United

States 

Department 

of

Agriculture

Forest 

Service

Pacific 

Southwest

Region

Final Environmental 

Impact Statement for 

Greys Mountain 

Ecological Restoration 

Project

Sierra National Forest, Bass Lake Ranger District

Madera County, CA
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest

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recycled paper – June 2009
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest

GREYS MOUNTAIN ECOLOGICAL RESTORATION 

PROJECT

Final Environmental Impact Statement

Madera/Mariposa Counties, California; Sierra National Forest; Bass Lake Ranger District

Lead Agency: USDA Forest Service

Cooperating Agencies: N/A

Responsible Official: Scott Armentrout, Forest Supervisor 

 1600 Tollhouse Road, Clovis, CA 93611 

For Information Contact: Burt Stalter, District Fuels Specialist 

 57003 Road 225, North Fork, CA 93643

(559) 877-2218 ext. 3208

Abstract: This document examines the environmental effects of a proposal to move towards 

meeting management goals and objectives for the Greys Mountain Ecological Restoration Project 

(Greys Mountain Project) as set forth in the SNF Land and Resource Management Plan (SNFLRMP) as amended by the 2004 Sierra Nevada Forest Plan Amendment (SNFPA) and the 2007 

Sierra Nevada Forests Management Indicator Species Amendment (SNF MIS). The purpose of 

the proposal is to achieve ecological restoration objectives and protect communities in the 

Wildland Urban Intermix (WUI) from wildfire. The ecological restoration goals of the Greys

Mountain Project is multi-faceted and includes the following: (1) increase forest resilience to 

insects, disease, and drought through prescribed fire and mechanical thinning treatments, (2) 

promote heterogeneity in forest structure for improving wildlife habitat, (3) decrease the 

occurrence of uncharacteristically severe wildfires and their impacts to ecosystems and 

watersheds, (4) promote native biodiversity, (5) restore degraded montane meadows, (6) improve 

habitat quality and connectivity for sensitive wildlife species, (7) decrease impacts of invasive 

plant species, (8) decommission and restore unneeded user defined vehicle trails, and (9) provide 

sustainable delivery of ecosystem services, such as clean water and carbon sequestration, in an 

era of changing climate. Alternatives considered in detail are: Alternative 1 (No Action), would 

leave the area in its present condition; Alternative 2 (proposed action), would thin conifer stands 

to reduce stand densities and ladder fuels and promote stand heterogeneity; masticate ladder fuels 

and brush/shrub patches; utilize prescribed , understory and pile burning; manually treat and/or 

prescribed burn noxious weed infestations; prepare and plant failed conifer plantations; restore 

degraded aquatic features; reduce fuel loading and ladder fuels in prehistoric and historic sites; 

restore user-defined vehicle trails to natural condition; restore native plant communities for 

cultural gathering needs; improve wildlife habitat by restoring key structures and components; 

improve and maintain existing forest transportation routes; improve and maintain existing range 

management facilities and resources; reduce conifer stand densities within developed recreation 

sites. Alternative 3, would contain similar types of treatments as Alternative 2, but would limit 

the degree of treatment to that needed to achieve only the fire and fuels objectives in all treatment 

areas.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest iv Table of Contents 

Table of Contents

Summary..............................................................................................................ix

Chapter 1. Purpose of and Need for Action ............................................................1

Document Structure............................................................................................1

Background.......................................................................................................1

Purpose and Need for Action...............................................................................6

Proposed Action ................................................................................................6

Decision Framework ........................................................................................10

Forest Plan Direction........................................................................................10

Public Involvement ..........................................................................................11

Issues..............................................................................................................11

Changes between the DEIS and the FEIS............................................................12

Chapter 2. Alternatives, Including the Proposed Action........................................13

Design Criteria Common to All Action Alternatives.............................................33

Monitoring Plan...............................................................................................51

Comparison of Alternatives...............................................................................54

Chapter 3. Affected Environment and Environmental Consequences....................58

Past, Present and Reasonably Foreseeable Actions...............................................58

Cultural Resources...........................................................................................62

Botany: Rare Plants and Noxious Weeds............................................................71

Geology/Soils..................................................................................................82

Lands/Special Uses/Recreation..........................................................................95

Terrestrial Wildlife...........................................................................................99

Terrestrial Wildlife Management Indicator Species...........................................131

Aquatic Wildlife and Management Indicator Species.........................................148

Range Management........................................................................................179

Hydrology/Water Quality................................................................................193

Forest Vegetation/Silviculture .........................................................................209

Fire/Fuels......................................................................................................230

Air Quality ....................................................................................................255

Engineering / Transportation ...........................................................................271

Engineering / Transportation ...........................................................................271

Economics.....................................................................................................274

Short-term Uses and Long-term Productivity ....................................................281

Unavoidable Adverse Effects ..........................................................................281

Irreversible and Irretrievable Commitments of Resources...................................281

Legal and Regulatory Compliance ...................................................................282

Chapter 4. Consultation and Coordination.........................................................287

Preparers and Contributors..............................................................................287

Distribution of the Environmental Impact Statement..........................................288

Glossary ............................................................................................................289
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest v Table of Contents 

Literature Cited.................................................................................................299

Index .................................................................................................................312

Appendices........................................................................................................313

Appendix A – Map Package for Greys Mountain Project....................................313

Appendix B – Best Management Practices Associated with Greys Mountain Project

....................................................................................................................314

Appendix C---Soils and Geology .....................................................................332

Appendix D – Data Tables for Greys Mountain Project......................................339

Appendix E – Proposed Treatment Acres..........................................................343

Appendix F -- Acronyms ................................................................................345

Appendix G – Response to Public Comments ...................................................346

Table of Tables

Table 1. Summary of proposed action treatments........................................................................... 9

Table 2. Meadows and WIN sites identified for restoration within the Project area (ND = no 

quantified measurement of encroachment). .............................................................................. 18

Table 3. Riparian Area Management Zones.................................................................................. 40

Table 4. Summary of Relationship between Riparian Area Criteria............................................. 41

Table 5. Streamside Management Zone designation by stream class ........................................... 44

Table 6. Roads that have hydrologically connected drain points and culvert problems in 

subdrainage 503.0056................................................................................................................ 46

Table 7. Comparison of the Components of the Alternatives ....................................................... 54

Table 8. Present and Reasonably Foreseeable Actions Contributing to Cumulative Effects by 

Resources this Action is likely to affect.................................................................................... 60

Table 9. Forest Service Sensitive Plant Species Known or with Potential to occur within the 

Greys Mountain Project Area.................................................................................................... 72

Table 10. Soil Map Units for the Greys Mountain Project............................................................ 83

Table 11. Soil families for the Greys Mountain Project................................................................ 84

Table 12. Soil transect summary for the Greys Mountain Project ................................................ 86

Table 13. Special Status species on the Sierra NF and a summary of their habitats, area of 

consideration, and rationale for inclusion/exclusion from detailed analysis within the project 

BE/BA. .................................................................................................................................... 100

Table 14. Action Alternatives Summary of changes to CWHR Forest Type within treatment units 

of the Greys Mountain Project ................................................................................................ 104

Table 15. Greys Mountain Project Proposed Treatment Units within California spotted owl PACs 

or HRCAs................................................................................................................................ 108

Table 16. Stand Attributes for units in California Spotted Owl PAC's and HRCA's.................. 110

Table 17. Greys Mountain Treatment Units within Northern Goshawk PAC’s.......................... 111

Table 18. Action Alternatives Summary of changes to CWHR Forest Type within the Boundaries 

of the Greys Mountain Project ................................................................................................ 136

Table 19. Summary of subwatershed conditions. *From project hydrologist review (Stone 2011).

................................................................................................................................................. 148

Table 20. Perennial streams (mi); resident trout occupancy (mi), mean summer water temperature 

(period 7/15-9/15), and maximum daily temperature (greatest mean daily period 7/15/9/15).149
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest vi Table of Contents 

Table 21. Summary of potential habitat within project area subwatersheds (acres based on GIS).

................................................................................................................................................. 155

Table 22. Activities proposed under Alternative 1...................................................................... 159

Table 23. Acres of habitat cumulatively affected under Alternative 1. (*lacustrine/riverine miles 

converted to acres assuming 9 ft wide stream)........................................................................ 164

Table 24 Gross acres from proposed activities by subwatershed................................................ 165

Table 25. Alternative 2 activities (acreages approximations generated by GIS). 

Riverine/Lacustrine and wet meadow habitats have Class I SMZ buffers (100 feet) with no 

direct affects anticipated. Affected miles or acres reflect treatments in the outer 50 feet....... 166

Table 26. Overlap of Proposed Treatment Areas and Potential Habitat for species. Thinned 

includes hand thin. (*lacustrine/riverine miles converted to acres assuming approximately 9 ft 

wide stream) ............................................................................................................................ 167

Table 27. Acres of habitat cumulatively affected under Alternative 2. (*lacustrine/riverine miles 

converted to acres assuming 9 ft wide stream)........................................................................ 173

Table 28. Effects from Greys Mountain Alternative 1 (No Action) on aquatic threatened, 

endangered, candidate, and sensitive species.......................................................................... 176

Table 29. Effects from Alternatives 2 and 3 on aquatic threatened, endangered, and sensitive 

species. .................................................................................................................................... 176

Table 30. Summary of ecological status data collected at two key area meadows within to the 

Greys Mountain Project Area.................................................................................................. 182

Table 31. Current Permitted Numbers and Season of Use for Soquel Allotment. ...................... 184

Table 32. Current Permitted Numbers and Season of Use for the Central Camp Allotment. ..... 186

Table 33. Allowable utilization levels by vegetation community ............................................... 187

Table 34. Desired conditions for montane meadows and riparian conservation areas................ 188

Table 35. Stream mile summaries for all 8th-field subdrainages potentially affected by project 

activities................................................................................................................................... 194

Table 36. List of priority roads that area causing impacts to watershed function by hydrologic 

connectivity. AOP stands for Aquatic Organism Passage....................................................... 199

Table 37. Points of hydrologic connectivity and stream crossings with high bypass potential. *A 

“Non-Functional Culvert” is one that has been identified as being 1⁄2 plugged to completely 

plugged or buried..................................................................................................................... 200

Table 38. Calculated base ERA % and ERA % with the Proposed Action or Alternative 3....... 202

Table 39. CWE results for post harvest prescribed fire in 2015. The baseline ERA% is prorated 

(i.e., “recovered”) for each year between actions. As a result, the baseline ERA% is somewhat 

reduced. ................................................................................................................................... 202

Table 40. Acres of activities proposed within project area subdrainages under Alternative 2 

(approximate maximum acres generated by GIS). .................................................................. 205

Table 41. Fire History within the Project Boundary ................................................................... 232

Table 42. Fire History Outside of the Project Boundary (within a 3 mile radius)....................... 232

Table 43. Adapted from How to Predict the Spread and Intensity of Forest and Range Fires. 

