

DECISION AND RATIONALE

Decision

Based on the analysis presented in the final Environmental Impact Statement for the Pack and Saddle 

Stock Outfitter-Guide Special Use Permit Issuance, which is hereby incorporated by reference, I am 

selecting Alternative 4. Alternative 4 will issue 10-year term special use permits for pack and saddle 

stock outfitter-guides on the Methow, Chelan, and Tonasket Ranger Districts with a maximum of 6,700 

service days. Permits will be issued to Cascade Corrals, Cascade Wilderness Outfitters, Deli Llama 

Wilderness Adventures, Early Winters Outfitting, North Cascade Outfitters, North Cascade Safaris, and 

Sawtooth Outfitters. Additional permits may be issued to other acceptable pack and saddle stock 

businesses if any of these businesses cease operation, or have permits revoked, as long as the maximum 
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annual service days are not exceeded. The outfitters would have a total of 390 animal unit months for 

authorized grazing.

The service days will 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 1 shows the distribution in the different areas. When the 10-year 

permits are issued, the number of service days allocated to each outfitter will be determined by adding 

the highest actual use in the past 5 years, plus 25%, following Forest Service Handbook direction. Any 

unallocated service days will be held in a 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 will be 

adjusted at the 5-year mark in the 10-year permits using the same technique, without exceeding 6,700.

Figure 1. 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

The above service days include day rides in the North Cascades and Alta Lake areas for 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 National Forest 

System (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 will be assigned to specific

horse and mule packers to allow closer monitoring. Camp management plans will be required for each 

assigned site. All the sites are in the Pasayten Wilderness, and already exist at Bald Mountain, Sheep 

Mountain, and Beaver Creek, Crow Lake, and Whistler. Assigned sites will be used for full-service trips. 

Outfitters will 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 will be removed from the camp at the end of 

the season, and will not be cached over the winter. Camp locations for all other trips will be limited to 

existing pre-approved locations (refer to Appendix A in the FEIS for the authorized campsites). Creation 

of new camps will not be permitted without appropriate subsequent environmental analysis. Camping 

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

occupied.

I am approving base camps outside of Wilderness at the existing locations of Andrews Creek, Billygoat, 

Crater Creek, and Slate Creek trailheads on the Methow Valley Ranger District, and at the Fish Creek 

Camp on the Chelan Ranger District. Each location will have corrals, livestock watering troughs, and 

other improvements necessary to protect resources. These base camps will provide places where 
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outfitter-guides can keep pack and saddle stock during times of high use, and as starting locations where 

clients meet outfitters.

My decision also includes site-specific, non-significant amendments to two standards and guidelines in 

the Okanogan National Forest Land and Resource Management Plan (campsite location and vegetation 

loss at campsites) and one in the Wenatchee National Forest Land and Resource Management Plan 

(vegetation loss and bare, compacted mineral soil).

A non-significant amendment will make standards for outfitter-guide campsites 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 will make outfitter-guide campsites compatible with the 

‘limits of acceptable change’ indicators (Table IV-15, page IV-77). The amendment will only apply to 

pack and saddle stock outfitter-guides in the Pasayten and Lake Chelan-Sawtooth Wilderness Areas. The 

Okanogan Forest Plan will be amended by adding the following to standard and guideline MA15B-22B 

and the Wenatchee Forest Plan will 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 (MA15B22B) in campsites in the Pasayten Wilderness and the portion of the Lake Chelan-Sawtooth Wilderness 

on the Methow Valley Ranger District. The Wenatchee Forest Plan allows areas of bare, compacted 

mineral soil and vegetation loss of up to 1,000 square feet (Table IV-15, page IV-77) in campsites in the 

portion of the Lake Chelan-Sawtooth Wilderness on the Chelan Ranger District. It is physically 

impracticable to fit 12 people and 18 head of stock inside areas of 400 to 1,000 square feet of barren 

core (vegetation loss or bare, compacted mineral soil) in every campsite. Due to topography, vegetation 

type, historical use - including large party-sizes and livestock grazing, and the current party size of 12 

people and 18 head of stock, 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. 

The Preferred Alternative in the DEIS (Alternative 2) allowed use of up to 5,250 square feet of barren 

core in wilderness campsites (without creating additional barren core), based on the campsite 

calculations shown in Appendix C of the FEIS. The Forest Service measured the barren core in the 

wilderness camps used by the outfitter-guides, and found that six campsites have over 5,250 square feet 

of barren core (vegetation loss or bare, compacted soil) (FEIS pages 3-47 through 3-49). Although I am 

allowing the pack and saddle stock outfitter-guides to use all of the existing barren core in wilderness 

campsites, I want to closely monitor camps with more than the 5,250 square feet allowance in 

Alternative 2. I am requiring camp management plans to be developed for these 6 campsites. These 

plans will track barren core and ensure it is not increasing. Slight year-to-year fluctuations will be 

acceptable and expected as a result of annual vegetative growth and use patterns, or when camps are 

being restructured. Camp management plans will be developed by the end of the 2014 operating

season. However, the plans can only be developed when the outfitter-guide is occupying the camp, and 

not every camp is used annually. Those not completed by the end of 2014 will be done as soon as 

possible in the following operating seasons. This amendment will continue the overall trend of 

improving wilderness conditions, specifically related to campsite conditions.
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Another non-significant amendment to the Okanogan Forest Plan will 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. Outfitters will continue to use 

popular camps they are accustomed to using (FEIS page 3-19). The Wenatchee Forest Plan (USDA Forest 

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

following standard and guideline will be amended as follows: 

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.

My decision also includes many mitigation measures to avoid or minimize impacts to resources. These 

are covered in detail on pages 2-19 through 2-26 of the FEIS. The measures will avoid or minimize 

impacts to aquatic resources, native vegetation, soil, water, wilderness character, and terrestrial 

wildlife. The monitoring plan is included on pages 2-26 through 2-29, and includes monitoring outfitterguide operations, wilderness, pack and saddle stock grazing, and riparian areas. 

Rationale and Factors Other than Environmental Effects Considered in Making the Decision

I have chosen Alternative 4 because it best meets the Purpose and Need for the project (FEIS page 1-18)

evaluated with the Decision Factors listed on FEIS page 1-23. The components of the Purpose and Need 

and corresponding Decision Factors are displayed in the following figure.

Purpose and Need (FEIS page 1-18) Decision Factor (FEIS page 1-23)

Respond to special use permit applications Extent to which the alternative responds 

to applications in a manner that provides 

stability to outfitter-guide businesses

Protect wilderness character while 

providing necessary commercial services

Extent to which the alternative meets the 

minimum extent necessary for commercial 

services in Wilderness while protecting 

wilderness character

Reconcile inconsistencies between Forest 

Plan standards and guidelines

Extent to which the alternative designates 

an amount of campsite barren core that is 

compatible with party size

Effects of the alternative on the 

environment, particularly those aspects of 

the environment identified as Significant 

Issues.

Alternative 4 will respond to the permit applications by issuing 10-year outfitter-guide special use 

permits. It fully meets the Decision Factor associated with this part of the purpose and need because it 

will provide the greatest stability to the outfitter-guide businesses (FEIS page 2-16 and 3-19). The Forest 

Service Handbook guidance is to issue the highest number of service days actually used over the 

previous 5 years, increased by 25% to allow for growth. There was a substantial decline in actual use 

levels between the early 2000s, and those in 2006 through 2011. The reason for this decline is 

unknown, however may have been a result of wildfires, the downturn in the economy, decreased 
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demand, or other factors (FEIS page 3-24). For this alternative, I have decided to go beyond the 

previous 5 years and use the highest level of actual use over the past 10 years (plus 25%) to ensure the 

outfitter-guide businesses can expand to meet the demand if it rebounds to previous levels, thus 

increasing business stability (FEIS page 3-19). I will assign service days to the individual permits 

following the handbook direction (the highest amount of annual use by each permittee over the past 5 

years, plus 25%), and create a pool of days with the remaining service days. The outfitters will have the 

opportunity to request days from the pool if demand exceeds their allocation. The days will be returned 

to the pool at the end of each season (FEIS page 2-16). 

