CHAPTER 1

Purpose and Need
Changes Between Draft and Final Environment Impact Statement

Revised the Purpose and Need to add a Forest Plan Amendment addressing 

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

Incorporated information from revised 2012 Needs Assessment.

Revised the Proposed Action to add a Forest Plan amendment to MA15B-21L to 

allow the pack and saddle stock outfitter-guides to use existing campsites within 

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

Updated the Public Involvement section to add information about release and 

review of the Draft EIS.

As a result of comments on the DEIS, added a Significant Issue pertaining to the 

number of service days and barren core limitations in Alternative 2.

As a result of comments on the DEIS, added an Other Issue pertaining to the 

economic impact of the pack and saddle stock outfitter-guides.

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

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 to 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 3% of the overall outfitted and non-outfitted visitor days (defined as 

one person for one day) across the analysis area, and approximately 15% 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 Final Environmental Impact Statement (FEIS) in compliance 

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

and regulations. A Draft EIS was published for a 45 day public and agency comment period on 

August 31, 2010. The comment period was extended until November 22, 2010. This FEIS 

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 FEIS, is a separate document 

based on this FEIS.

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 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-2 February 2013

Okanogan-Wenatchee National Forest

measures and monitoring are also detailed. Finally, this chapter provides a summary table 

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 

FEIS. 

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, 

Sawtooth Backcountry, the Bear/Ramsey/Volstead area, Alta Lake, 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 Ranger District, and acres in 

the analysis area.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-3 February 2013

Okanogan-Wenatchee National Forest

Figure 1-1: Analysis Area Acreage

Sub-Area 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 Methow Valley 

(administered by the 

Chelan District

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 the Pasayten 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 the Pasayten. 

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 ; these are along the 

shores of Lake Chelan and 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 North Cascades 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.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-4 February 2013

Okanogan-Wenatchee National Forest

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 camp1at the Slate Creek trailhead.

 

1 An assigned base camp is a Permanent camps near trailheads where outfitter-guides can keep stock, meet clients and base operations. Base camps 

have corrals and other facilities for stock handling and care, in addition to parking areas for clients and employees.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-5 February 2013

Okanogan-Wenatchee National Forest

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 

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 first special use permits for outfitting and guiding with pack and saddle stock were issued in 

the 1950s and 1960s. Since then, the number of companies operating and the number of 

service days used has fluctuated, but there has been a consistent, active group of pack and 

saddle stock outfitter-guide over the 50 years. 

Service Days

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 one 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. There are currently 4,460 service days divided between the outfitters, 

with a portion held in a pool to be assigned as needed to help the outfitters respond to 

increases in demand. Two of the current outfitters offer day rides in the North Cascades and 

Alta Lake sub-areas. All other service days are for overnight camping. The days are spread 

across the analysis area as shown in the following figure.

Figure 1-2. Current Service Days by Sub-area

Sub-area Assigned Service Days Pool Service Days Total Service Days

Pasayten Wilderness 1,548 252 1,800

Lake Chelan-Sawtooth 

Wilderness

539 176 715

North Cascades 143 25 168

North Cascades

(day rides)

355 250 605

Sawtooth Backcountry 250 144 394

Bear/Ramsey/Volstead 11 37 48

Middle Methow

Alta Lake

(day rides)

585 145 720

TOTAL 3,431 1,029 4,460
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-6 February 2013

Okanogan-Wenatchee National Forest

Campsites

The outfitter-guides are allowed to use any established campsite across the permit area 

(analysis area), with the exception of within the Lake Chelan-Sawtooth Wilderness, where they 

are restricted to using designated campsites. There are five camps in the Pasayten Wilderness –

Bald Mountain, Beaver Creek, Sheep Mountain, Crow Lake, and Whistler camp – that are 

assigned sites. These campsites are designated and authorized for occupancy and use by a 

specific outfitter, and closed to use by the general public. The outfitter pays an additional fee 

for each site, and is allowed to leave camping equipment and supplies in camp for the entire 

season. All equipment and supplies must be removed at the end of the season. For all other 

campsites, all equipment and supplies must be removed at the end of each trip.