Richard C. Rothermel, 1983 and Rocky Mountain Research Station Fuel Models, Scott and 

Burgan, 2005 ........................................................................................................................... 239

Table 44. Rocky Mountain Research Station Fuel Models, Scott and Burgan, 2005 ................. 240

Table 45. Indicators for Fuel Models in Timbered Brush/shrub Covered Areas. ....................... 241

Table 46. Shows the predicted results of fuel model conversions anticipated with this Alternative.

................................................................................................................................................. 246

Table 47. Cumulative Effects: Past, Present and Reasonable Foreseeable Activity, summary. . 249

Table 48 Comparison of Fire Suppression and Effects Measured By Indicators........................ 254

Table 49.Sensitive receptors identified within 10 miles of the Greys Project............................. 257
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest vii Table of Contents 

Table 50.Federal de minimus Threshold Levels for Criteria Pollutants based on Air Basin 

attainment status...................................................................................................................... 259

Table 51. Class I airsheds near the Greys Project area................................................................ 261

Table 52 Statewide Emission Inventory for Natural Sources-Wildfire....................................... 264

Table 53 Potential emissions if a wildfire were to burn within the entire Greys Project boundary.

................................................................................................................................................. 265

Table 54 Tons of Estimated Pollutants per Individual Project-Annual Underburn Program of 

Work........................................................................................................................................ 265

Table 55 Total Emissions from All Prescribed Fire Treatments Proposed in this Action (in tons)

................................................................................................................................................. 267

Table 56 Total tons of emissions for mechanical treatments and road maintenance-reconstruction 

activities for the completion of operations in Alternative 2. ................................................... 268

Table 57 Emissions conformity to General Conformity Rule for Criteria Pollutants................. 268

Table 58. Greys Mountain economic analysis for alternative 2 .................................................. 276

Table 59. Greys Mountain economic analysis for alternative 3 .................................................. 278

Table 60. Full time Job relationship to specific project tasks...................................................... 280

Table 61. Soil disturbance class by percent present for each soil transect completed ................ 335

Table 62. Forest floor summary .................................................................................................. 335

Table 63. Forest slope summary.................................................................................................. 335

Table 64. Large woody debris (LWD) summary ........................................................................ 336

Table 65. Summary of meadow encroachment for the selected meadows in the Greys Mountain 

Project area.............................................................................................................................. 336

Table 66. Soil transect data for T units 1, 11, 12, 18 and 28....................................................... 337

Table 67. Soil transect data for T units 29, 30, 32, 35, and 36.................................................... 338

Table 68. Conifer Plot Data Tables............................................................................................. 341

Table 69 Proposed Treatment Acres by Area and Method ......................................................... 343

Table of Figures

Figure 1. Locations of meadow restoration sites within the Greys Mountain ERP (note: Meadows 

504M292 and 293 have been combined into one site). ............................................................. 20

Figure 2. Map of WIN 51015 in meadow 504M292 and 504M293; red triangles denote main 

WIN features. ............................................................................................................................ 22

Figure 3. Map of WIN 51036 in Poison Meadow (meadow 504M209); red triangle denotes main 

WIN features. ............................................................................................................................ 23

Figure 4. Map of WIN 51037 in meadow 504M211; red triangles denote main WIN features.... 24

Figure 5. Map of WIN 51038 in Meserve meadow (meadow 504M132); red triangles denote main 

WIN features. ............................................................................................................................ 25

Figure 6. Map of WIN 51104 in Progeny meadow (Meadow 503M8); red triangles denote WIN 

features. ..................................................................................................................................... 26

Figure 7. Map of WIN 51241 in Chipmunk meadow (Meadow 504M220); red triangle denotes 

main WIN feature...................................................................................................................... 27

Figure 8. Map of WIN 51244 in meadow 504M208; red triangles denote main WIN features.... 28

Figure 9. Map of WIN 51246 in Railroad meadow (Meadow 504M198); red triangles denote 

WIN features. ............................................................................................................................ 29

Figure 10. Map of WIN 51295 in meadow 504M7; red triangles denote main WIN features; 

darker green polygons represent the true meadow components................................................ 30
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest viii Table of Contents 

Figure 11. Map showing the alignment of the OHV track through meadow 503M7. This track will 

be restored to improve soil productivity and allow for native vegetative recovery. ................. 31

Figure 12: Associated Bounds and Treatments within Old Forest Linkages ................................ 40

Figure 13. Associated Bounds and Treatments within Old Forest Linkages ................................ 44

Figure 14. Points of hydrologic connectivity and bypass potential along system roads in 

subdrainage 503.0056. Repair of the crossings (i.e., culverts) and relocation of the 

hydrologically connected drain points should be part of the road maintenance plan for 06S0. 47

Figure 15. Looking down cultural resource boundary within Greys Mountain Ecological 

Restoration Project area; previously treated unit to left of pine in center of photo; cultural 

resource site with heavy fuel loading to right of pine. .............................................................. 64

Figure 16. Locations of Noxious Weeds within the Greys Mountain Project Area. ..................... 76

Figure 17. Occupied mountain yellow-legged frog (brown triangles indicating RAMU) in relation 

to Greys Mountain project treatment units.............................................................................. 169

Figure 18. Allotment boundaries and meadows with proposed restoration within the project area.

................................................................................................................................................. 181

Figure 19. Location of Greys Mountain Project in relation to the Willow Creek 5th-Field 

watershed................................................................................................................................. 195

Figure 20. Stream Side Management Zone (SMZ) and subdrainage map of the Greys Mountain 

Project Area. Color-coded lines represent different stream orders, which are offered a 

protection buffer based on designated class. ........................................................................... 196

Figure 21. Yield Tables for Ponderosa Pine from Meyers Bulletin 630. .................................... 213

Figure 22 Displays stand thinning needs over time as basal increases........................................ 214

Figure 23. Example of thinning release....................................................................................... 219

Figure 24. Hauling Chart displaying modeled surface fire behavior by fuel models for each 

project alternative.................................................................................................................... 248

Figure 25. Step-pools built into two narrow headcuts at the toe of Summit Meadow, Sierra 

National Forest. ....................................................................................................................... 329

Figure 26. . Log-and Fabric Step-Falls used for headcut mitigation, Johnson Meadow, Sierra 

National Forest. ....................................................................................................................... 330

Figure 27. Greys Mountain Project selected meadows for conifer encroachment...................... 332

Figure 28. Greys Mountain Project soil transects........................................................................ 333
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest ix Summary

Summary

The Sierra National Forest (SNF), Bass Lake Ranger District (BLRD) proposes to restore 

ecological structure and function to create a resilient landscape that can better withstand future 

disturbances and continue to provide sustainable ecosystem services for future generations. To 

accomplish this goal, the SNF BLRD proposes several restoration objectives aimed at promoting 

native biodiversity and ecosystem resilience in the Greys Mountain Project area. The Greys 

Mountain Project would restore the ecological processes and forest heterogeneity through a series 

of prescribed fire and thinning treatments aimed at reducing ladder fuels and dead and down fuel 

loads. Another objective is to create a network of landscape area treatments and defensible fuels

profiles near key transportation corridors to reduce the intensity and rate of spread of wildfires

across the landscape and near communities. A third objective is to improve stand resistance to 

drought, insects, and disease by reducing inter-tree competition and improving tree vigor. 

Growth rates of residual trees would increase resulting in larger diameter, taller trees developing 

over shorter periods of time. Proposed treatments would increase the percentage of shade 

intolerant conifers (pines) and oaks in treated stands helping to return stand composition more 

closely to historical conditions prior to railroad logging. Montane meadow restoration would be 

accomplished in targeted hydrologic systems through a combination of treatments, including 

improvements to degraded hydrologic features, encroaching conifer removal, and noxious weed 

management. Proposed treatments would restore culturally-significant vegetation and protect 

important historic and cultural resources threatened by uncharacteristically severe wildfire. .

The area affected by the proposal includes 9600 total project boundary acres within the mid to 

upper elevations of the Willow Creek and Fresno River watersheds, in the Southern Sierra 

Nevada. The project is immediately north of the community of Bass Lake, California and south of 

Soquel Meadow, east of Nelder Grove Historical Area and west of Graham Mountain. Vegetation 

types include ponderosa pine plantations, mixed conifer, true fir, and hardwood species, as well 

as areas dominated by brush/shrubs, herbs and grasses (meadows), rock, and steep slopes. 

This action is needed, because under the amended SNF-LRMP (Sierra Nevada Forest Plan 

Amendment [SNFPA], Record of Decision [ROD], USDA-FS 2004), an ecosystem approach to 

project development and planning is recommended. Where there are significant departures from 

the desired condition or potential for a loss in key ecosystem functions, opportunities for 

management actions to address this departure were developed. An emphasis on the interrelationship of the major functional program goals was placed on these opportunities. Of 

particular concern was the Willow Creek watershed with its highly departed ecological condition 

and its importance in providing valuable ecosystem services and community benefits to meet the 

ecological, social, and economic needs of the public. 