Alternative 4 will protect the wilderness character, and fully meet the Decision Factor by managing at 

providing the upper end of the range of the minimum extent of commercial service necessary. The 

analysis of the effects of Alternative 4 on wilderness character found that there will be no effect on the 

untrammeled or undeveloped qualities of the Pasayten or Lake Chelan-Sawtooth Wildernesses (FEIS 

page 3-64). The outfitter-guide activities will continue to have localized impacts to the natural quality, 

however the impacts will be minor because plant communities will not be altered (FEIS page 3-258). 

The activities will likely affect some R6 sensitive plant species by trampling, and a loss of some 

populations or individuals may occur where species are in close proximity to established camps and use 

patterns overlap. Sensitive plant populations are recovering from past livestock grazing, and the 

populations will continue to improve with Alternative 4. The mitigation measures will ensure species

viability is not compromised (FEIS pages 3-78 and 3-257). There will be isolated spots of damage to 

stream banks, but not at a level that will degrade aquatic habitat or water quality (FEIS page 3-78). 

Outfitter-guide activities will impact opportunities for solitude in and around campsites, and along trails 

because the sights and sounds of their activities and clients will detract from the remoteness of those 

localized areas (FEIS page 3-77). The Forest Plan amendments allowing the outfitters to use existing 

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

barren core at any campsite without increasing the barren core will prevent degradation of wilderness 

character by avoiding creation of new campsites and not increasing the current amount of barren core 

(FEIS page 3-77). 

The Needs Assessment and Minimum Extent Necessary Determination established a range of service 

days needed to meet the minimum amount of commercial services necessary to provide for recreation 

in wilderness (FEIS pages 3-25 and Appendix B-35). Alternative 4 will have enough service days to meet 

the upper end of the range in the Pasayten (2,170 service days) and Lake Chelan-Sawtooth (825), thus 

satisfying the need for additional services as a result of changes in demographics from an aging 

population (FEIS pages 3-2, Appendix B-39-41, and Appendix B-42). 

Alternative 4 will also reconcile the inconsistencies between Forest Plan standards and guidelines. Pack 

and saddle stock outfitter-guides will be allowed to use existing barren core in established campsites, 

and will not be allowed to increase the amount of barren core in any campsite. The amount of barren 

core will fluctuate every year based on a number of factors, including weather (influencing vegetation 

growth), use patterns, and accuracy and pattern of actual measurements (refer to FEIS pages 3-32, 3-45

and Glossary-3). There may also be temporary increases in the amount of barren core in any campsite if 

it is being restructured or if camps sections are being restored, but over time, no net increase in barren 

core will be allowed (FEIS page 2-20). 

Alternative 2 would have allowed the outfitters to use up to 5,250 square feet of barren core in any 

wilderness camp. After reviewing the calculations used to reach the 5,250 square feet (FEIS page 
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Appendix C-1), and considering comments received on the DEIS, I determined that this will not be 

adequate for a party with 12 people and 18 head of stock at all campsites. Therefore, Alternative 4 was 

developed to fully meet the Decision Factor of authorizing a campsite barren core size compatible with 

the party size. I have decided to require a Camp Management Plan on every campsite with over 5,250 

square feet of barren core, in addition to all assigned sites, however, to closely monitor these large 

camps. There are 6 campsites in the Pasayten Wilderness (none in the Lake Chelan-Sawtooth) with 

more than 5,250 square feet, and 2 assigned sites that are less than 5,250 square feet. 

Alternative 4 will also amend the Okanogan Forest Plan to allow the pack and saddle stock outfitterguides to use established campsites in the Pasayten Wilderness and the portion of the Lake ChelanSawtooth Wilderness on the Methow Valley Ranger District within 200 feet of meadows, lakes, streams, 

and key interest areas (FEIS page 2-18). The pack and saddle stock outfitter-guides use approximately 

99 campsites within the Pasayten and this portion of the Lake Chelan-Sawtooth. Of these, 86 fall within 

200 feet of these identified features. The remaining 13 campsites would not be an adequate number for 

their operations (FEIS page 1-20). Many of the 86 are in the most desirable locations, so allowing their 

use will allow the outfitters to continue offering the high quality camping experiences they have in the 

past. It will also avoid the possibility of new campsites being created in the future, under separate NEPA 

decisions, to compensate for what would be a lack of adequate sites (FEIS page 3-77).

The environmental effects of Alternative 4 are all acceptable, and very similar to the existing condition, 

and the projected effects of Alternative 2. Each issue, and how Alternative 4 addresses the issue are 

discussed in detail below. Impacts to resources have been adequately mitigated. The outfitter-guide 

operations will have minor, localized impacts to the natural quality of wilderness. The impacts will be 

minor because the dispersed, loose-grazing stock will not alter plant communities, and will only slightly 

increase impacts to sensitive or rare plant species. There will be isolated spots of damage to stream 

banks, but not at a level that will degrade aquatic habitat or water quality (FEIS pages 3-65, 3-66, and 3-

78). Opportunities for solitude or primitive and unconfined recreation, another quality of wilderness 

character, will be protected by managing campsites to keep the size and condition on a stable trend, 

avoiding creating additional barren core, or exposing roots on trees (FEIS pages 3-66 and 3-67). 

Campsite use limitations will limit pack and saddle stock outfitter-guide use in areas popular with nonoutfitted recreationists or in areas with limited graze or other resource concerns (FEIS pages 3-67 and 3-

68). Mitigation measures pertaining to campfires and firewood will protect standing snags, and not 

allow firewood to be stored at non-assigned sites, reducing impacts to visual quality (FEIS page 3-68). 

Requiring the outfitters and their clients to follow Leave-No-Trace principles will reduce the sights and 

sounds of outfitter-guide parties (FEIS page 3-68). Prohibiting new trail construction, and limiting 

maintenance to only National Forest System trails and campsite access trails unless prior approval is 

granted will avoid increases in trail density (FEIS page 3-69). Requiring proper disposal and management 

of human waste, stock manure, and hunting refuse will improve campsite conditions (FEIS page 3-69). 

Allowing oversized parties only when Forest Plan limitations are met will continue to minimize 

encounters, impacts from grazing stock, and impacts to campsites (FEIS pages 3-69, 3-98, and 3-101).

Impacts to soil would be reduced or avoided by using Camp Management Plans in assigned and large 

campsites to track barren core and ensure the amount is not increasing over time, prohibiting new 

campsites, prohibiting construction of new trails, encouraging loose grazing, properly placing stock 

containment facilities, prohibiting overnight picketing of stock in subalpine meadows, requiring efforts

to minimize trampling or damaging vegetation, requiring displaced soils to be replaced or smoothed out, 

and managing stock travel routes through wetlands (FEIS pages 3-161 and 3-162). 
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Best Management Practices that will protect water quality include mitigation measures to reduce the 

following: soil disturbance and compaction at campsites; the potential for decreased water quality as a 

result of erosion from trails; and sedimentation and fecal coliforms at trail crossings, watering spots, and 

campsites. Practices addressing vegetation and soil will reduce the risk of water quality degradation by 

minimizing damage to vegetation, wet soils, and meadows, and by restoring areas of soil damage. 

Practices addressing aquatic resources will help protect riparian areas, and reduce the risk of impacts to 

water quality by decreasing sedimentation, protecting streamside vegetation to maintain shade, and 

minimizing risks of contamination from hazardous materials (FEIS pages 3-176 and 3-177; ROD page 24

Errata Sheet). 