There are also four established base camps; one at the Andrews Creek Trailhead, another at the 

Crater Creek Trailhead, the third at the Slate Lake Trailhead, and the forth at Fish Creek. There 

are permanent camps where outfitter-guides can keep stock, meet clients and base operations. 

Base camps have corrals and other facilities for stock handling and care, in addition to parking 

areas for clients and employees.

Appendix A lists all the campsites regularly used by the outfitters. They use other camps 

periodically, but tend to return to the same camps year after year. The outfitters can use any 

established campsite within their permit area on the Methow Valley and Tonasket Ranger 

Districts, and are restricted to using designated campsites on the Chelan District. 

Current Outfitters

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

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-areas. 

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-areas. 

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-areas. The permit also includes an additional 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-areas.

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-areas. 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-7 February 2013

Okanogan-Wenatchee National Forest

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-areas. The permit also includes an additional 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. They are permitted to use established campsites throughout the 

analysis area. There are five assigned sites in the Pasayten Wilderness: Bald Mountain, Sheep 

Mountain, Beaver Creek, Crow Lake, and Whistler. These campsites are assigned to specific 

outfitter-guides, who pay additional charges for exclusive use of the camps. The outfitters are 

allowed to set up camps in these locations, and leave the equipment in place for an entire 

season. There are also four base camps outside wilderness: Andrews Creek, Billygoat, Slate 

Creek, and Crater Creek. These are also assigned to specific outfitters, and are used as staging 

areas near trailheads where clients meet with the outfitter and leave from their trips.

The types of trips offered are:

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; food and gear is packed

Standard Hiking Trips: Same as full-service hiking 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.

Loose Grazing and Stock Containment

The outfitter-guides use two methods of caring for stock on overnight trips into wilderness and 

the backcountry: stock containment and loose grazing. Stock containment refers to tying stock 

to trees for short durations, tying to hitch rails or highlines, picketing stock, or holding them in a 

corral. Loose grazing is a technique where the stock are let loose to graze. 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-8 February 2013

Okanogan-Wenatchee National Forest

Stock confinement methods currently used include hitch rails, corrals, highlines, and pickets. 

Hitch rails are installed at the Sheep Mountain and Bald Mountain assigned sites. They consist 

of wooden side posts and a wooden top rail. There is also a corral at Sheep Mountain, 

constructed with wooden posts and rails. Highlines or lowlines are used at most camps. They 

are made by tying a rope between two trees, then tying the stock to the rope. Some outfitters 

occasionally use pickets to anchor stock to one spot to graze, then move the stock to a highline 

after feeding. 

Confined stock must be taken to a grazing area and watering spot, then returned. Processed 

weed-free feed is often brought for stock that are confined, and to areas where adequate graze 

is not available near the campsite.

Loose grazing is often the method used by outfitters in camps they frequent often, such as the 

assigned sites. The outfitter identifies areas with sufficient graze, typically within one to two 

miles of camp depending on the location of the camp. These areas are carefully selected to 

move stock well away from other campsites and private stock. The stock are led to the grazing 

area, or travel there on their own, and left for the night. Bells are often placed on one or two of 

the stock to help the outfitter locate them if they do not return to camp on their own. Some 

outfitters hobble selected stock to help confine movement and facilitate catching, although 

stock can still travel very well with hobbles. In some camps, the stock are led back to camp in 

the mornings. In others, the stock is trained to return in the morning on their own. One to two 

horses are usually kept contained near the camp at night, to facilitate catching horses in the 

morning if needed. 

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. Those most 

relevant to impacts associated with this project are:

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 

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 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-9 February 2013

Okanogan-Wenatchee National Forest

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 implementing regulations at 36 CFR 220 establish 

the basic process for conducting and documenting environmental analyses, including public 

participation. Under this law and these regulations, 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 

the Okanogan National Forest Land and Resource Management Plan (1989) and Wenatchee 

National Forest Land and Resource Management Plan (1990).

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.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-10 February 2013

Okanogan-Wenatchee National Forest

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 and the 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)

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 – LAND AND RESOURCE MANAGEMENT PLANS

Management direction for the analysis area has been established by the Okanogan and 

Wenatchee National Forests’ Land and Resource Management Plans. 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-11 February 2013

Okanogan-Wenatchee National Forest

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 (USDA Forest Service 1990a) and its accompanying Land and 

Resource Management Plan (Wenatchee Forest Plan, USDA Forest Service 1990b). Forest Plan 

standards and guidelines provide general direction for the administration of National Forest 

System land. Relevant standards and guidelines established by both Forest Plans for this project 

are listed below. 