Current forest conditions, due to past management activities (including railroad and other 

harvesting operations, fire exclusion/suppression, housing development, etc.) have been changed 

from one of more open, drought resistant, pine dominated stands where fires were of frequent, 

low/ moderate intensity to infrequent, high intensity to even aged young growth, more fir and 

incense cedar dominated, fire excluded stands. Owing to these changes, forest stands have 

become less diverse, more homogenous, and more susceptible to uncharacteristically severe 

wildfire and drought. Current forest stands are typified by an overabundance of shade-tolerant

conifer species. Other areas have converted from forested stands to brush/shrub species. This 

overstocking of conifers has led to a decline in forest health and high susceptibility of loss from 

insects, disease, wildland fire, and climate change.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest x Summary

A variety of wildlife species are highly dependent on conditions provided by functioning and 

intact ecosystems, including, Pacific fisher, California spotted owl and Northern goshawk., 

These species are highly susceptible to habitat loss and fragmentation caused by wildfire, insect 

and disease outbreaks, past logging practices, and changing climate. Although there is inherent 

uncertainty (due to gaps in information) surrounding habitat management of these sensitive 

species, , the vulnerability of these habitats to future stressors can be reduced through the 

implementation of ecological restoration treatments focused on improving ecosystem resilience, 

retaining key habitat structures (large live trees and snags), and restoring important forest 

characteristics (heterogeneity, fire-resilient tree species).

 Alternative 1 – No Action. Under the No Action alternative, current management 

plans would continue to guide management of the project area. No ecological restoration 

activities would be implemented to accomplish the purpose and need. 

 Alternative 2 – Proposed Action. Treatment areas within the project area boundary 

were delineated to include those areas where some form of treatment was necessary to 

meet the purpose and need. First, treatment areas were designed to reduce the intensity 

and spread of wildfires in and around WUI. Treatment areas near key transportation 

corridors and within the defense zone of the WUI were designed next. Treatment areas 

were further designed to meet several additional ecological restoration objectives: (1) 

restoration of forest structure and composition (forest heterogeneity and biodiversity is 

promoted using prescribed burning and mechanical thinning) (2) fire and fuels 

management(treatments are designed to reduce ladder and surface fuels that occur within 

the lower and limited mid-level canopy); (3) wildlife habitat and watershed restoration 

(enhancement and retention of key habitat structures, meadow restoration), (4) forest 

health and ecological resiliency (overstocked stands are thinned in the lower- and midlevel canopy to promote resilience to changing environmental conditions resulting from 

insects, disease, wildfire, and drought; and (5) invasive species management (eradication 

or containment of noxious weed populations). 

 Alternative 3 – Lower and Limited Mid-level Canopy Treatments, All 

Treatment Areas. In Alternative 3, treatment areas would remain the same as in 

Alternative 2, treatments within these areas would include only those needed to reduce 

the surface and ladder fuels (within the lower and limited mid-level canopy levels) 

needed to achieve fire and fuels objectives. Under Alternative 3 there would be no 

additional treatments (i.e. additional thinning in the mid-level canopy) to fully address 

stand density and forest health objectives. 

This alternative would receive treatment only to achieve fire and fuels objectives and 

limit treatments to mechanical clearing of ladder and surface fuels and prescribed 

burning. 

A summary of effects are in the following table. See chapter 3 of this document 

for the full discussion of effects.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest xi Summary

Summary of Effects by Alternative

Resource Area Indicator Alt 1 Alt 2 Alt 3

Cultural Resources The degree to which 

historic property 

values are 

diminished.

Cultural resource 

sites have the 

potential to be 

adversely affected 

if an 

uncharaceristically 

severe wildfire was 

to occur from 

untreated fuel 

accumulations. 

Artifact looting 

could occur from 

increased access 

and visibility of 

sites resulting from 

an 

uncharacteristicall

y severe wildfire 

Cultural site 

context could be 

affected by post 

fire runoff and 

erosion, increased 

tree mortality, and 

increased rodent 

and insect 

burrowing. 

Cultural resources 

could be affected 

by lack of road 

maintenance.

Cumuluative 

effects could result 

from failure to 

address fuel 

loading within 

cultural resource 

sites which could 

result in adverse 

effects from a 

severe wildfire.

By following the Stipulations 

and implementing the 

Standard Protection Measures 

outlined in the Regional PA, 

Attachment B and the Interim 

Fuels Protocol, following 

design measures, and 

consulting with SHPO to 

develop mitigations for 

potential adverse effects, the 

historic property values of 

sites would not be diminished 

as a result of implementing 

this alternative.

Artifact looting could occur 

from increased access and 

visibility of sites resulting 

from an uncharacteristically 

severe wildfire or through 

mechanical treatment and 

prescribed burning within 

sites. Cultural site context 

could be affected by post fire 

runoff and erosion, increased 

tree mortality, and increased 

rodent and insect burrowing 

should a severe wildfire occur. 

Cumulative effects could 

occur post implementation in 

the form of increased visibility 

and looting, but would be 

minimal through postimplementation monitoring 

and appliction of Standard 

Resource Protection Measures 

of the Regional PA.

By following the Stipulations 

and implementing the Standard 

Protection Measures outlined in 

the Regional PA, Attachment B 

and the Interim Fuels Protocol, 

following design measures, and 

consulting with SHPO to 

develop mitigations for potential 

adverse effects, the historic 

property values of sites would 

not be diminished as a result of 

implementing this alternative.

Artifact looting could occur from 

increased access and visibility of 

sites resulting from an 

uncharacteristically severe 

wildfire or through prescribed 

burning within sites. Cultural 

site context could be affected by 

post fire runoff and erosion, 

increased tree mortality, and 

increased rodent and insect 

burrowing should a severe 

wildfire occur. 

Cumulative effects could occur 

post implementation in the form 

of increased visibility and 

looting, but would be minimal 

through post-implementation 

monitoring and appliction of 

Standard Resource Protection 

Measures of the Regional PA.

Botanical TES

*Other plant species 

do not have habitat 

within the project 

area, therefore will 

not be impacted by 

any of the 

alternatives.

Determinations for TES species

No effect 1 Threatened 

species 

Calyptridium 

pulchellum

1 Threatened species on SNF 

(not in Greys Mountain 

Project)

Calyptridium pulchellum

1 Threatened species on SNF

(not in Greys Mountain Project)

Calyptridium pulchellum

May affect but is 

not likely to 

adversely affect 

N/A N/A N/A
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest xii Summary

Resource Area Indicator Alt 1 Alt 2 Alt 3

May affect 

individuals, but is 

not likely to result 

in a trend toward 

Federal listing or 

loss of viability 

(includes 3 species 

known to occur in 

project area and 

others that might 

occur but are 

protected by project 

design features for 

riparian and aquatic 

areas)

8 Sensitive species

Bruchia bolanderi 

Collomia 

rawoniana

Epilobium howellii

Fissidens 

aphelotaxifolius 

Hulsea brevifolia

Lewisia disepala

Meesia triquetra

Peltigera 

hydrothyria

8 Sensitive species

Bruchia bolanderi

Collomia rawsoniana

Epilobium howellii

Fissidens aphelotaxifolius 

Hulsea brevifolia

Lewisia disepala

Meesia triquetra

Peltigera hydrothyria

8 Sensitive species

Bruchia bolanderi

Collomia rawsoniana

Epilobium howellii

Fissidens aphelotaxifolius 

Hulsea brevifolia

Lewisia disepala

Meesia triquetra

Peltigera hydrothyria

Noxious Weeds Potential for 

noxious weed 

spread, number of 

infestations and 

number of plants 

per infestation. 

Increased risk of 

spread if wildfire 

was to occur in the 

area and fireline 

equipment does 

not follow Noxious 

Weed Prevention 

Practices (e.g. 

under extreme 

emergency no time 

for equipment 

cleaning), also 

control of existing 

infestations would 

not occur. 

Low risk of spread through 

use of project design criteria 

for prevention of spread as 

well as the fact that the 

proposed action includes 

controlling existing weed 

infestations.

Low risk of spread through use 

of project design criteria for 

prevention of spread as well as 

the fact that the proposed action 

includes controlling existing 

weed infestations.

Soils/Geology Potential for 

reduction in Soil 

porosity due to 

compaction

Compacted soils 

(in 1.51 percent of 

the project area) 

would continue to 

recover over time 

with no additional 

disturbance. 

Design Measures would 

minimize detrimental 

compaction of soils.

Design Measures would

minimize detrimental 

compaction of soils.

Soil Cover 

Remaining (Large 

Woody Debris)

Meets and/or 

exceeds current 

Soil Management 

Objectives

Reduction, but would continue 

to meet and/or exceed Soil 

Management Objectives

Reduction, but would continue to 

meet and/or exceed Soil 

Management Objectives
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest xiii Summary

Resource Area Indicator Alt 1 Alt 2 Alt 3

Lands/Special Uses Effects to Special 

Uses Permitted in 

Project Area.

No Effect With implementation of 

Design Criteria minimal to No 

effect

With implementation of Design 

Criteria minimal to No effect

Terrestrial Wildlife

(T)=Threatened 

(E)=Endangered 

(P)=Proposed 

(C)=Candidate 

(FSS)=Forest Service 

Sensitive

*Listed below are 

species that do not 

have habitat within or 

adacent to the project 

area, nor are directly, 

indirectly or 

cumulatively effected 

by this project 

therefore the project 

would have No 

Effect on them:

Valley Elderberry 

Longhorn Beetle

Desmocerus 

californicus 

dimorphus (T)

Bald Eagle 

Haliaeetus 

leucocephalus (FSS)

Wolverine Gulo 

gulo(FSS, C)

Willow Flycatcher

Empidonax trailli 

(FSS)

Sierra Nevada red 

fox Vulpes vulpes 

necator (FSS) 

Townsend’s bigeared bat 

Corynorhinus 

townsendii (FSS)

Determinations for 

TECPS Species

No effect.

May affect but is 

not likely to 

adversely affect. 

May affect 

individuals, but is 

not likely to result 

in a trend toward 

Federal listing or 

loss of viability.

Alternative 1 

would have no 

direct effect on any 

TECSP species or 

their habitats.

However, by 

taking no action to 

reduce fuel levels, 

the threat of large 

scale, standreplacing wildfires 

would remain 

unabated, and if 

such an event 

occurs, there could 

be significant 

detrimental 

impacts to TECPS 

species.