Aquatic resources will be protected by managing large campsites and avoiding the creation of additional 

barren core, restricting outfitter-guides to existing campsites and trails, minimizing damage to 

vegetation, wet soils and meadows to reduce overland flows, and protecting riparian areas to reduce 

impacts to water quality by decreasing sedimentation, protecting streamside vegetation to maintain 

shade, and minimizing risks of contamination from hazardous materials (FEIS 3-220 and 3-221, ROD 

page 24 Errata Sheet).

Impacts to botany resources, including sensitive species and native plant populations, will be avoided or 

minimized by managing large camps and reducing the amount of barren core, limiting outfitter-guide 

use to established campsites and trails, encouraging loose grazing, prohibiting the use of pickets

overnight in sub-alpine meadows, requiring outfitters to bring in weed free feed when it becomes 

necessary to restrict or limit the use of native forage, concentrating stock on a minimum number of 

trails through wetlands and preventing the spread and introduction of noxious weeds (FEIS pages 3-257

and 3-258). 

Impacts to wildlife will be mitigated by prohibiting new campsites and snag cutting (FEIS page 3-276), 

and protecting deciduous and riparian habitats by limiting use to existing trails, minimizing use of wet 

soil and meadow areas, and ensuring protection of riparian habitat (FEIS page 3-283). Prohibiting 

picketing of stock overnight in sub-alpine meadows and limiting outfitter-guide use to existing trails will 

be highly effective in limiting impacts to meadows by prohibiting additional trails in meadows, and 

allowing loose grazing stock to move freely to avoid over-grazing (FEIS page 3-289). Stock that loose 

graze tend to do so in a widely dispersed pattern and forage use is will distributed (FEIS page 3-14). 

Impacts to gray wolves will be avoided by prohibiting establishment of new camps or trails, so the 

potential for disturbance to den or rendezvous sites will be low. The possibility of species 

misidentification will be mitigated by requiring the outfitter-guides to make hunting clients aware of the 

consequences of shooting a wolf (FEIS page 3-296). Grizzly bears will be protected by requiring food and 

other attractants to be stored in bear resistant manners, prohibiting feeding of wildlife, reporting 

sighting of grizzly bears as soon as possible, and reporting negative encounters with bears. The 

possibility of species misidentification will be reduced by requiring outfitter-guide to make hunting 

clients aware of the consequences of shooting a grizzly bear (FEIS page 3-299). The possibility of 

shooting a lynx will be mitigated by requiring the outfitter-guide to educate hunting clients about the 

species, and consequences of shooting one (FEIS page 3-302). Great gray owl habitat will be protected 

by prohibiting snag cutting (FEIS page 3-310). 

Invasive species prevention measures are included to reduce the potential for spread (FEIS, page 3-332 

and 3-333). Over-utilization of forage will be prevented by loose grazing, requiring outfitters to carry 

supplemental feed if utilization standards are close to being exceeded, prohibiting picketed stock in subalpine meadows overnight, and limiting stock grazing during times of high use (FEIS page 3-353). There 
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will be no effects to cultural resources since there will be no new ground disturbance, and each permit 

will contain a resource protection clause (FEIS page 3-372). The alternative complies with Section 106 of 

the National Historic Preservation Act. It meets the conditions listed in Appendix B of the Programmatic 

Agreement and has been excluded from case-by-case review by SHPO (FEIS page 3-375). 

This alternative may affect but is not likely to adversely affect Federally listed threatened or endangered 

species nor will it cause a trend toward Federal listing of sensitive species as threatened or endangered 

(FEIS, pages 3-218, 3-219, 3-255, 3-296, 3-299, 3-302, 3-304, 3-307, 3-308, 3-309, 3-310, 3-311, 3-312, 3-

313, 3-314, 3-315, 3-316, 3-317, 3-318). 

In addition to the environmental factors listed above, Alternative 4 provides the potential for outfitterguides to expand their businesses (FEIS page 3-19), and increase the number of jobs created, thus 

increasing their potential to contribute economically to Okanogan County (FEIS page 3-366).

Other Alternatives Considered

Alternative 1, the no action alternative, would not have issued any pack and saddle outfitter-guide 

permits. I did not choose it because it did not meet the purpose and need of providing necessary pack 

and saddle stock outfitter-guide commercial services in wilderness (FEIS page 3-64) or elsewhere. It 

does respond to the permit applications, however the response would be to deny the applications, so it 

does not meet the Decision Criteria of providing stability to outfitter-guide businesses. Inconsistencies 

between standards and guidelines pertaining to pack and saddle stock outfitter-guide businesses would 

have been resolved by this alternative by not allowing the outfitters to operate. There would be no 

environmental effects from pack and saddle stock outfitter-guides with Alternative 1.

I did not choose Alternative 2, which would have issued 10-year permits to the current pack and saddle 

stock outfitter-guides or suitable replacements, with a total of 4,620 service days. It would have 

amended the Forest Plans to allow the use of up to 5,250 square feet of barren core in wilderness 

campsites exceeding that amount, but not allow additional barren core to be created. After additional 

analysis subsequent to the DEIS, I determined that 5,250 square feet would be inadequate for a party 

size of 12 people and 18 head of stock in every campsite due to differences in terrain, vegetation, 

natural barriers, and other factors. Restricting barren core to 5,250 square feet could lead to unsafe 

situations between stock and people (FEIS 3-17).

An amendment of the Forest Plan standard and guideline prohibiting camps within 200 feet of 

meadows, lakes, streams, and key interest areas was added to the version of Alternative 2 in the DEIS 

after these camps were brought to my attention in the comments responding that document. The 

amendment would have allowed the outfitters to use existing campsites within 200 feet of meadows, 

lakes, streams, and key interest areas (FEIS page 2-9 through 2-12). 

Alternative 2 would have fully met the purpose and need by issuing the permits in response to the 

permit applications, however the number of service days would not provide as much stability to the 

outfitter-guide businesses as Alternative 4, and would have limited their ability to make financial 

commitments (FEIS page 3-17). The number of service days for this alternative was the highest amount 

of actual use over the past 5 years, increased by 25%, as specified in the Forest Service Handbook (FEIS 

page 2-9). Wilderness character would have been protected, and the number of service days in 

Wilderness would have been within the range of the minimum extent necessary. If the need for such 
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services increased due to the aging population, this alternative would have fallen short of meeting the 

need (FEIS page 3-73). 

The environmental effects of this alternative would be acceptable, and very similar to the current 

condition.

Alternative 2 would have limited the authorized service days to the highest amount of actual use over 

the past 5 years, increased by 25%, as specified in the Forest Service Handbook (FEIS page 2-9), while 

Alternative 3 would issue the average amount of actual use, increased by 25%, falling short of handbook 

direction (FEIS page 2-12). 

I did not choose Alternative 3, which would have issued 10-year permits to the current pack and saddle 

stock outfitter-guides or suitable replacements, with a total of 2,660 service days. It would have 

amended the Forest Plans to allow the use of up to 2,800 square feet of barren core in wilderness 

campsites exceeding that amount, but not allow additional barren core to be created. An additional 

Forest Plan amendment would have reduced the pack and saddle stock outfitter-guide party size to 12 

(combination of people and stock) (FEIS page 2-12 through 2-15). The barren core allowance would 

have been adequate for the outfitter-guide camps because of the reduced party size. 

An amendment was added to the version of Alternative 3 in the DEIS that would have prohibited use of 

campsites within 200 feet of wet meadows, lakes, and streams. Approximately 46 campsites, including 

two currently assigned sites, would have been closed to pack and saddle stock outfitter-guides with this

amendment. This would have impacted the quality of camping the outfitters could offer their clients, 

since many of these 46 are the most popular and desirable campsites (FEIS page 3-18).