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 meet the objectives of LSR 

management. (USDA and USDI 1994: C-19).

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

the underlying NWFP and original Forest Plan management direction on all streams and 

wetlands. The Northwest Forest Plan and Riparian Reserves are discussed in the Aquatic 

Section, beginning on page 3-9. 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).

o Congressionally Reserved: lands that have been reserved by act of Congress for specific 

land allocation purposes. The Pasayten Wilderness and Lake Chelan-Sawtooth 

Wilderness are within this allocation. Management of these lands follows the direction 

in the Wilderness Act (applicable legislation) since it provides more restrictive or greated 

benefits to late-successional forest related species (USDA and USDI 1994: ROD 6 and C8). 

o Administratively Withdrawn: areas identified in current forest plans and include 

recreation and visual areas, back country, and other areas not scheduled for timber 

harvest. The portion of the North Cascades sub-area within the North Cascades Scenic 

Highway Corridor is included in this allocation. The standards and guidelines of the 

current forest plans apply where they are more restrictive or provide greater benefits to 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-12 February 2013

Okanogan-Wenatchee National Forest

late-successional and old-growth forest related species (USDA and USDI 1994: ROD 7 

and C-29).

o Matrix: areas not included in the five categories of designated areas described above. 

There are no standards and guidelines for Matrix pertaining to special use permits or 

recreation activities (USDA and USDI 1994: ROD 7 and C-39).

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. 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 provides additional management 

direction in riparian areas (overlaying original Forest Plan direction) 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 Priority Watersheds and requires 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 referred to as the Eastside Screens. 

The Eastside Screens only apply to timber sales and thus are not relevant to this analysis and 

will not be discussed further. 

On December 17, 2009, the U.S. District Court for the Western District of 

Washington issued an order in Conservation Northwest, et al. v. Sherman, et al., No. 

08-1067-JCC (W.D. Wash.), granting Plaintiffs’ motion for partial summary judgment 

and finding NEPA violations in the Final Supplemental to the 2004 Supplemental 

Environmental Impact Statement to Remove or Modify the Survey and Manage 

Mitigation Measure Standards and Guidelines (USDA and USDI, June 2007). In 

response, parties entered into settlement negotiations in April 2010, and the Court 

filed approval of the resulting Settlement Agreement on July 6, 2011. Projects that 

are within the range of the northern spotted owl are subject to the survey and 

management standards and guidelines in the 2001 ROD, as modified by the 2011 

Settlement Agreement. 

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.

“Recreation special use authorizations shall conform to the goals of the MA.” 

Forest-wide Standard and Guideline 8-11.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-13 February 2013

Okanogan-Wenatchee National Forest

The Wenatchee Forest Plan recognizes that outfitter-guides 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 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. The Pasayten and 

Lake-Chelan Sawtooth Wilderness Areas have their own wilderness management allocations. All 

of the analysis area sub-areas 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), and most areas outside wilderness are 

in Late Successional Reserves. Each sub-area 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 Class in the Wenatchee 

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

Pristine 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).
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-14 February 2013

Okanogan-Wenatchee National Forest

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).

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-area 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-area 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 25 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-area lie within the Upper Methow Late-Successional Reserve under the Northwest 

Forest Plan. Map 1-6 in the Map Section of this document shows the North Cascades 

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 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-15 February 2013

Okanogan-Wenatchee National Forest

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)

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-area 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-area 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.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-16 February 2013

Okanogan-Wenatchee National Forest

Other Policy, Guidance, and Analyses Considered and Incorporated by Reference

Forest Service Handbooks and Manuals

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

outfitting and guiding. The Forest Service Manual Chapter 2320.2 sets policy for wilderness 

management. Refer to these for detailed information. 