Alternative 2: May affect 

individuals, but is not likely to 

result in a trend toward 

Federal listing or loss of 

viability.

California Spotted Owl Strix 

occidentalis occidentalis 

(FSS)

Great Gray Owl Strix 

nebulosa (FSS)

Northern goshawk Accipiter 

gentilis (FSS)

Pallid bat Antrozous pallidus

(FSS)

Western red bat Lasiurus 

blossevillii (FSS)

American marten Martes 

americana (FSS)

Pacific fisher Martes pennanti

pacifica (FSS)

Alternative 3: May affect 

individuals, but is not likely to 

result in a trend toward Federal 

listing or loss of viability.

California Spotted Owl Strix 

occidentalis occidentalis (FSS)

Great Gray Owl Strix nebulosa

(FSS)

Northern goshawk Accipiter 

gentilis (FSS)

Pallid bat Antrozous pallidus

(FSS)

Western red bat Lasiurus 

blossevillii (FSS)

American marten Martes 

americana (FSS)

Pacific fisher Martes pennanti

pacifica (FSS)
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest xiv Summary

Resource Area Indicator Alt 1 Alt 2 Alt 3

Aquatic Wildlife TES 

*Listed are species 

that do not have 

habitat withinor 

adacent to the project 

area, nor are directly, 

indirectly or 

cumulatively effected 

by this project 

therefore the project 

would have no effect 

on them:

Central Valley 

Steelhead (T)

Delta smelt (T)

Hardhead (FSS)

California Red 

Legged Frog (T)

Limestone 

Salamander (FSS)

Relictual slender 

salamander (FSS)

FYLF (FSS)

Western Pond 

Turtle(FSS)

Moutain Yellow 

Legged Frog 

(C/FSS)

Yosemite Toad 

(C/FSS)

May affect 

individuals, but is 

not likely to result 

in a trend toward 

Federal listing or 

loss of viability 

N/A

Moutain Yellow Legged Frog 

(C/FSS)

Yosemite Toad (C/FSS)

Moutain Yellow Legged Frog 

(C/FSS)

Yosemite Toad (C/FSS)
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest xv Summary

Resource Area Indicator Alt 1 Alt 2 Alt 3

Aquatic 

Management 

Indicator Species 

Habitat conditions 

or alteration of 

species CWHR 

(California Wildlife 

Habitat Relations)

Lacustrine/Riverin

e: Stream Surface 

Shading, Flow, and 

Sediment

Wet Meadow: Flow

Lacustrine/Riverin

e Habitat 

Wet Meadow 

Habitat 

No expected 

direct, indirect or 

cumulative effects 

to habitat. 

Habitat stable at 

Regional scale

Lacustrine/Riverine Habitat: 

Direct or indirect effects to 

Stream Surface Shading and 

Flow not anticipated. 

Wet Meadow Habitat: Project 

Design Criteria expected to 

maintain habitat. No direct, 

indirect, or cumulative effect 

to Flow.

Both habitat types stable at 

Regional scale.

Lacustrine/Riverine Habitat: 

Direct or indirect effects to 

Stream Surface Shading and 

Flow not anticipated. 

Wet Meadow Habitat: Project 

Design Criteria expected to 

maintain habitat. No direct, 

indirect, or cumulative effect to 

Flow.

Both habitat types stable at 

Regional scale.

Terrestrial 

Management 

Indicator Species 

*Listed below are 

species that do not 

have habitat within or 

adacent to the project 

area, or species 

whose habitat would 

not be direcrtly or 

indirectly affected by 

the project:

Greater sagegriouse

(Centrocercus 

urophasianus)

Mule deer

(Odocoileus 

hemionus)

Yellow warbler

(Dendroica petechia)

Sooty grouse

(Dendragapus 

obscurus)

Black-backed 

woodpecker

(Picoides arcticus)

Habitat conditions 

or alteration of 

species CWHR 

(California Wildlife 

Habitat Relations)

All terrestrial 

MIS.

No direct effects to 

MIS habitat from 

Alternative 1. 

Largest indirect 

effect on species 

habitat would be 

loss or alteration 

created by 

uncharacteristicall

y severe wildland 

fire.

Fox sparrow (Passerella 

iliaca)

Mountain quail (Oreortyx 

pictus)

California spotted owl (Strix 

occidentalis occidentalis)

American marten (Martes 

americana)

Northern flying squirrel 

(Glaucomys sabrinus)

Hairy woodpecker (Picoides 

villosus)

Although there would be 

alterations to canopy closure 

on 121 acres (approximately 

4 percent of the treatment 

area), these predicted changes 

would not alter the existing 

trend in the habitat at the 

project-level, nor would it lead 

to a change in the distribution 

of the aforementioned 

terrestrial MIS across the 

Sierra Nevada bioregion. 

Fox sparrow (Passerella iliaca)

Mountain quail (Oreortyx 

pictus)

California spotted owl (Strix 

occidentalis occidentalis)

American marten (Martes 

americana)

Northern flying squirrel 

(Glaucomys sabrinus)

Hairy woodpecker (Picoides 

villosus)

Although there would be 

alterations to canopy closure on 

53 acres (approximately 2

percent of the treatment area), 

these predicted changes would

not alter the existing trend in the 

habitat at the project-level, nor 

would it lead to a change in the 

distribution of the 

aforementioned terrestrial MIS 

across the Sierra Nevada 

bioregion.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest xvi Summary

Resource Area Indicator Alt 1 Alt 2 Alt 3

Hydrology Cumulative 

Watershed Effects 

(CWE’s)

Threshold Levels 

Reached

The only 

watershed 

considered a 

candidate for CWE 

response is 

subdrainage 

503.0056. Baseline 

ERA % for this 

subdrainage is high 

at 9.25%, which 

resulted from past 

timber harvest 

activity. With the 

no action 

alternative, no 

tractor related 

ground disturbance 

or prescribed fire 

would occur, 

which, (given 

sufficient time), 

would allow the 

subdrainage to 

recover and 

stabilize.

The baseline or existing 

condition of most of the 

subdrainages is below the 

Lower TOC %, but 

subdrainages 503.0056 and 

503.3051 are over their Lower 

TOC %. When adding in the 

proposed action, none 

exceeded the Upper TOC of 

14%. 

Alternative 3 treatment areas 

would remain the same as in 

Alternative 2 and thus baseline 

or existing condition of most of 

the subdrainages is below the 

Lower TOC %, but subdrainages 

503.0056 and 503.3051 are over 

their Lower TOC %. When 

adding in Alternative 3, none 

exceeded the Upper TOC of 

14%. 

Air Quality Degree of 

degradation of Air 

Quality from Smoke 

High degree of 

long lasting 

unhealthy to severe 

degraded air 

quality from 

potential 

uncontrolled 

wildfire(s).

With prescribed burning 

occuring on Air District 

designated affirmative Burn 

Days, only short-term impacts 

to air quality would occur in 

isolated areas.

Potential air quality impacts 

from wildfires would be 

reduced with less ground fuels 

available.

With prescribed burning 

occuring on Air District 

designated affirmative Burn 

Days, only short-term impacts to 

air quality would occur in 

isolated areas.

Potential air quality impacts 

from wildfires would be reduced 

with less ground fuels available.

Transportation 

System 

Effects of 

Transportation 

System 

With minimal 

maintenance there 

is a continued 

potential for loss 

of infrastructure 

investment from 

erosion, wet 

weather use and 

brush 

encroachment.

Roads not meeting acceptable 

Standards would be required 

to be have maintenance, or 

recontruction done for project 

implementation.

This can have the potential to 

reduce potential erosion 

problems caused by 

transportation corridors.

Implementation of BMP and 

erosion control measures 

would reduce the impacts of 

such construction.

See Alternative 2.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 1 Chapter 1

Chapter 1. Purpose of and Need for Action

Document Structure _________________________

The Forest Service has prepared the Greys Mountain Ecological Restoration Project (Greys 

Mountain Project) Environmental Impact Statement (EIS) in compliance with the National 

Environmental Policy Act (NEPA) and other relevant Federal and State laws and regulations. 

This EIS discloses the direct, indirect, and cumulative environmental impacts that would result 

from the proposed action and alternatives. The document is organized into four chapters: 

Chapter 1. Purpose and Need for Action: This chapter briefly describes the proposed action, 

the need for that action, and other purposes to be achieved by the proposal. This section 

also details how the Forest Service informed the public of the proposed action and how 

the public responded. 

Chapter 2. Alternatives, including the Proposed Action: This chapter provides a detailed 

description of the agency Proposed Action as well as alternative actions that were 

developed in response to comments raised by the public during scoping. The end of the 

chapter includes a summary table comparing the proposed action and alternatives with 

respect to their environmental impacts.

Chapter 3. Affected Environment and Environmental Consequences: This chapter describes 

the environmental impacts of the proposed action and alternatives. 

Chapter 4. Consultation and Coordination: This chapter provides a list of preparers and 

agencies consulted during the development of the environmental impact statement. 

Appendices: The appendices provide more detailed information to support the analyses 

presented in the environmental impact statement.

Index: The index provides page numbers by document topic.

Additional documentation, including more detailed analyses of project area resources, may be 

found in the project planning record located at BLRD office in North Fork, California.

Background ________________________________

The Sierra National Forest (SNF)-Land and Resources Management Plan (LRMP) 1991 was 

amended in 2001 by the Sierra Nevada Forest Plan Amendment (SNFPA) Record of Decision 

(USDA-FS 1992, 2001b). Standards and Guidelines for project planning were to focus on the 

modification of fire behavior through fuels treatments. These treatments were to have the highest 

priority in areas described as Wildland Urban Interface/Intermix (WUI), (see map book; Map 2). 

In 2004, a Supplemental Environmental Impact Statement (USDA-2004a) was written to the 

SNFPA and a Record of Decision (ROD) was signed (USDA-FS 2004b). This ROD replaced the 

2001 decision in its entirety. This decision recommended an ecosystem approach whereby the 

development and planning of projects would be not only based on fuels reduction treatments, but 

would create an overall approach by looking at all key elements within an ecosystem. WUI 

continued to be the highest priority area for treatments. The 2004 SNFPA decision as it relates to 

the SNF has been incorporated into the SNF-LRMP as an amendment.