Although Alternative 3 would have met the purpose and need to respond to the permit applications by 

issuing 10-year permits, it would have a substantial impact on the viability of the outfitters due to the 

reduction of allowable service days (FEIS page 3-18). The 2,660 service days is the average of actual use 

over the past 5 years, increased by 25%. Using the average annual use instead of the highest actual use 

does not follow the guidance in the Forest Service Handbook. The Forest Plan amendment in 

Alternative 3 that would have reduced the party size for pack and saddle stock outfitter-guides to 12 

heartbeats which would also have a financial impact on the outfitters because it would have likely 

increased operation costs (FEIS page 3-18). 

Alternative 3 would not have authorized enough service days to be within the range of the minimum 

extent necessary for commercial services in Wilderness as determined by the 2012 Needs Assessment 

(FEIS pages 1-20 and 3-77). Opportunities for primitive and unconfined recreation would have been 

reduced for people requiring the services of an outfitter-guide. Pack and saddle stock wilderness 

recreation would have been available for approximately half of the people needing the services due to 

physical limitations, or lack or skill and equipment. The unserved half would not have the opportunity to 

experience the primitive and unconfined recreation offered in wilderness (FEIS page 3-77). 

IDENTIFICATION OF THE ENVIRONMENTALLY PREFERABLE ALTERNATIVE

The Council on Environmental Quality Regulations at 40 CFR 1505.2(b) require an agency to specify the 

alternative or alternatives that are considered to be environmentally preferable in the process of 

reaching its decision. The definition of environmentally preferable is the alternative that causes the 

least damage to the physical and biological environment, and which best protects, preserves, and 
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enhances historic, cultural, and natural resources. Alternative 1, no action, best meets this definition. 

No environmental impacts would occur under this alternative as a result of pack and saddle outfitterguide use because no pack and saddle stock outfitter-guides would be permitted to operate on National 

Forest System lands within the analysis area. 

Of the action alternatives, Alternative 3 is the environmentally preferable alternative because it would 

reduce the amount of pack and saddle stock outfitter-guide activity on National Forest System lands, 

and reduce the party size in wilderness to a total of 12 heartbeats. This would slightly reduce impacts to 

National Forest System lands and resources. 

Reasons for not choosing these alternatives are detailed above in the “Other Alternatives Considered” 

section.

PUBLIC INVOLVEMENT and CONSULTATION

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 that was developed 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 

Okanogan Forest Plan standard and guideline MA15B-22B and Wenatchee Forest Plan Table IV-15 on 

page IV-77 to allow outfitter campsites in wilderness to exceed the specified amount of barren core 

(referred to as “vegetation loss” in the Okanogan Forest Plan, and “vegetation loss and bare, compacted 

mineral soil” in the Wenatchee Forest Plan). 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 initial 

proposal identified in the November 15, 2000 scoping letter 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 after publication of the Forest Service Handbook 2709.11, which 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 amendments to enlarge barren core size. A letter was also sent 
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on July 30, 2010 to those on the project mailing list updating the DEIS release date, and explaining the 

proposed Forest Plan amendments.

A Notice of Availability for the DEIS was published in the Federal Register on September 17, 2010 

initiating the formal 45 day comment period. A letter was sent to 28 federal, state and local agencies; 3 

tribes; 28 organizations; 41 businesses; and 198 individuals to notify them of the availability of the DEIS 

and the start of the comment period. On October 20, 2010 the comment period was extended another 

20 days in response to a request received from a member of the public. A total of 259 comment letters 

were received. A number of comments were received stating that the barren core allowance in 

Alternative 2 (5,250 square feet) was too small, and that more service days were needed. Comments 

were also submitted stating the value and need for the pack and saddle stock outfitter-guides. Several 

other comments were received expressing concern about impacts to wetlands, native plants, wildlife 

habitat, wilderness character, water quality, and aquatic habitat, and questioning the need for the 

commercial service in wilderness. 

Given the length of the FEIS and the addition of Alternative 4, I intentionally released the FEIS 30 days 

before I signed the Record of Decision to give people extra time to review the information and analysis. 

No new substantive comments, concerns, or information were received during the 30 days. 

Consultation and Coordination

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, nor did they submit comments on the DEIS.

Consultation with the U.S. Fish and Wildlife Service (USFWS) and National Marine Fisheries Service 

(NMFS) was initiated in August 2011. Subsequent clarification was sent to both agencies. The USFWS 

concurred with the determinations of may affect, not likely to adversely affect bull trout and its critical 

habitat, gray wolf, grizzly bear, lynx and the northern spotted owl, and no-effect for designated critical 

habitat for Canada lynx and northern spotted owl in a letter dated January 28, 2013. NMFS concurred 

with the determinations of may affect, not likely to adversely affect for bull trout, steelhead, and spring 

Chinook, and critical habitats in a letter dated November 13, 2012. 

Issues

Issues were identified during the public scoping process that raised concerns about the proposed action. 

The Significant Issues were used to develop alternatives or additional mitigation and monitoring not 

included in the proposed action. Other issues were also raised. These were considered as the project 

was developed and analyzed. However they are less focused on the elements of the Purpose and Need 

and did not influence formulation of alternatives. Each issue is listed below, followed with a description 

of how Alternative 4 will respond to the issue.

Significant Issues

Significant 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.
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A Forest Plan amendment will allow the outfitters to use existing barren core in established 

campsites, but prohibit creation of additional barren core. All established camps with more than 

5,250 square feet of barren core, in addition to all outfitter-guide assigned sites, will have camp 

management plans to ensure protection of resources. Another amendment will allow use of 

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

on the Okanogan portion of the National Forest to allow the outfitters to continue to use the 

camps they are accustomed to using, rather than seeking out other existing camps locations 

away from these features (FEIS pages 2-17, 2-18 and 3-19). Mitigation measures will insure that 

outfitter-guides do not further degrade the condition of the wilderness (FEIS pages 3-65 through 

3-69). See decision rationale above.

Outfitter-guides activities will comply with the amended standards and guidelines. The forest 

plan amendment concerning barren core will result in no degradation to the opportunities for 

solitude from the current minor, localized impacts. The amendment allowing outfitter-guides to 

use existing campsites within 200 feet of meadows, streams, lakes and key interest areas will 

maintain the current impacts to opportunities for solitude since only existing campsites will be 

used (FEIS page 3-78). 

The outfitter-guide activities will comply with all other standards and guidelines. There will be a 

20% increase in authorized allowable service days in the Pasayten Wilderness compared to 

current levels, however overall use (outfitted and non-outfitted) will only increase approximately 

2%. The number of authorized allowable service days in the Lake Chelan-Sawtooth will increase 

6% over current levels, and result in virtually no increase in overall use levels compared to 

current numbers. The untrammeled and undeveloped qualities of wilderness will be unaffected

since they are influenced by intentional manipulation of wilderness ecosystems, or use of 

motorized or mechanical equipment or transportation methods (FEIS page 3-64). The natural 

quality of the Pasayten and Lake Chelan-Sawtooth wilderness areas will continue to receive 

minor, localized impacts (FEIS page 3-78). 

There will be a small increase in the total number of people using pack and saddle stock in 

wilderness under Alternative 4 compared to the current condition, so any changes to the 

opportunities for solitude will likely be unnoticeable. People will continue to encounter pack and 

saddle stock outfitter-guides in the places the outfitters frequent. Campsite occupancy will 

increase slightly, but not enough to make finding established campsites difficult for non-outfitted 

recreationists (FEIS page 3-78). 

The barren core and campsite location amendments will result in no degradation to the 

opportunities for solitude, from the current minor, localized impacts. The outfitter-guides will 

use existing barren core in established campsites, and not be permitted to create new barren 

core or travel routes, or expose roots on trees (FEIS page 3-78). 

Significant 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.