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, management implications and 

recommendations for late-successional 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 made the recommendation to 

carefully consider effects of 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, requiring an interim 

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

the Forest Plan Revision process currently underway on the Okanogan-Wenatchee National 

Forest. 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

Watershed analyses within Key and Priority Watersheds have 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 substantial uses 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. The following watershed analyses include areas within the analysis 

area:
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-17 February 2013

Okanogan-Wenatchee National Forest

Chewuch River Watershed Analysis (USDA Forest Service 1994)

The area generally west of the Chewuch River is a Key Watershed in the Northwest Forest Plan)

and the area generally east of the Chewuch River is a Priority Watershed in PACFISH.

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 a Priority Watershed under PACFISH. 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.

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 a 

Priority Watershed under PACFISH. It contains a portion of the Sawtooth Late-Successional 

Reserve.

Salmon Watershed Assessment (USDA Forest Service 1997d)

Salmon Creek is a Priority Watershed under PACFISH.

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.

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 2001a)

The Upper Skagit River is not designated as a Key Watershed.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-18 February 2013

Okanogan-Wenatchee National Forest

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

in the Pasayten Wilderness and Lake Chelan-Sawtooth Wilderness, 2012 (USDA Forest Service, 

2012)

The Forest Service Manual also includes the requirement to address the need for and role of 

outfitters in the Forest Plan. The Wilderness Act prohibits commercial services except “to the 

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

purposes of the areas.”

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”, August 2012 (USDA Forest Service, 2012). This paper is referred to as 

the “2012 Needs Assessment” in this document. The following information is summarized from 

the Needs Assessment. The Needs Assessment is included in Appendix B of this FEIS. 

The 2012 Needs Assessment found there is a need for pack and saddle stock outfitter guides in 

wilderness. The minimum amount of commercial services needed to provide for recreation is 

not a number that can be precisely calculated. Rather, several factors are considered to 

establish a range of service days that would provide the minimum extent of commercial service. 

Considering all the factors, the minimum extent of pack and saddle stock commercial services in 

the Pasayten will range from approximately 1,735 to 2,170 service days. In the Lake ChelanSawtooth, the range will be approximately 660 to 825 (Needs Assessment, 2012).

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,

reconcile inconsistencies between forest plan standards and guidelines for barren core (see 

Glossary) in wilderness with party size limitations (currently 12 people and 18 head of 

stock), and the non-degradation policy and the prohibition on camps within 200 feet of 

meadows, streams, lakes, and special interest areas. 

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. Part of the 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 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-19 February 2013

Okanogan-Wenatchee National Forest

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

FSH 2709.11 also includes the requirement to address the need for and role of outfitters in the 

Forest Plan. The Wilderness Act prohibits commercial services except “to the extent necessary 

for activities which are proper for realizing the recreational or other wilderness purposes of the 

areas.”

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”, April 2012 (USDA Forest Service, 2012). This paper is referred to as the 

“2012 Needs Assessment” in this document. The following information is summarized from the 

Needs Assessment. Refer to Appendix B for the full document. 

The 2012 Needs Assessment 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 conversations 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. Rather, several factors are considered to establish a range of 

service days that would provide the minimum extent of commercial service. The factors include

the:

need for commercial services, 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-20 February 2013

Okanogan-Wenatchee National Forest

historic number of service days,

proportional relationship between outfitter and non-outfitted use levels,

current resource conditions and impacts from recreation use on wilderness character,

wilderness capacity, and 

anticipated changes in overall number of recreationists and need for outfitter guides.

Considering all the factors, the minimum extent of pack and saddle stock commercial services in 

the Pasayten ranges from approximately 1,735 to 2,170 service days. In the Lake ChelanSawtooth, the range is approximately 660 to 825 (Needs Assessment, 2012).

Reconcile Inconsistencies Between Forest Plan Wilderness Standards and Guidelines

Currently both the Okanogan and Wenatchee Forest Plans have inconsistent management 

direction regarding party sizes and maximum vegetation loss (barren core) sizes. There is also 

inconsistency between campsite proximity to meadows, streams, lakes, and special interest 

areas and the non-degradation policy (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.