As part of the SNFPA ROD (USDA-FS 2004b), an adaptive management and monitoring strategy 

designed to address high priority, key questions that relate to the uncertainties associated with 

management activities was to be initiated. In 2006, Region 5 (Pacific Southwest Region) of the 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 2 Chapter 1

Forest Service, as well as other Federal and State Agencies, entered into an agreement with the 

University of California whereby the university would act as a neutral third party to studying the 

effects of management actions associated with implementation of the SNFPA ROD (USDA-FS 

2004) management direction. Focus was on the four key areas where the highest priority 

management questions exist (detailed and incorporated from SNFPA FEIS, Appendix E [USDAFS 2001] and SNFPA FEIS [USDA-FS 2004a]). These key areas include wildlife (specifically 

Pacific fisher/California spotted owl), fire and forest health, water quality and quantity, and 

public participation. Information from these studies was used to develop the alternatives (see 

Chapter 2).

Following management goals and direction from the SNFPA ROD (USDA-FS 2004b), treatment 

areas for the Greys Mountain Project were developed. These treatment areas were based on the 

basic fire and fuels strategy which remained in the SNFPA ROD (USDA-FS 2004b); reducing the 

risk of wildland fire to WUI and to effectively modify wildland fire behavior by strategically 

placing a pattern of area treatments (known in the SNFPA ROD (USDA-FS 2004b) as SPLATs, 

see map3) across broad landscapes. In addition, this strategy was broadened to include the need 

to consider and provide for other important objectives to improve forest health by restoring and 

maintaining ecosystem structure, composition and process. 

A network of land allocations, designated as part of the SNF-LRMP as amended, have an 

associated set of desired conditions, management intents, and management objectives. From 

standards and guidelines (referred to as S&G) management direction is provided for project 

planning and implementation. The vegetation and fuels treatment standards and guidelines are 

intended to (1) act as sideboards for local managers as they design projects to meet fuels and 

vegetation management objectives and respond to site-specific conditions, and (2) retain 

important components of habitat that are believed to be important to species associated with old 

forests, including large trees, structural diversity and complexity, and moderate to high canopy 

cover. At the project level, these standards and guidelines are used in conjunction with desired 

conditions, management intents, and management objectives for the relevant land allocation to 

determine appropriate treatment prescriptions (SNFPA ROD; USDA-FS 2004b).

The Greys Mountain Project lies within the mid to upper elevations of the Willow Creek and 

Fresno River watersheds. 

In June of 1995 the Minarets and Mariposa Ranger Districts (Later to become the Bass Lake RD) 

completed the Willow Creek Landscape Analysis. In the Willow Creek Landscape Analysis, the 

desired conditions for the ecological units that are within the project area are as follows: 

• Improve forest health,

• Manage for wildlife indicator species which are spotted owl and mule deer 

• Manage fuel loading to reduce risk of high intensity fire.

This area includes high concentrations of recreational activity and human habitation, adjacent 

forests suffer with declining health from overstocking and include habitat for species-at-risk (such 

as California Spotted Owl, goshawk and Pacific fisher).

Historical Conditions

During the period before significant Euro-American influence, natural fires and Native American

burning occurred frequently and were of low to moderate intensity with return intervals ranging 

from five to ten years in the Project area vegetation types. These types of fires produced fire 

effects of low to moderate severity throughout this ecosystem. Occasional patches of high 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 3 Chapter 1

severity fire effects did occur where pockets of heavier surface fuel loads and ladder fuels aligned 

with favorable slope, wind and aspect during drought conditions to induce mortality in larger 

conifer pockets. 

Wildfire history cartographic data beginning in 1910 show most wildfires have started and burned 

from the lower elevations around the Oakhurst Basin and Bass Lake Area up into the mid 

elevations of the Project area. At these elevations fuel models change. More favorable terrain and 

micro-site weather conditions moderated fire behavior and allowed fires to be controlled by early 

day suppression forces. Since the 1930s as forests on the district and within the project area 

continued to grow without frequent fires, they have become densely overstocked. 

Wildfires that burn in these areas today, burn at such levels that severe resource damage occurs, 

especially to soil layers. Once these soils are heavily damaged by fire, key ecosystem components 

can take longer to recover especially trees. Recent examples of this can be seen locally in the 

2001 North Fork Fire; the 2003 Source Point Fire; and the 2008 Oliver Fire. 

Nelder Grove, a historical area is adjacent to the northern border of the Greys Mountain Project 

area and is potentially impacted by a uncontrolled fire starting in or around the project area. 

Although there are no historical records of wildland fires reaching into the Nelder Grove 

Historical Area, fires could easily threaten the grove of giant sequoias based on topographic 

features of the area and given suitable burning conditions. 

The project area has a long history of past logging activities with the first lumber mill in Madera 

County beginning operation just east of Sivels Meadow at a place known as the Board Ranch in 

1852. From 1852 until 1927 various lumber mills processed timber logged from the area within 

the Project boundary. Railroad, cable and ground-based logging activities over this period 

removed approximately 7,500 to upwards of 21,000 board ft of timber per acre. A conservative 

estimate of 96,000,000 board ft of timber were removed by logging and have resulted in most of 

the forested areas consisting of trees less than 130 years of age. See Appendix A Map 19.

Project area stands, once composed of more openly spaced fire and drought resistant ponderosa 

and sugar pine; have become dominated by less fire resistant even aged, young growth white fir 

and incense cedar. There was no evidence of tree replanting activities following historic logging

and the current forest today is a result of young shade tolerant conifers such as white fir and 

incense cedar and scattered shade intolerant ponderosa pine and sugar pine growing once the 

mature dominant sugar and ponderosa pine forests were removed. 

Timber harvesting since 1927 has generally consisted of salvage/sanitation, overstory harvests 

and commercial thinning, with most occurring from 1970 to 1995. The regeneration harvest areas 

were reforested and are now established younger-aged conifer plantations intermixed within the 

natural stands that help create a mosaic of habitat diversity for wildlife. These areas are very 

important for maintaining this ecological diversity and need to be managed by maintaining 

conifer stocking and competing vegetation at levels that reduce moisture stress and improve 

levels of survivability during natural disturbance events and wildfire. 

Existing Condition

Hundreds to thousands of small trees per acre are common beneath stands of second growth white 

fir, sugar pine, incense cedar, and ponderosa/Jeffrey pine in the lower elevations and red fir in the 

higher elevations. These small understory trees consist of mostly shade tolerant incense cedar and 

white fir. These shade tolerant species have naturally reseeded into many areas where they are 

severely overstocked, create extensive fuel ladders or, in previously thinned areas, have created a 

dense layer of regeneration. Much of the regeneration is currently small in size; however without 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 4 Chapter 1

treatment it would grow into a dense even-aged understory with limited vertical heterogeneity. In 

addition this overstocking has created stands that can no longer successfully survive natural 

disturbances such as drought conditions, climate change, insects/disease attacks and/or wildfire. 

Changes to the forest structure by past logging and the lack of fire have been a compounding 

factor in causing poor ecosystem conditions within the Project area. 

The last century was unusually wet compared to prior centuries.1 This wetter than normal period 

coupled with the exclusion of fire has set the stage for forest stands and riparian structures to 

become overcrowded with competing conifers, oaks and other vegetation. Changes in weather

conditions over the past thirty years have placed stress on many of these stands, and future 

predictions are similar. Disturbance agents such as insects and disease are predicted to increase 

to epidemic levels due to the warmer climate. More intense weather events such as heavy snow 

storms, wind storms and intense droughts would create conditions that favor these disturbance 

agents. 

Inter-tree competition, drought, rising temperatures, and insect attacks are beginning to take a toll 

on both plantation and wild stands and are causing meadow systems to experience reductions in 

water holding capacity. White pine blister rust has also been causing mortality in sugar pine over 

the past 15 to 20 years. Dead and down surface fuel loadings have been rising at annual rates of 

approximately 1 ton per acre. Existing surface fuel loadings are from 10 to 80 tons per acre with 

most areas averaging 30-40 tons per acre. Fuel loadings of 10 tons per acre or less are the desired 

condition in the SNF LRMP. 

Water storage in meadows has a great influence over water quality, quantity, habitat potential, 

and forage within the meadow system and downstream riparian areas. Because montane meadows 

serve a vital role as water storage and release systems, it is essential that the hydrologic function 

of meadows be preserved, improved, or restored. Five meadows within the Project area are 

degraded because of accelerated erosion associated with past land use activities. Accelerated 

erosion results in gully formation, incised streams, head cuts and soil loss. This creates a lowered 

groundwater table and a change in soil moisture conditions throughout the meadow, which in turn 

promotes a favorable growing environment for conifers previously excluded by the meadow 

moisture. As the density of encroaching conifers increases, so does the rate of evapotranspiration, which continues to lower the groundwater table and encouraging even more conifer 

encroachment. This encroachment cycle (along with continued erosion) could eventually lead to 

the complete de-watering of the meadow system, severely impacting aquatic habitat, water 

quality, and water quantity. 

These meadows have all been degraded to the extent where the groundwater tables have been 

lowered with compromised hydrologic function, and vertically and laterally unstable stream

systems. The resulting change in soil moisture conditions has resulted in conifer encroachment 

beyond the range of natural variability. Maintaining, improving or restoring hydrologic function 

in riparian areas such as meadows is necessary to meet the guidance set forth in the Sierra 

National Forest Land and Resources Management Plan (SNF-LRMP USDA, 1991), as amended 

by the Sierra Nevada Forest Plan Amendment ROD (SNFPA USDA, 2004). The desired 

condition in accordance with the Forest Plan as amended by the 2004 SNFPA is:

• Vertically and laterally stable stream channels with in the meadows

• No depletion of ground water due to encroaching conifers

• No impacts from roads/tacks/trails

 1 Sierra Nevada Forest Plan Amendment, Record of Decision, 2004.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 5 Chapter 1

• Minimal impacts from grazing

Forest stand structures and processes currently need to be restored to provide more quality 

wildlife habitat, specifically to improve the diversity and restore the fire cycle in the system as a 

process that is currently lacking. 