Current pack and saddle stock outfitter-guide activities are impacting approximately 86 acres of 

wetlands, based on proximity of campsites to wetlands (FEIS page 3-242). These impacts will 

continue, but 99% of the wetland habitat will remain in good ecological condition since there will 
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be no potential impact from outfitter-guide camps (FEIS page 3-266). The outfitter-guides will 

continue to use a combination of loose grazing and stock containment. Loose grazing stock have 

less of a tendency to overgraze an area because they graze in a dispersed pattern, and don’t 

travel over the same ground repeatedly. They may travel through wetland habitats as they

access upland grazing areas, but do not tend to linger in wetlands because they avoid wet soil, 

and their preferred graze grows in drier, upland habitat (FEIS page 3-239 and 3-348 to 3-349). 

Alternative 4 will continue to maintain high quality aquatic and riparian conditions at the reach, 

6

th and 5th field watershed scales. There are approximately 21 campsites within riparian reserves 

scattered across the analysis area. Loose grazing will be encouraged to minimize impacts to 

riparian areas. Loose grazing stock tend to move rapidly to and from water sources with very 

little feeding or loafing activities near drinking water (FEIS page 3-211 and 3-230). Stock 

containment areas within camps will be designed to minimize off-site effects (FEIS page 2-23 and 

3-230). 

The effects of outfitter-guide activities on riparian areas will be immeasurable because there will 

be no increase in barren core, and no new trails or campsites (FEIS page 3-217). The outfitterguide activities will be consistent with PACFISH because they will be unlikely to hinder the 

attainment of the RMOs, not affect pool frequency since sediment inputs from bank trampling 

will be marginal, not change large woody debris levels, and not affect water temperature since 

stream shading will essentially not be reduced (FEIS page 3-227). The outfitter-guide activities 

will also be consistent with the Northwest Forest Plan’s Aquatic Conservation Strategy 

Objectives. Some localized impacts will occur across the analysis area, however, the outfitterguide activities will have negligible effects at the site scale and virtually no effect at the reach, 

sub-watershed, or watershed scales (FEIS page 3-234). 

The pack and saddle stock outfitter-guide activities will not cause unacceptable impacts to 

habitat for native plant species. Stock grazing in and around campsites will not result in 

landscape modifications of natural plant succession due to the limited amount of area where the 

animals graze and the small number of animals compared to past use, and other current use by 

the public (FEIS page 3-258). 

There would be “no effect” on any listed plant species (FEIS page 3-257). Alternative 4 will not 

contribute to a downward trend of Federally Listed Threatened or Endangered, R6 Special Status 

or Survey and Manage species across the analysis area (FEIS page 3-270). 

Significant 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.

The biological assessment for these species reached the following determinations: “may affect, 

not likely to adversely affect” gray wolf (FEIS page 3-296), grizzly bear (FEIS page 3-299), lynx

(FEIS page 3-302), and northern spotted owl (FEIS page 3-305); “no effect” on all other 

threatened or endangered wildlife species and designated critical habitat for Canada lynx and 

northern spotted owl (FEIS pages 3-303, 3-304 and 3-306); “may impact individuals, but not 

likely to cause a trend toward Federal listing or a loss of population viability” on great gray owl

(FEIS page 3-310); and “no impact” on all other sensitive wildlife species (FEIS pages 3-307 

through 3-309, 3-311 through 3-318).
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Significant 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.

This alternative will have minor, localized impacts to aquatic resources and water quality. There 

may be a slight increase in stream sedimentation at some stream crossings or watering areas 

and campsites, but the sedimentation contribution from the damaged sections of stream banks 

will not be detectable compared to background in-stream bank erosion (FEIS page 3-176 and 3-

228). Minor impacts to riparian vegetation will occur when pack stock access water to drink and 

at stream crossings. Impacts to riparian vegetation will be limited to areas near camps, day use 

areas, and along trails at stream crossings (FEIS pages 3-233 and 3-350).

There will be very little to no reduction in water quality in the vicinity of the camps. Nearly all 

surface erosion from the barren core within camps will be captured by ground vegetation before 

it reaches waterways (FEIS page 3-164). Stream bank erosion at trail crossings and watering 

spots, and increases in turbidity from stock fording streams or rivers will not be detectable 

compared to ongoing channel and hill slope erosion, except at the point of disturbance in the 

stream channel during the time of traffic crossing in water. Stream turbidity is not expected to 

change because the suspended sediment will not change by measureable levels (FEIS page 3-

176). 

Fecal contamination may occur in areas where pack stock cross streams and water, adding to 

the background level from wildlife and non-outfitted pack stock. This may cause increased 

nutrient levels at the site scale. Any increases will only occur on a limited basis compared to the 

analysis area as a whole due to the fact that the outfitter-guide campsites, trail crossings, and 

stock watering sites are isolated and infrequent across the landscape. Fecal coliform in streams 

will be quickly diluted, keeping levels well below the state water quality standard (FEIS page 3-

174). 

This alternative will comply with the Clean Water Act, and the Aquatic Conservation Strategy 

Objectives and Riparian Management Objectives. There will be no new created openings in 

riparian areas, and no measurable reduction in stream shading. Water temperature in any 

stream in the analysis area will not be raised as a result of pack and saddle stock outfitter-guide 

activities. Therefore, water temperature within the analysis area or further downstream in 

303(d) listed segments will not change (FEIS page 3-176). Refer to the discussion under 

Significant Issue #2 above for details of compliance with the Aquatic Conservation Strategy 

Objectives and Riparian Management Objectives.

Alternative 4 “may affect, but is not likely to adversely affect” bull trout, steelhead, and spring 

Chinook, and the critical habitat for each species. There will be no effect on all other listed fish 

species, and individual sensitive fish species may be impacted, but Alternative 4 will not likely 

cause a trend toward Federal listing or a loss of population viability (FEIS pages 3-219 through 3-

220).

Significant Issue #5. The 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 
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not allow the businesses to respond to increases in demand for pack and saddle stock outfitterguide services. 

This issue was added to the FEIS in response to comments received on the DEIS. Alternative 4 

was added to the FEIS to address this issue. It will increase available service days to 6,700, which

will give the outfitters the opportunity to meet the demand for their services if that demand 

rebounds to the level experienced in the early part of the last decade. According to the 

outfitters, the ability to increase the number of clients will likely allow them to cover increasing 

operating costs and remain viable businesses in the future (FEIS page 3-19).

The Forest Plan amendment concerning barren core will allow the outfitter-guides to use existing 

barren core in established campsites. The amount of barren core in each campsite is a result of 

topography, vegetation, past use (grazing and unlimited party sizes prior to Forest Plan 

implementation) and current recreation use. Monitoring has shown that larger, established 

camps are on an improving condition trend (FEIS pages 3-47 through 3-49). Allowing the 

outfitters to use the existing barren core in established campsites will give enough room for 12 

people and 18 head of stock in every camp that currently accommodates this party size without 

changing use patterns, or impacting the quality of the camping experience for clients. It will 

allow safe handling and confinement of stock, and comfortable, albeit primitive wilderness 

campsites that will fully meet the needs and expectations of their clients (FEIS page 3-19).

Other Issues

1. Pack and saddle stock outfitter-guides could introduce noxious weeds into currently weed-free 

areas, such as wilderness, in stock manure.

Outfitters and their clients will be required to prevent transport of any seeds by removing any 

plant material attached to vehicles, shoes, clothing or the bodies of pack and saddle stock. They 

will also be required to use only certified weed-free feed on all National Forest System Land. 

Outfitters will help identify and map newly established weed populations, aiding in early 

treatment. Outfitters will be required to assist in control measures as directed by the Forest 

Service (FEIS pages 3-332 and 3-333).