Currently, the Okanogan Forest Plan includes a standard and guideline that prohibits camping 

within 200 feet slope distance from meadows, lakes, streams, and key interest areas in the 

Pasayten and Lake Chelan-Sawtooth wilderness areas (MA15B-21L). The Wenatchee Forest plan 

does not include standards and guidelines restricting camping near these features. The 

established network of campsites includes approximately 500 sites in the Pasayten and 135 in 

the Lake Chelan-Sawtooth Wilderness. The pack and saddle stock outfitter-guides regularly use 

approximately 75 of those in the Pasayten and 24 in the Methow Valley Ranger District side of 

the Lake Chelan-Sawtooth, or a total of 99 within the area subject to the Okanogan Forest Plan 

requirement. Approximately 86 of these are within the 200-foot buffer around meadows, 

streams, lakes, and key interest points. The remaining 13 campsites would not be an adequate 

number for the pack and saddle stock outfitter-guide operations. As with the need to amend 

the barren core standards and guidelines, an amendment of MA15B-21 L is needed in order to 

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

Appendix A for a list of campsites, and which are within the buffer.

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 and were located close to 

meadows, streams, lakes, and key interest areas. These same campsites still exist and are 

currently used by both outfitter-guides and the non-outfitted public. 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-21 February 2013

Okanogan-Wenatchee National Forest

In the time between when the Forest Plans were published and the present (over two decades), 

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

have consistently suggested that using existing, stable campsites is preferable to creating new 

campsites and degrading the wilderness character (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. Refer to Figures A-1 and A-2 for details 

about each camp.

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 cores in excess of 

the forest plan standards and guidelines. 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.

The Forest Service also encourages people to use existing campsites to avoid wilderness 

degradation by controlling campsite density and keeping the wilderness condition on the 

current upward or stable trend. As with the amendment for barren core, amending the 

Okanogan Forest Plan to allow outfitter-guides to use existing campsites is a mechanism to 

prevent wilderness degradation from creation of new campsites.

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. The 

original proposed action included in the DEIS and used for public scoping was modified. The 

Forest Service Handbook was revised after scoping and the number of service days in the 

proposed action was modified to meet current handbook direction for determining service days 

(FSH 2709.11, Chapter 40). In addition, a forest plan amendment was added that would allow 

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

interest areas. Refer to the Alternatives Considered but Eliminated section in Chapter 2 for the 

rational for eliminating the original proposed action. The original proposed action was 

eliminated from further consideration (see Alternatives Considered but Eliminated in Chapter 2). 

The modified proposed action became Alternative 2 in this FEIS. It is described in detail in 

Chapter 2. 

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):

Cascade Wilderness Outfitters

Deli Llama Wilderness Adventures

Early Winters Outfitting
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-22 February 2013

Okanogan-Wenatchee National Forest

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 service 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 days (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 within wilderness for existing assigned 

camps at Bald Mountain, Sheep Mountain, Crow Lake, Beaver Creek, and Whistler. Assigned 

sites are locations authorized for exclusive occupancy and use for which a fee is paid by the 

permit holder (also called ‘designated’ or ‘reserved’ sites). All sites listed above are in the 

Pasayten Wilderness (refer to Map 3.2-1 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 could be designated at 

existing campsites to allow for closer monitoring and subsequent modification of use to address 

resource concerns and assist in outfitter-guide operations if needed in the future.

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

Slate Creek, and Crater Creek trailheads (Methow Valley Ranger District); Fish Creek camp 

(Chelan Ranger District). These locations are outside wilderness. Each location has corrals, 

watering troughs, and other improvements necessary to protect resources. All assigned camps 

and base camps are shown on Maps 3.2-1 and 3.2-2 in the Map Section of this document.

Forest Plan Amendments

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-Guide Permit FEIS 1-23 February 2013

Okanogan-Wenatchee National Forest

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, pack and saddle stock 

outfitter-guides shall not use more than 5,250 square feet of the barren core. All pack 

and saddle stock outfitter-guides shall use the same delineated, 5,250 square-foot area 

for each camp and shall not use any area outside of the delineated 5,250 square-foot 

area.

Standard and guideline MA15B-21L would be reworded as follows:

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

streams, and key interest areas, except existing campsites used by pack and saddle 

stock outfitter-guides. Camping may be restricted or prohibited in certain areas to 

protect wilderness values.