Local Native American tribes have historically utilized areas within the project boundary for 

gathering of culturally significant resources for multiple uses. The preferred method of 

management to improve the quantity and quality of this vegetation in the past has been fire.

Due to the policy of avoiding cultural resource sites for the past 30 plus years during project 

implementation, fuels have unnaturally built up within cultural resource sites; creating the 

potential for significant damage in the form of partial or total loss of the resources should a fire 

occur. Moreover, the increase in fuels has altered the original setting for most cultural sites. 

Several prehistoric sites that had exposed features, access to water resources, and a view shed that 

have been encroached by an understory that detracts from its setting by obscuring features and the 

view shed and has left the water resources difficult to access or has substantially decreased the 

amount of water available. Moreover, artifacts such as obsidian and features such as milling 

stations have been shown to be damaged by high intensity fire to the extent that the artifacts and 

features no longer contribute to the data potential of a prehistoric cultural resource. Due to this 

same policy, trees and brush within historic resources, including railroad grades, have grown 

substantially contributing to an altered setting and in some places have affected the integrity of 

the sites. For instance, the walls of through-cuts and the downslope of fill on railroad grades have 

been compromised where trees and their roots have grown through the side walls. When a tree 

falls, it often takes a part of the grade feature with it, thereby disrupting the design and solidity of 

the grade. The feature is no longer intact and often continues to degrade through erosion and 

undermining of the resource. The spatial distribution of features is also a key element in a site’s 

design. Where these features are obscured by underbrush or dense tree stands, a site’s design is 

masked. 

Man made features that are creating a degraded resource condition are forest roads in poor 

maintenance condition and user created vehicle trails that are not on the Sierra National Forest 

Travel Plan. These user created areas are a cause of high soil erosion during water runoff events 

which leads to reduced water quality and a reduction in soil production capacity. Unmanaged 

OHV use has resulted in unplanned roads and trails, erosion, watershed and habitat degradation 

and impacts to cultural sites; (“Four Key Threats Facing the Nation’s Forests and Grass Lands; 

USDA-FS June 2004). In March of 2010 the Sierra National Forest completed the Travel 

Management Final Environmental Impact Statement (FEIS), which amends SNF LRMP and 

implements the 2005 Travel Management Rule (36 CFR Part 212). This decision prohibits motor 

vehicle travel by the public, off designated National Forest Transportation System facilities 

(roads, motorized trails and areas) except as allowed by permit or other authorization (this 

prohibition would not apply to snowmobiles).
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 6 Chapter 1

Purpose and Need for Action__________________

The objectives for this project are:

• Protect human communities from moderate/high intensity wild fires as well as minimize 

the spread of wildfires that might originate in urban areas into the forested lands created 

by unnaturally high levels of fuel ladders and dead and downed fuels. 

• Improve resiliency in stands that are currently overstocked and are becoming more 

susceptible to attack from insects, diseases, drought conditions, and/or wildfire.

• Restore hydrologic function in five meadows that have vertically and laterally unstable 

stream systems and changed soil moisture conditions has resulted in conifer 

encroachment beyond the range of natural variability.

• Improve the quality and quantity of culturally significant vegetation which has 

deteriorated due to the absence and suppression of fire.

• Reduce the potential for undesirable damage from high intensity fire behavior to 

historical sites which are over grown with dense conifers and high fuels loads. 

• Reduce resource damage caused by user-created vehicle routes in undeveloped recreation 

sites causing offsite movement of soil into streams and riparian areas that is reducing 

water quality for downstream users.

• Improve forest health conditions in developed recreation sites which are in a distressed 

state with mortality occurring and threatening public safety. 

• Improve the integrity and characteristics that make cultural resources eligible for the 

NRHP by reducing fuels within cultural resource sites through hand thinning and piling 

with follow up burning, prescribed under burning, and mechanical treatments in an effort 

to reduce damage to the sites from the threat of intense forest fires, to decrease the 

potential for slope failure along railroad grades and stream channels, and to restore 

setting where setting in a key aspect of a site’s integrity.

Proposed Action ____________________________

Restoration treatments would: 

• Treat surface and ladder fuels (live and dead) to modify wildland fire spread and fire 

intensity levels. This is proposed to be completed by thinning of pre-commercial (1-10” 

dbh) and commercial (10”-30” dbh) conifers, mastication and hand- dozer piling/burning 

of dead and downed fuels. Treatment areas have been initially identified to provide a 

“strategic” means to modify intensity and rate of spread of wildland fires across the 

landscape and near communities. This is commonly known as the “SPLAT” 

(Strategically Placed Area Treatment) strategy. In addition to the SPLATS, other areas 

would be treated for the specific purpose of constructing and reconstructing a fuelbreak 

along the west portion of the project, creating defensible fuel profiles near key 

transportation corridors and within the Defense zones of the Wildland Urban Interface 

(WUI). Fire suppression capabilities are enhanced by modified fire behavior inside the 

WUI zones. SPLATS and fuelbreaks also provide a safe and effective area for fire 

suppression activities to occur. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 7 Chapter 1

When needed utilize prescribed fire within treatment areas as a tool to reduce natural and 

activity-generated fuels through pile burning understory and/or broadcast burning.

• Enhance heterogeneity in forest stand structure at both the stand and landscape scale. 

This is proposed to be completed using a combination of pre-commercial and commercial

thinning of conifers and hand-dozer piling/prescribed burning of fuels. Treatment areas 

will follow the principles outlined in the PSW-GTR-220, including the removal of 

overrepresented shade-tolerant conifers in the lower- and mid-level canopy to provide 

discontinuity in fuels along both horizontal and vertical fuel profiles, begin moving 

stands toward a more historical species composition, and increase forest resilience. 

Stand densities will be varied based on topography and natural site conditions. Cutting 

prescriptions will achieve ecological restoration goals of restoring stand structure 

consistent with an active fire regime.

• Reduce densities in overstocked conifer stands. This is proposed to be completed by 

commercially thinning from below (10”-30” dbh) pine, mixed conifer and fir stands and, 

where needed, precommercial (1-10” dbh) thinning the areas throughout the treatment 

areas. Additional treatments within SPLATs have been proposed where stands are 

densely stocked and thinning is needed to reduce this inter-tree competition. This 

proposal reduces stand densities within the lower and mid-canopy layers of the treated 

stands to sustainable levels enabling stands to better withstand fluctuations in temperature 

and precipitation, attacks from insects and diseases, and the effects of wildfires by 

creating sustainable stand densities.

• Tie restoration treatment areas and fuel breaks together in strategic locations. This is 

proposed to be completed by masticating over stocked conifer stands and brush/ shrub 

patches.

• Prepare sites within failed conifer plantations for conifer reforestation and future 

release needs. This is proposed to be completed by hand using planting bars, hoedads or 

mechanical augers. Conifer planting will be done by hand and release treatments will be 

done with hand tools such as Pulaski’s and McLeod’s.

• Reduce natural and activity generated surface fuel loads. Hand/ machine piling and 

burning, jackpot, and understory burning. The majority of the burning will occur in the 

commercial thinning areas and hand thin areas within the project. Six areas within the 

project boundary will be prescribed burn only treatments. 

• Treat infestations of noxious weeds. This is proposed to be completed by prescribe 

burning and/or manual methods such as hand pulling. Post treatment monitoring will be 

completed to ensure any new populations are dealt with promptly. 

• Restore production and enhance vitality of plant material. This is proposed to be 

completed by hand thinning and under burning.

• Improve the integrity and characteristics that make cultural resources eligible for the 

NRHP by reducing fuels within cultural resource sites. This is proposed to be 

completed by hand thinning and piling with follow up burning, prescribed under burning, 

and mechanical treatments in an effort to reduce damage to the sites from the threat of 

intense forest fires, to decrease the potential for slope failure along railroad grades and 

stream channels, and to restore setting where setting in a key aspect of a site’s integrity.

This project proposes to treat approximately100 acres of natural dead and down fuels and 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 8 Chapter 1

vegetation within cultural resources according to the unit prescription within which they 

are present

• Restore degraded meadows. This is proposed to be completed by reducing encroaching 

conifers by thinning and pile burning and understory burning along meadow edges and 

stabilizing areas of accelerated erosion with structures where necessary. The overall goal 

of meadow restoration is to improve, enhance or completely restore the hydrologic 

function of degraded meadow systems such that water storage and residence time is 

maximized, increasing annual water availability to riparian-aquatic systems, wildlife, and 

livestock.. Restoration of meadows within the project area will address the physical 

repairs and vegetation treatments, noxious weeds, maintenance levels of designated OHV

trails; user defined OHV track impacts, National Forest System (NFS) roads impacts, and 

improved grazing strategy. 

• Improve wildlife habitat by restoring key components such as large dbh snags, 

adequate quantities of coarse woody debris, and by promoting health and vigor of oaks 

and encouraging growth of larger dbh trees. This is proposed to be completed by 

girdling or topping trees for snag creation or using prescribed fire to create pockets of 

contiguous snags. Methods to achieve the desired level of CWD include falling and 

leaving trees ≥16”dbh, and recruitment of CWD through prescribed burning activities 

that will create some snags which will eventually fall over and contribute to CWD levels. 

Growth and vigor of oaks will be promoted where needed by clearing overtopping 

conifers. Commercial and precommercial thinning treatments will allow leave trees to 

increase in growth in both height and diameter. 

• Restore user defined vehicle tracks and roads not identified as designated trails or 

roads under the Motorized Travel Management Final Environmental Impact 

Statement (March 2010) to the natural setting. This is proposed to be completed by 

following established S&G mitigation methods that return these tracks and roads to the 

natural setting to prevent future vehicular traffic. Restoration would include 

barricading/blocking vehicle access.

• Improve and maintain existing forest transportation routes within the project. 

(“Restore degraded facilities” from scoping letter) This is proposed to be completed by 

replacing plugged or non-functioning culverts, grading of road surfaces to keep offsite 

soil movement to a minimum, develop and implement an intensive maintenance plan on 

designated OHV routes, replacing damaged or missing road signs and installing 

designated OHV trail markers and construct a short section of temporary road (0.25 

miles) for treatment area access. 