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

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

requiring cooking on stoves. Applying this limitation to pack and saddle stock outfitter-guides 

was eliminated because firewood gathering by outfitters, and outfitter campfires were not found 

to adversely affect air quality or the ecosystem (FEIS, page 2-3). 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 (FEIS page 3-376) 

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

woody debris and limiting or eliminating this habitat component.
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An alternative was considered but eliminated that would not allow campfire or firewood 

gathering in sub-alpine ecosystems (FEIS page 2-3). This alternative was eliminated because 

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

be adversely affecting resources (FEIS pages 3-274 through 3-276, 3-279, and 3-310). Firewood 

gathering is prohibited in areas where down woody debris is insufficient, and except where 

safety is an issue, no cutting of standing trees (live or dead) is allowed (FEIS, page 2-21). 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

(FEIS page 3-274).

4. 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.

The number of authorized service days would allow the existing businesses, or suitable 

replacements, to increase business to approximately 25% over levels from the highest levels 

experienced in the past 10 years. This alternative could lead to increased revenues if demand 

increases over current levels (FEIS page 3-19).

5. 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.

The amount of pack and saddle stock outfitter-guide activities will increase in areas outside 

wilderness which may change the recreation experience for others. There will be increases in the 

Alta Lake and North Cascades areas because of the increase in day rides (FEIS pages3-116 and 3-

149 . There is little non-outfitted use in the areas of day riding, however, so few people will be 

affected. The biggest potential for change and conflict will be in the Sawtooth Backcountry, 

where the amount of pack and saddle stock use service days will increase approximately 104% 

over current levels, however overall outfitted and non-outfitted use will only increase 3%. Nonoutfitted recreationists will have a noticeable increase in encounters with outfitted parties on 

trails and at destination locations compared to the current condition (FEIS page 3-124 and 3-

125).

6. 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.

Most existing detrimental soil damage occurred prior to implementation of the Forest Plans. Soil 

in and around campsites, at stock watering areas, and trail crossings would continue to be 

compacted and displaced by outfitted pack and saddle stock, but amount of area affected would 

be inconsequential (FEIS pages 3-157 through 3-158, and 3-163). Outfitter-guide activities would 

result in little, if any soil displacement. Nearly all displacement that will occur in camps, at stock 

watering areas, or along trails will be trapped by surrounding vegetation. Soil in stock 

containment areas in camps will be compacted and displaced, but there will be little erosion 

because these areas are relatively flat and surrounded by ground vegetation that will capture 

any eroding soil. Areas where stock loose graze will have virtually no soil impacts because of the 

dry soil and vegetative cover. Stock traveling through wet areas to reach grazing areas will 

impact and displace the soil within the trails, but these impacts will be too small and isolated to 
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change conditions on the ground, and will approximate natural processes. Outfitted stock will 

not further degrade stream banks at existing crossings since they will be restricted to existing 

campsites and trails (FEIS pages 3-164 and 3-165). 

7. 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.

Outfitter-guide stock forage utilization would be well within allowable use standards and 

consistent with all standards and guidelines (FEIS pages 3-335 and 3-336). Loose grazing will be 

the preferred method. Loose grazing stock disperse and their constant movement pattern results 

in no concentrated grazing areas. The outfitters will be required to carry supplemental feed if 

forage utilization or resource monitoring shows that utilization standards are close to being 

exceeded. Picketing stock in subalpine meadows will be prohibited, avoiding over-utilization of 

forage since stock will be able to roam free in the constant movement patterns that avoid overgrazing. Finally, outfitter-guide stock grazing will be limited to suitable areas during times of 

high use. This will ensure that the stock do not over-graze areas where there is a high number of 

non-outfitted stock, or in areas where forage conditions cannot support stock grazing (FEIS page 

3-353). 

8. Pack and saddle stock outfitter-guides are important to the local economy.

Pack and saddle stock outfitter-guides currently contribute approximately $1,293,940 annually 

to Okanogan Country, and provide 26.6 jobs (FEIS page 3-362). The increase in service days with 

Alternative 4 will increase the contribution to approximately $1,943,811, and increase the 

number of jobs to 40 (FEIS page 3-366) if demand increases to permitted levels.

FINDINGS REQUIRED BY OTHER LAWS

This project was prepared under and complies with the regulations for the National Environmental 

Policy Act. Standards and guidelines established in the amended Okanogan National Forest Land and 

Resource Management Plan, as applicable, and the amended Wenatchee National Forest Land and 

Resource Management Plan, as applicable, have been met, except where amended above as noted on 

pages 1-20, 2-17 and 2-18 off the FEIS. Both Forest Plans were prepared in accordance with the 

National Forest Management Act. 

Aquatic resource standards, including but not limited to Aquatic Conservation Strategy Objectives and 

Riparian Management Objectives will be met. The outfitter-guide activities will be consistent with 

PACFISH because they will not hinder the attainment of the RMOs in the long run, not affect pool 

frequency since sediment inputs from bank trampling will be marginal, not change large woody debris 

levels, and not affect water temperature since stream shading will not be affected (FEIS pages 3-225 

through 3-227, ROD page 24 Errata Sheet). The outfitter-guide activities will also be consistent with the 

Northwest Forest Plan’s Aquatic Conservation Strategy Objective. Some localized impacts will occur 

across the analysis area, however, the outfitter-guide activities will have negligible effects at the site 

scale and virtually no effect at the reach, sub-watershed, or watershed scales (FEIS pages 3-227 through 

3-234). 

Botany and vegetation standards, including but not limited to wetland habitat and natural plant

succession will be met. Outfitter-guide activities in and around campsites will not result in landscape 
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modification of natural plant succession due to the limited amount of area where the animals graze, the 

small number of animals compared to past use, and the other current use by the public. Alternative 4 

will be consistent with the amended standard and guideline pertaining to barren core (FEIS pages 3-258 

and 3-270). 

The project was prepared to be consistent with the requirements of the Pacific Northwest Invasive Plant 

Program Final Environmental Impact Statement, Record of Decision, 2005 (FEIS page 3-319). The 2005 

standards that apply to this project require an emphasis on prevention and the use of pelletized or 

certified weed free feed in wilderness and at wilderness trailheads (FEIS page 3-337). All Forest Plan 

standards and guidelines pertaining to noxious weeds will be met with the mitigation measures that will 

prevent noxious weed infestations from the pack and saddle stock outfitter-guide activities, to the 

extent practical, require use of certified weed-free feed, and require the outfitters to participate in a 

weed identification, mapping and treatment program (FEIS pages 3-337 and 3-338).

All standards and guidelines for forage utilization and range improvements will be met. The outfitters 

will be required to carry supplemental feed if utilization standards are close to being exceeded, and 

forage use in wilderness will conform to all wilderness standards. Outfitter-guide stock grazing will be 

prohibited in Whistler Basin and in the meadows at the Rainy Lake turnoff and in Management Area 10 

(FEIS pages 3-355 through 3-356). 

Regional soil quality standards, and Forest Plan standards and guidelines for soil resources will be met. 

The amount of soil compaction will be less than 0.1% of the total analysis area, and virtually no soil 

displacement or erosion will occur in campsites. Grazing practices will not trigger erosion because soil 

erosion from stock containment areas will be captured by surrounding ground vegetation. In addition, 

loose grazing will cause some soil trampling in travel routes through isolated wetlands leading to grazing 

areas, but impacts to soils will be reduced somewhat by the requirement to establish travel routes. 

Stock will be concentrated on a minimum number of pathways, minimizing the amount of soil 

compaction and erosion (FEIS page 3-260). Trail stream crossings and stock watering locations will 

result in some erosion into waterways, but the sediment will be quickly dissipated by flowing stream 

water. (FEIS page 3-167). 