Decision Framework

The Forest Supervisor of the 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 Forest Supervisor will also decide what, if any, mitigation 

measures and monitoring are needed. The decision will be made based upon the analysis made 

in the FEIS 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 Significant 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

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

environment identified as Significant Issues.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-24 February 2013

Okanogan-Wenatchee National Forest

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 altered when the revised Forest Service Handbook 2709.11 was 

published, giving specific direction on calculating service days. 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 DEIS was distributed to approximately 200 people and organizations on August 31, 2010. 

The original 45-day comment period was extended to 60 days to accommodate requests for 

additional review time. Two hundred and fifty-eight comment letters were received. All 

comments were addressed in the FEIS, and additional analysis was added where needed. 

Alternative 4 was added to respond to concerns about the barren core limitations in Alternative 

2, and to a concern that the number of service days in Alternative 2 would not be enough for 

the pack and saddle stock outfitter-guides if the demand for their services rebounded to levels 

seen ten years ago. The Forest Service also determined that an amendment of the standard and 

guideline prohibiting camping within 200 feet of meadows, lakes, streams, would be needed to 

implement the proposed action.

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

letters are included in the analysis file.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-25 February 2013

Okanogan-Wenatchee National Forest

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. Consultation with the US Fish 

and Wildlife Service and the National Marine Fisheries Service was completed, and both 

agencies issued concurrence letters. Consultation with the State Historic Preservation Office 

was not required because the proposed action and alternatives would be excluded from caseby-case review by the Programmatic Agreement.

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.

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 “Significant 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.

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.

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 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-26 February 2013

Okanogan-Wenatchee National Forest

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.

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.

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.

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.

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.

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 and in a Wildlife Biological 

Assessment (BA) completed for the analysis.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-27 February 2013

Okanogan-Wenatchee National Forest

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.

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 minimize impacts.

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

effects determination statements from Biological Assessment for threatened and 

endangered fish species;

quantitative estimates of the square feet of riparian areas affected by pack and saddle stock 

activities;

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 loose grazing on riparian areas, streams, and lakes,

qualitative discussion about stream sedimentation;

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 and in the Aquatic Biological Assessment completed for this analysis.

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 not allow the businesses to respond to increases in demand for pack and saddle stock 

outfitter-guide services. 

The current pack and saddle stock outfitter-guides, in addition to numerous individuals and 

organizations, expressed concern over the barren core limitations and number of service days in 

Alternative 2 in the DEIS. They felt that a larger barren core was needed. They also felt that the 

number of service days in Alternative 2 would not allow them to respond to demand for their 

services if that demand increased to the level seen ten years ago. 

The effects on outfitter-guide operations were measured by:

quantitative discussion on existing barren core in outfitter camps, and the amount of 

area needed for a party of 12 people and 18 head of stock

qualitative discussion on the impacts to the businesses from the number of service days.

Alternative 4 was added to this FEIS to address these concerns. The environmental and social 

impacts of the alternative are included in Chapter 3.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-28 February 2013

Okanogan-Wenatchee National Forest

OTHER ISSUES

In addition to resources associated with the Significant 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, or found to be unaffected by the 

proposed action or alternatives, and were not used in alternative formulation. The effects on 

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

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

weed-free areas, such as wilderness, in stock manure. Mitigation measures were added 

to avoid introduction and spread of invasive species, and to require the pack and saddle 

stock outfitter-guides to participate in the species identification, mapping, surveying and 

control

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

campfires. An analysis of smoke from outfitter-guide campfires found that it would not 

degrade air quality, or violate the Clean Air Act. The analysis is included in Chapter 3. 

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

down woody debris and limiting or eliminating this habitat component. A mitigation 

measure was added that would prohibit outfitter-guides from using downed wood larger 

than 12 inches in riparian areas. Another mitigation measure would prohibit outfitters 

from cutting snags for firewood. The terrestrial wildlife analysis found that firewood 

gathering (of downed wood) would not limit habitat for species needed downed wood.

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. This was 

addressed in Alternative 4.

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

users outside of wilderness by perpetuating conflicts between outfitted and nonoutfitted user groups, increasing the number of people recreating in any given area, and 

adding to conflicts between user groups. These concerns were analyzed in the 

Recreation section in Chapter 3. Infrequent conflicts between user groups have been 

reported in the past.

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. Mitigation measures were added to avoid or minimize impacts to soil and 

vegetation. Impacts to soil are included in the Soil section of Chapter 3.