• Improve and maintain resources for range management activities. (“Restore degraded 

facilities” from scoping letter) This is proposed to be completed by maintenance of stock 

drives, reconstruction of drift fences and installation of cattle guards.

• Reduce conifer stand densities within developed recreation sites for public safety and 

increased stand resiliency. This is proposed to be completed by removing potential 

hazard trees and thinning to improve stand health. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 9 Chapter 1

Table 1. Summary of proposed action treatments

Proposed action Treatments Units of 

Measure 

Structural Restoration Treatments

Commercial 

Thinning Acres 1535

Mechanical Fuels and Vegetation Treatments Acres 882

Handwork Fuels and Vegetation Treatments Acres 124

Mastication Fuels and Vegetation Treatments Acres 318

Fuel Break Construction and Reconstruction Acres 325

Reforestation Acres 50

Meadow Restoration

(Conifer Removal) Acres 13

Meadow Restoration (WIN)

(Watershed Improvement Need Site Work) Acres 36

Developed Recreation Sites 

(Hazard Tree and Thinning) Acres 31

Cultural /Historical Site Restoration Acres 100

Noxious Weed Management Acres 10

Wildlife Habitat Restoration Acres 36072

Range Maintenance

 (Stock Drive) Miles 7.6

Road Maintenance Miles 56

Road Reconstruction Miles 20.3

Temporary Road construction Miles 0.25

Designated OHV Trail maintenance Miles 5.5

User Defined Vehicle Trail Reclamation Miles 0.42

Measure or Effect

Units of 

Measure 

Alternative 2

Proposed 

action

Process Restoration Treatments

Prescribed Fire 

(Initial Entry) Acres 596

Prescribed Fire 

(After structural restoration treatments have 

been completed)

Acres 1855

Total Process Restoration Acres 2451

 2 Acres of wildlife habitat would be improved through) 1. Reducing the risk of uncharacteristically severe

wildfires; And 2. Promoting stand heterogeneity of forest vegetation, thereby making it more resilient to 

natural disturbances, and enhancing native wildlife species habitat and diversity. 

Units of measure for proposed treatments are approximate. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 10 Chapter 1

Decision Framework _________________________

Given the purpose and need, the deciding official will review the proposed action, other 

alternatives, and their environmental consequences, in order to determine whether to implement 

the proposed action as described, select a different alternative or take no action at this time. 

Forest Plan Direction ________________________

The proposed action and alternatives are guided by the SNF-LRMP. The SNF is subdivided into 

land allocations (management areas) with established desired conditions and associated 

management direction (Standards and Guidelines). All applicable standards and guidelines for 

the allocations would be adhered to. In addition a portion of the standards and guidelines are 

incorporated as design criteria where there are project-specific requirements (see Chapter 2, 

Design Criteria Common to All Alternatives). Land allocations that are found within the Greys 

Mountain Project boundary are shown on either individual maps for the specific land allocation or 

on the Land Allocations-Map 4. These maps are in the Map Package in Appendix A and include:

Wildland Urban Interface/Intermix (both Defense and Threat Zones). This land 

allocation encompasses 4487 acres within the Greys Mountain Project boundary and is 

set in closest proximity to communities, areas with higher densities of residences, 

commercial buildings, and/or administrative sites with facilities. Of this acreage; 389 

acres are designated as Defense Zone3 and 4090 acres are designated as Threat Zone4

. 

There were no local site-specific adjustments made to these boundaries as allowed by 

SNFPA ROD (USDA-FS 2004b) and are the zones mapped in the SNFPA FSEIS 2004. 

Totals may not add exactly add up due to rounding errors.

California Spotted Owl Protected Activity Centers (PACs) and Home Range Core Areas 

(HRCA). This land allocation encompasses 3038 acres of the project area as suitable 

nesting habitat and nearly the entire Greys Mountain Project area is suitable foraging 

habitat. There are five PACs and nine associated HRCAs either entirely or partially 

within the project boundaries. The SNF-LRMP, as amended sets forth standards and 

guidelines for this land allocation that address mechanical treatments conducted to meet 

fuels management objectives in PACs located in the WUI defense zones and in threat 

zones where prescribed fire is not feasible and where avoiding PACs would significantly 

compromise the overall effectiveness of the landscape fire and fuels strategy (USDA-FS 

2004b, pgs. 59-61). 

Northern Goshawk PAC. This land allocation encompasses 338 acres of suitable nesting 

habitat within two PAC’s and nearly the entire Greys Mountain Project area is suitable 

foraging habitat. The SNF-LRMP, as amended sets forth standards and guidelines for 

this land allocation which are similar to those for California spotted owl PACs (USDAFS 2004b, pgs. 59-61). 

Fisher Conservation Area. This land allocation is designated in approximately 9600 acres 

within the Greys Mountain Project boundary. The standards and guidelines associated 

with this land allocation are as follows. Design measures to protect important habitat 

structures as identified by the wildlife biologist. Use mechanical treatments when 

 3 Defense Zones designated in the project extend 1⁄4 mile from private property lines. 4 Threat Zones designated in this project extend 1 1⁄4 miles out from the Defense Zone boundary.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 11 Chapter 1

appropriate to minimize effects on preferred fisher habitat elements. (USDA-FS 2004b, 

pgs. 61 & 62). 

Riparian Conservation Areas (RCA). This land allocation encompasses the entire Greys 

Mountain Project boundary because of the extensive stream network within the project 

boundary. 

Public Involvement __________________________

A Notice of Intent (NOI) to prepare an Environmental Impact Statement for the Greys Mountain 

Project was published in the Federal Register on July 15, 2011. The notice asked that comments 

on the proposed action be received no later than 30 days after the publication date. The scoping 

letter was sent on June 6, 2011 to residents within 1.5 mile radius of the project area, to members 

and groups in the Native American community and to publics expressing interest in the project. 

The project was also listed in the SNF Schedule of Proposed Actions. On June 25, 2011 the 

Forest Service held a public field trip to the project area. The scoping letter included an invitation 

to participate in the field trip and a news release announcing the public meeting was sent to the 

Sierra Star (local newspaper) on June 17, 2011. The public field trip was attended by one 

individual from the local community.

There were four respondents, all of whom raised concerns and issues regarding the proposed 

project. All of the responses are in the project record on file at the Bass Lake Ranger Station. 

Using the comments from the public, the interdisciplinary team developed a list of issues to 

address. A portion of these comments led to the development of Alternative 3. 

Issues _____________________________________

Comments from the public and other agencies were used to formulate issues concerning the 

proposed action. There were no comments received from members or groups from the Native 

American community. The Forest Service separated the issues into two groups: significant and 

non-significant. Significant issues were defined as those directly or indirectly caused by 

implementing the proposed action. Non-significant issues were identified as those: 1) outside the 

scope of the proposed action; 2) already decided by law, 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 (CEQ) NEPA regulations 

explain this delineation in Sec. 1501.7, “...identify and eliminate from detailed study the issues 

which are not significant or which have been covered by prior environmental review (Sec. 

1506.3)...” A list of non-significant issues and reasons why they were found non-significant may 

be found in the project record located at Bass Lake Ranger Station in North Fork, California. 

The Forest Service identified the following significant issues during scoping:

• Improper use of prescribed fire may put homes at risk.

Forest Service Response: Forest personnel are required to follow a suite of prescriptive 

measures to make sure prescribed fires do not put homes at risk. A summary of the fuels 

analysis and risk to communities can be found in Chapter 3, Fire/Fuels section of this 

document.

• Allow for opportunity of intense fire effects on the landscape.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 12 Chapter 1

Forest Service Response: Both action alternatives allow some areas of intense fire effects. 

A summary of the fuels analysis and potential for active crown fire can be found in 

Chapter 3, Fire/Fuels section of this document.

• Use fire as a treatment method on a greater scale rather than timber removal.

Forest Service Response: Current fire suppression policy under the National Fire Plan 

allows for wildfires on national forests to be managed for the most efficient and effective 

use of suppression resources however under the current SNF LRMP the Project area is in 

a land allocation that requires full suppression for all wildfires. 

• Removal of trees over 10” dbh is unnecessary for reducing potential for high intensity 

fire.

Forest Service Response: Both action alternatives respond to this issue. A summary of 

the fuels analysis and potential for active crown fire can be found in Chapter 3, Fire/Fuels 

section of this document.

• Removal of trees up to 30” dbh is unnecessary for fire/fuels management and for reducing 

fire severity.

Forest Service Response: Alternative 3 responds to this issue. See the Alternative 3 

description in Chapter 2 of this document. 

Changes between the DEIS and the FEIS

Based on both public comment and Forest Service review, changes were made between DEIS and 

FEIS. The following types of changes and clarifications were applied to the FEIS:

Data Omissions – In cases where omissions in data were identified by the Forest Service or the 

public, those omissions were fixed in the FEIS. Where data pertinent to the analysis was 

identified between DEIS and FEIS it was include and analyzed. 

Corrections and Edits – Where typos or errors were identified they were corrected. 

Clarifications – Public comment inspired the clarification of items in many sections of the FEIS. 

These clarifications ranged from adding a few words to help the reader more fully understand the 

content and rationale of a section to changing the treatment methods for two areas and creation of 

two new maps. The following proposed treatment areas were modified to a less intensive 

treatment method after public comments showed the land allocation provided only prescribed fire 

as a treatment:

T-18 and FX-9 were originally planned for precommercial and commercial thinning by hand and 

or mechanical methods but the WUI land allocation was removed during the planning process 

after field verifications showed the private property did not meet the WUI criteria. After the land 

allocation was changed the treatments proposed were inadvertently not modified to reflect this 

change. Public review of the DEIS pointed out this error and the treatments were changed to 

correct method that was allowed for that land allocation which was prescribed burning only. 

Additions in Response to Comments –These comments were evaluated and the reasons 

proposed alternatives were not included in the FEIS were explained. The proposed alternatives 

were included in the Alternatives Considered but Eliminated from Detailed Study in Chapter 2. 