The outfitter-guide activities will comply with the Wilderness Act. The pack and saddle stock outfitterguide activities will be managed to protect the wilderness character by allowing only local, minor to 

moderate impacts to the natural qualities, and to the opportunities for solitude or primitive and 

unconfined recreation. The activities will also comply with Forest Service Manual 2300, and the 

Wilderness Management Model. This Model is the basis for the Forest Service wilderness management 

policy of maintaining or improving wilderness character from its state at the time of wilderness 

designation (FEIS page 3-22). The Pasayten and Lake Chelan-Sawtooth wilderness areas will continue on 

an upward trend with implementation of Alternative 4 (FEIS page 3-91). Mitigation measures and 

special use permit administration will ensure the outfitter-guide activities comply with all existing and 

amended Forest Plan standards and guidelines. Refer to FEIS pages 3-91 through 3-107 for a complete 

list of relevant wilderness the standards and guidelines, and an explanation of compliance. 

The Okanogan Forest Plan Forest-wide standard and guideline 8-12 requires that priority be given to 

authorizations that provided a needed public service, as do these permits (see Needs Assessment in FEIS 

Appendix B). Forest-wide standard and guideline 8-13 requires that new permits only be granted when 

the use is compatible with planning direction for National Forest System land, use will not cause major 

damage or impairment of resources and programs, and NFS land is the most logical place for the use. 
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The analysis in Chapter 3 of the FEIS shows the issuance of permits is compatible with the Forest Plan 

(see consistency findings for each resource area in Chapter 3) and that no major damage to impairment 

of resources or programs will occur. National Forest System land is the most logical place for these 

backcountry activities – sufficient land for this experience is not available on other lands. In accordance 

with standard and guideline 8-10, annual reviews of these authorizations will be completed and will 

emphasize health, safety and resource protection (FEIS page 3-149). Permits will include stipulations for 

protecting trails consistent with the goals and recreation opportunity of the management area 

consistent with standard and guideline 8-16. 

The project will comply with the Clean Water Act. None of the water bodies in the analysis area are 

listed as impaired on the 303(d) list, and the outfitter-guide activities will not reduce water quality. 

There will be no newly created openings nor any meaningful reduction in stream shading, so water 

temperature in streams in the analysis area or further downstream will not change from current levels. 

There will be no measurable or detectable changes in fecal coliform levels. Best Management Practices 

will prevent non-point source water pollution and ensure compliance with the Clean Water Act and 

Washington Administrative Code Chapters 173-201 and 202 (FEIS pages 3-176 and 3-177). The outfitterguide activities will also comply with Executive Orders 11988 and 11990 directing Federal agencies to 

avoid adverse impacts to floodplains and wetlands. Outfitter-guides will continue to use camps close to 

wetlands, and grazing stock will travel through wetlands on the way to upland areas. These activities 

will result in vegetation trampling, selective grazing, and soil damage in approximately 1% of the 

wetland habitat in the analysis area although loose grazing practices minimize the intensity of any 

impacts. The remaining 99% will be unaffected. The activities will comply with the Aquatic 

Conservation Strategy Objectives and Riparian Management Objectives, as explained earlier in this 

Record of Decision (FEIS page 3-337). 

The project will meet air quality standards set by the Clean Air Act. The Pasayten Wilderness is the only 

Class 1 airshed in or near the analysis are. Clients and employees of the outfitter-guides will be allowed 

to have campfires, which tend to burn quickly and efficiently, with nearly total consumption of fuel. The 

fires occur at times, and in locations where air movement usually keeps the smoke from settling into a 

localized area. The outfitter-guides are required to extinguish all campfires before leaving camp, which 

will further reduce the possibility of a fire smoldering over a long period of time (FEIS page 3-376). 

The project will comply with the Wilderness Act by permitting the minimum amount of commercial 

services necessary while protecting wilderness character (FEIS page 3-91 and Appendix B-35 through 

Appendix B-43). The project may affect, but is not likely to adversely affect or would have no effect on 

threatened, endangered or proposed listed species under the Endangered Species Act (see discussion of 

Significant Issues #2 and 3 above). The U. S. Fish and Wildlife Service and National Marine Fisheries 

Service have both concurred with these determinations (see above and FEIS pages Appendix M-271 

through Appendix M-290 and USFWS and NMFS concurrence letters dated January 28, 2013 and 

November 13, 2012, respectively, in project record). The National Marine Fisheries Service letter also

concurred with the determination of compliance with the Magnuson-Stevens Act (FEIS page Appendix 

M-271). 

This project complies with the National Historic Preservation Act (NHPA) as amended, and will not 

adversely affect heritage resources. The projects meet the conditions listed in Appendix B of the 

Programmatic Agreement and has been excluded from case-by-case review by the State Historic 

Preservation Office (FEIS page 3-375). Consultation with affected Indian Tribes was completed in 

compliance with Section 106 of the NHPA (FEIS, page 3-369 and 3-370). 
Pack and Saddle Stock Outfitter-Guide Permit ROD 20 March 2013

Okanogan-Wenatchee National Forest

This project is consistent with the Roadless Area Conservation rule because no timber harvest or road 

construction will occur in an inventoried roadless area (FEIS, page 3-374). The project is also consistent 

with the Wild and Scenic Rivers Act because the only camp located along an eligible river is the Andrews 

Creek base camp located within 1⁄4 mile of the Chewuch River. The maintenance of the corral at the 

camp sill not affect future potential designation under the Wild and Scenic River system because the 

corral is not a permanent structure, and could be removed if the Chewuch River is designated as Wild 

and Scenic in the future (FEIS page 3-376). There will be no effects on prime lands since the analysis 

area does not contain any prime farmlands, and will not convert any prime rangelands or prime 

forestlands to other uses (FEIS page 3-377). It will also comply with Executive Orders 11246 (Civil Rights) 

and 12989 (Environmental Justice). The outfitter-guides will be prohibited from discrimination on the 

basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial 

status, parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or 

because all or a part of an individual’s income is derived from any public assistance program. It is 

extremely unlikely additional traffic from the outfitter-guide activities, when added to other traffic 

already present on roads, will be noticeable to low income or minority residents along routes leading to 

outfitter-guide operating areas. Okanogan County has areas of high poverty and local economies will 

benefit from clients passing through towns and making purchases (FEIS page 3-379). 

My conclusions are based on a review of the record that shows a thorough review of relevant scientific 

information was conducted, opposing views were considered, and incomplete or unavailable 

information was acknowledged. A thorough review of scientific literature found no conflicting scientific 

evidence as to the effects of this project. All comments received during scoping and review of the DEIS 

were considered and addressed in the development of alternatives and the analysis of effects. The 

disposition of each comment is shown on the issue tracking forms in the analysis file. Incomplete or 

unavailable information was found in the analysis for fecal coliform levels and the number of people 

who hire an outfitter for convenience instead of actual need. The process specified in 40 CFR 1502.22 

was followed for each of these. 

Quantifiable bacteria data (fecal coliform) for the analysis area are unavailable. Water testing for 

bacteria is problematic from wilderness and backcountry areas because of the time constraints between 

sample collection and testing. In addition, extensive and repetitive testing of background levels of fecal 

coliform, followed by testing when outfitted pack and saddle stock and clients are in the area would be 

required to determine the precise effect. The information about the effect of pack and saddle stock 

outfitter-guides on fecal coliform levels is not relevant to determining effects simply because the 

number of outfitted stock in the analysis area is too small to significantly increase fecal coliform levels 

over background levels (FEIS page 3-174). 