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. The range analysis found that forage utilization standards are not 

being exceeded. This is included in the Range section of Chapter 3.

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

economic analysis was added to the FEIS. The results are included in the Economic and 

Social Analysis section of Chapter 3.

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, 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-29 February 2013

Okanogan-Wenatchee National Forest

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 Forest Service regulations on 

special use permit fees (USDA Forest Service, 2008a).

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

because 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 outside the scope of the 

analysis because the proposed action is to issue pack and saddle stock outfitter-guide 

permits. It does not propose any changes to threatened and endangered species habitat 

management. The Forest Service’s policy is to not maintain buffer around wilderness to 

provide an informal extension of wilderness (FSM 2320.3). Refer to the wildlife section 

in Chapter 3 for the analysis of the proposed action and alternatives on these species. 

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

old growth. This issue is irrelevant to the decision because 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 because 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

and the requirements in the OG permits will be enforced.

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. Outfitter-guide use is tracked and monitored as 

part of permit administration.

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 FEIS 1-30 February 2013

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. The proposed action and alternatives address limits on both people 

and stock for outfitter-guides.

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

not part of the purpose and need or proposed action.

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

This issue is not accurate, and is outside the scope of the analysis because any 

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

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

and saddle stock outfitter-guide permits across the analysis area, including the Pasayten 

Wilderness. The other alternatives permit both horses and outfitters in the Pasayten 

Wilderness.

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 

connected to or influenced by the pack and saddle stock outfitter-guides.

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 and will be accomplished 

through permit administration.

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. Alternative 1 would not issue pack and saddle stock outfitter-guide permits, so 

there would be no outfitters in these areas of concern. Alternative 3 would prohibit pack 

and saddle stock outfitter-guides from camping within 200 feet of wetlands, lakes and 

streams. An alternative that would have prohibited outfitters from camping within 200 

feet of all meadows, streams, lakes and key interest areas was considered but eliminated

(see Alternatives Eliminated from Detailed Study in Chapter 2). The effects of pack and 

saddle stock outfitter-guides on these resources is included in the specialist reports, and 

in this document.

16. Private users with stock are causing serious impacts also, and an EA should be done on 

that, too. Forest plan amendments should apply to everyone. This is outside the scope 

of the proposed action, which only includes 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. The Forest Service is not proposing to close these 

areas to horse camping, so this issue is inaccurate and conjectural. 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-31 February 2013

Okanogan-Wenatchee National Forest

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 has no bearing on the 

environmental effects of issuing pack and saddle stock outfitter-guide permits and is not 

part of the purpose and need. National Trail designation is under the authority of 

Congress, which has already designated the Pacific Northwest Trail.

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 

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. The impacts of the proposed action and alternatives on 

threatened and endangered plant species are disclosed in the Botany section of Chapter 

3. 

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. An alternative that would have limited the distance pack and 

saddle stock outfitter-guides could travel from trailheads was considered but eliminated. 

Refer to the Alternative Considered But Eliminated section in Chapter 2. 

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. 

The impacts to trails from outfitter-guide use are addressed in the Soil section of Chapter 

3. 

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 to issue permits to 

Outfitter-Guides.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 1-32 February 2013

Okanogan-Wenatchee National Forest

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. Outward Bound’s use is considered in cumulative effects

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 decision2. 

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 because the budget is determined by Congress.

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 and trapping regulations are determined by Washington State 

Department of Fish and Wildlife. Impacts of recreational livestock grazing are addressed 

in various resource sections in Chapter 3. New roads, two stoke vehicles, commercial 

livestock grazing, mining, logging, drilling, and prescribed burning are not associated 

with pack and saddle stock outfitter-guides. 

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. 

Capacity analyses were completed for the Pasayten and Lake Chelan-Sawtooth 

wildernesses as part of the Need Assessment and Minimum Extent Necessary 

Determination (USDA Forest Service, 2012 and Appendix B). Any type of limitation on 

non-outfitted recreationists is outside the scope of this analysis because the purpose and 

need does not include non-outfitted use. 

31. Cattle and sheep grazing should be returned to the forest. This issue was eliminated 

because it is outside the scope of the analysis.

 

2

The DEIS contained some inaccurate information under this eliminated issue. The Forest Service regrets 

the error.