The Needs Assessment (FEIS Appendix B) uses past actual use levels in determining the minimum extent 

of commercial services needed in wilderness. Data does not exist that could be used to generate or 

calculate the percentage of clients who hire an outfitter-guide because of a legitimate need (lack of skill, 

knowledge, or equipment, physical limitations) verses those who hire one for convenience. The means 

to obtain the data to calculate this percentage are not known. No reasonably foreseeable significant 

adverse impacts on the human or biological environment were found in evaluating the effects of 

commercial services in either the Pasayten or Lake Chelan-Sawtooth Wildernesses. Therefore, 

determining the exact number or percentage of past use legitimately needing commercial services is not 

necessary (FEIS page Appendix B-36). 
Pack and Saddle Stock Outfitter-Guide Permit ROD 21 March 2013

Okanogan-Wenatchee National Forest

ADMINISTRATIVE APPEAL RIGHTS

This decision is subject to appeal pursuant to 36 CFR 215. Any written notice of appeal of the decision 

must be fully consistent with 36 CFR 215.14, "Appeal Content.” The notice of appeal must be 

postmarked, hand delivered, or faxed to the Regional Forester at the addresss or numbers shown below

within 45 days of the date the legal notice for this decision appears in the Wenatchee World. Hand 

deliveries must be made between 7:45AM and 4:30 PM Monday through Friday, except legal holidays. 

Electronic appeals must be submitted only to the e-mail address shown above as part of the actual email message, or as an attachment in Microsoft Word, rich text format or Adobe portable document 

format only. E-mails in other formats or containing viruses will be rejected. Note in the subject line the 

name of the project and that it is an appeal. 

The special use permittees have the right to appeal under 36 CFR 251. They may file an appeal under 

215 or 251, but not both. This decision is not appealable under 36 CFR 251 by other parties. Appeals by 

the permittees under 36 CFR 251 must follow the filing procedures in 251.88, and must meet all of the 

requirements in 251.90, including a statement of the facts of the dispute and issues raised by the 

appeal. The appeal must include specific references to any laws, regulations, or policies that the 

permittees believe have been violated. The appeal must be in writing and must be postmarked and sent 

within 45 days of this decision to:

Mail: Delivery Service or Hand Delivery:

Regional Forester Regional Forester

Attention: 1570 Appeals Attention: 1570 Appeals

P. O. Box 3623 333 SW First Avenue

Portland, Oregon 97208-3623 Portland, OR 97804

Appeals can be faxed to FAX #503-808-2339.

Electronic appeals can be sent via email to: appeals-pacificnorthwest-regional-office@fs.fed.us 

The permittees are also required to simultaneously send a copy of the appeal to the project deciding 

officer:

Forest Supervisor

c/o Forest Environmental Coordinator

215 Melody Lane

Wenatchee, WA 98801

Or: appeals-pacificnorthwest-okanogan-wenatchee@fs.fed.us

IMPLEMENTATION

Implementation of this decision shall occur no sooner than 45 days plus 5 business days after the 

publication of the legal notice of the decision in the Wenatchee World newspaper if no appeal is 

received. If a 215 appeal is received and the decision is affirmed, the project cannot be implemented for 

15 business days after the appeal decision. Implementation of this decision consists of issuance of 10-

year outfitter-guide special use permits to the existing outfitters, or other acceptable businesses if any 

of the current businesses cease operation, or have permits revoked, as long as the maximum annual 

service days (6,700) is not exceeded. 

Pack and Saddle Stock Outfitter

-Guide Permit ROD 23 March 2013

Okanogan-Wenatchee National Forest
Pack and Saddle Stock Outfitter-Guide Permit ROD 24 March 2013

Okanogan-Wenatchee National Forest

Errata Sheet

Pack and Saddle Stock Outfitter-Guide Special Use Permit FEIS

FEIS Page Number Published Data Corrected Data Explanation

2-18, paragraph 5 “MA15B-21K...” “MA15B-21L...” Typographical error

3-37, paragraph 3 “Refer to Figures 3.10-1, 

3.10-2, 3.10-3, and 3.10-4”

“Refer to Figures 3.2-2 

and 3.2-4”

Change is Figure 

Numbering

3-70, paragraph 1 “Refer to Figure 3.10-8 

and Figure 3.10-12”

“Refer to Figure 3.2-12 

and Figure 3.2-16”

Change in Figure 

Numbering

3-72, paragraph 4 “1,528 square feet of 

undesignated barren 

core”

“2,290 square feet of 

undesignated barren 

core”

Calculation error

3-72, paragraph 4 “This totals 11,010 square 

feet...”

“This totals 11,772 square 

feet...”

Calculation error

3-76, paragraph 6 “A total of 13,659 square 

feet (three-tenths of an 

acre)...”

“A total of 14,109 square 

feet (three-tenths of an 

acre)...”

Calculation error

3-157, paragraph 2 “798 miles of trail 

converts to 376 acres”

“798 miles of trail 

converts to 387 acres”

Incorrect conversion 

factor used in calculation

3-157, paragraph 2 “Outfitter-guides use 

378.7 acres of bare soil...”

“Outfitters use 389.7 

acres of bare soil...”

Incorrect conversion 

factor used in calculation

3-157, paragraph 3 “152 miles of trail 

converts to 71.6 acres”

“152 miles of trail 

converts to 74 acres”

Incorrect conversion 

factor used in calculation

3-157, paragraph 3 “Outfitter-guides use 72.7 

acres of bare soil...”

“Outfitter-guides use 75.1 

acres of bare soil...”

Incorrect conversion 

factor used in calculation

3-158, paragraph 4 “150 miles of trail 

converts to 70.6 acres”

“150 miles of trail 

converts to 73 acres”

Incorrect conversion 

factor used in calculation

3-158, paragraph 4 “This is approximately 

0.06% of total sub-area.”

“This is approximately 

0.03% of total sub area.”

Incorrect conversion 

factor used in calculation

3-158, paragraph 5 “60 miles of trail converts 

to 28.3 acres”

“60 miles of trail converts 

to 29 acres”

Incorrect conversion 

factor used in calculation

3-201, last sentence on 

the page 

“...4 campsites, and 35 

near wetlands...”

“...4 campsites on 

lakeshores, and 35 near 

wetlands...”

Editorial error

3-213, under “Barren core 

within riparian campsites

“Outfitter-guides use 21 

riparian campsites within 

the backcountry.”

“Outfitter-guides use 14 

riparian campsites within 

the Pasayten and Lake 

Chelan-Sawtooth 

Wilderness

Editorial error

3-177, 6th bullet & 

3-221, paragraph under 

“Aquatic Resources”

“...and reduce impacts to 

water quality from 

increased sedimentation, 

reduced shade and 

hazardous materials.”

“...and reduce impacts to 

water quality by 

decreasing sedimentation, 

protecting streamside 

vegetation to maintain 

shade, and minimizing 

risks of contamination 

from hazardous materials

Editorial error

3-277, first paragraph 

after figure

“...because they would be 

unlikely to hinder the 

attainment of the 

RMOs...”...

“...because they would not 

hinder the attainment of 

RMOs...”

Editorial error
Pack and Saddle Stock Outfitter-Guide Permit ROD 25 March 2013

Okanogan-Wenatchee National Forest

3-265, paragraph 7 “There are 64 

campsites...” 

“There are 86 

campsites...”

Editorial error

3-266, paragraph 6 “...measures included in 

numbers 6, 8, 10, and 

14...”

“...measures included in 

numbers 6, 8, 10, and 

13...”

Typographical error

3-289, paragraph 4 “...and prevent picketing 

of stock overnight in 

alpine meadows...”

“...and prevent picketing 

of stock overnight in subalpine meadows...”

Editorial error

3-353, 3rd bullet “Prohibiting picketing of 

stock...” 

“Prohibiting overnight 

picketing of stock...” 

Editorial error

3-353, paragraph 2, after 

bulleted list

“...would increase stock 

use by 5%...”

“...would increase stock 

use by 50%...”

Typographical error

3-356, addition to 

compliance with MA7-11A

The pack and saddle stock 

outfitter-guide permits 

would not include any 

domestic livestock 

grazing.

Editorial error.
Pack and Saddle Stock Outfitter-Guide Permit ROD 26 March 2013

Okanogan-Wenatchee National Forest

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