Appendix E was created to display proposed treatments and acreage by area. More information 

regarding the effects of Alternatives 2-3 has been brought forward from the BA/BE to make the 

FEIS a more clear and informative summary of the BA/BE analysis. This includes providing 

more of the BA/BE direct, indirect and cumulative effects information for Alternatives 2-3. Map 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 13 Chapter 1

18 and 19 have been created and added into Appendix A Map package as requested by 

commenter’s Edits and corrections to maps that displayed treatment area boundaries drawn on 

private lands have been made. Additional citations have been added in the Vegetation Section 

related to stocking levels, drought, insect and other stressors on trees as newer information is now 

available. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 13 Chapter 2

Chapter 2. Alternatives, Including the 

Proposed Action

Introduction

This chapter describes and compares the alternatives considered to meet the purpose and need of 

the Greys Mountain Project. It describes a no action alternative and two action alternatives in 

detail as well as those eliminated from detailed study. The end of this chapter presents the 

alternatives in tabular format so that the alternatives and their environmental impacts can be 

readily compared.

Alternatives Considered in Detail

The Forest Service is required to analyze a no action alternative. The proposed action and two 

additional alternatives were considered in detail. These included the no action alternative, and a 

Lower and Mid-Level Canopy Treatment alternative (the non-commercial funding alternative), 

which focused on limiting the quantity of material removed to just that needed to meet fire and 

fuels objectives in all treatment areas. This alternative was developed to address, in part, the key

issue #4 which was that removal of trees larger than 10 inches dbh would not reduce high 

intensity fires as in the proposed action. 

An adaptive management study known as Sierra Nevada Adaptive Management Study (SNAMP),

which studies Pacific fisher, focuses on an area directly west of the Greys Mountain Project. As

the Greys Mountain Project falls within the Pacific fisher habitat zone, knowledge gained by the 

SNAMP project was utilized in the design of the Greys Mountain Project. Information used in 

developing the project alternatives includes: current movement patterns and 2008 through 2011

denning sites (both birthing and maternal) of Pacific fisher that have been radio collared and 

intensively monitored within and outside of the project area, and information about what type of 

habitat conditions are preferred by denning females. Protection measures in light of this new 

information were incorporated into the design measures for both action alternatives.

Alternatives would adhere to the suite of standards and guidelines to selectively maintain and 

develop these habitats of large coniferous trees, hardwoods, overstory canopy gaps, tree group 

retention areas, understory vegetation retention areas, and conifers with structural defects in 

accordance with the LRMP as amended. Adherence to the required standards and guidelines 

would help ensure that the native wildlife populations would be sustained over the long-term, 

while also meeting other forest management goals and mandates, such as fuels management, 

forest health, and commodity production. 

Tree Removal Methods

Under both action alternatives, implementation of thinning strategies would be accomplished 

using mechanical and hand treatments to remove excess fuels, reduce stand densities, and restore 

large tree dominance, species composition and heterogeneity. These treatments consist of: 

1. Commercial thin consists of two methods of commercial tree removal are envisioned in the 

alternatives. Commercial tree harvest is envisioned within the project area. This method 

involves manual tree felling followed by skidding the logs to the landing. With this method limbs 

and tops are removed in the woods and left. Mechanical tree removal uses harvesting machines 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 14 Chapter 2

to remove commercial-size trees greater than 10 inches dbh. Once felled whole trees are skidded 

to the landing where they are limbed and topped via a de-limbing machine. The residual limbs 

and tops remaining are piled and either burned or potentially available for biomass removal if 

circumstances allow. Commercial-size trees are hauled to a process mill and converted to lumber 

and generate revenue, while small biomass material is hauled to an electrical generation plant. 

Biomass removal requires appropriated funds. Harvest of commercial-size trees is done using 

ground based vehicles with rubber tires or tracks. These vehicles are often called skidders and 

are equipped with grapples or cables to transport trees or logs to a landing. Tractor logging occurs 

in areas with road systems and slopes that are consistently less than 35 percent slope. Some small 

areas over 35 percent slopes are also treated in this manner. 

2. Pre-commercial thin of smaller sized trees less than 10 inches dbh for density management and 

fuel ladder reduction needs. These thinnings will be completed by hand with chainsaws and 

mechanically by mastication. Fuels created by these operations will be piled and burned and or 

underburned with prescribed fire. 

3. Mechanical mastication (shredding) of biomass and fuels is typically accomplished by a 

mastication cutting head mounted on an articulating arm on a track-laying, low ground pressure 

vehicle. The cutting head chops the vegetation to a height of approximately 1-2 inches above 

ground height. The equipment is able to treat vegetation on slopes up to 55 percent while having 

little ground impact. The debris is left on the ground where it rapidly decomposes and provides 

erosion protection while it is decomposing, or it is burned after it has dried out.

4. Hand cutting (also called pre-commercial thinning) involves the felling of unwanted trees, 

either with a chain saw or a machine feller, for burning in place or in preparation for piling. 

5. Mechanical (tractor) piling of fuels for prescribed burning involves using heavy equipment to 

scrape slash and other debris into piles for burning.

6. Lop and Scatter involves cutting the limbs from felled trees and scattering them in the general 

area where the trees were cut to allow the nutrients from the branches to be returned to the soil. 

Fuel Treatment Methods

Upon completion of the tree removal work FS personnel would apply prescribed fire to the area 

by using either pile burning or understory burning of pretreated stands to reduce activity-created 

slash and natural downed woody fuels. RX 1, 2, 3, 4, 5, 6, 7, 15, 22, 23 and 24 are designated for 

only understory burning as a treatment. Acres of prescribed fire are located in Table 1. Initial 

fuels treatments (first entry of understory burning and the pile burning) would be completed after 

treatment on each unit, but the units may be treated in different years. Treatment areas planned 

for understory burning would have multiple entries but in the post harvest burn areas, only 1 entry 

is planned for in the time span of this NEPA document. Any further burning in these areas would 

require analysis in another NEPA document. In the understory burning area alone, two to three 

entries over the first 15 – 20 years of the project may be necessary to reach and maintain the 

desired condition. In the post harvest burning areas understory burning would be accomplished at 

least once every ten years to reach and maintain desired conditions. Understory burning in 

untreated natural stands as well as treated stands are proposed for the two action alternatives. 

Reductions in hazardous fuels and the resulting fire behavior and severity would be consistent 

with the goals and objectives of the SNFPA (USDA-FS, 2004).

Fuel reduction treatments are used to lower the volume of flammable brush and slash across all 

emphasis areas. Prescribed burning occurs both in conjunction with tree removal and without 

tree removal. Actual protection levels would depend on how fast the brush and trees grow back 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 15 Chapter 2

following the fuel treatment or any subsequent site preparation treatments. Proposed fuels 

reduction would involve using prescribed fire in specific areas throughout the project area, 

thinning of some overstocked plantations, emphasis area treatments, and thinning from below. 

‘Thinning from below” refers to the removal of subordinate and intermediate trees to reduce 

ladder fuels and reduce the competition for resources like sunlight and water. The following 

techniques would be used:

1. Understory burning: is a prescribed burn under an existing canopy of trees (hardwood or 

softwood), designed to reduce live and dead vegetation. This type of burning is completed in the 

fall or spring when fuel moistures are low enough to carry fire and still be within prescription 

parameters. Understory burning differs from broadcast burning as it has cooler temperatures to 

protect overstory vegetation. Permission to burn is granted by the San Joaquin Valley Air 

Pollution Control District (SJVAPCD). Mechanical treatments are not practical for Rx1 and Rx2 

underburn units due to the location and slope present. Other than very expensive hand work, 

underburning is the only practical method available to tie treatment units together. To minimize 

ground disturbance, roads were used as the upper boundaries for the proposed burn units.

2. Pile Burning: involves burning piles created by hand labor or tractors. Usually kraft paper is 

used to protect an ignition point so piles can be burned in more cold and wet weather conditions. 

Pile burning is known to be of a higher intensity than broadcast burning and; therefore produces 

less particulate matter. Permission to burn is granted by the SJVAPCD.

3. Fire line: involves construction of areas that create a break in fuels used to control fire. Areas 

are scraped to mineral soil removing all organic material. The width of fire line varies from 2 

feet around hand piles to 6 feet around tractor piles. Fire lines are used to contain fuel-burning 

treatments (understory burns, pile burns, jackpot burns, and broadcast burns) when natural 

barriers to fire are lacking. Fire lines are usually located on topographic features that make 

control operations easier for onsite personnel. These are usually ridgetops and drainage bottoms 

with flowing water. 

Alternative 1 – No Action 

Under the no action alternative, current management plans would continue to guide management 

of the project area. No restoration treatments would be implemented. 

Alternative 2 –Proposed Action

How this Alternative was developed

Alternative 2 is a series of treatments that were developed over several years by a SNF 

interdisciplinary team in an attempt to restructure the forest and restore it to a resilient condition 

while minimizing adverse impacts to resources in the Project area that could result from changing 

weather patterns, drought stress, insect infestation, and wildfire. The alternative was developed to 

meet applicable landscape objectives consistent with the goals and objectives of the LRMP, as 

amended by SNFPA (USDA-FS, 2004) including:

1) Enhancement of shade intolerant (sun loving) trees through thinning; 

2) Meeting habitat needs of sensitive species;

3) Reintroduction of fire to mimic historic forest structures and to reduce fuel loading and small 

diameter (less than 10 inches dbh) tree density to more pre-1900 levels);
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 16 Chapter 2

4) Beginning to return stand structure and composition to more closely resemble historical 

conditions prior to railroad logging and increasing growth rates of residual trees to promote larger 

diameter, taller trees more quickly; and

5) Improvement of forest health and ecological resiliency through density management by 

thinning to promote resilience to changing weather patterns resulting in increased threats from 

insects, diseases, wildfire, and drought. 

One of the resultant adaptive management studies known as Sierra Nevada Adaptive 

Management Study (SNAMP) focuses on an area directly west of the Greys Mountain Project. 

As the Greys Mountain Project falls within the Pacific fisher habitat zone, knowledge gained by 

the SNAMP project and utilized in the design of the Greys Mountain Project include; current 

movement patterns and 2008/2009/2010/2011 denning sites (both birthing and maternal) of 

Pacific fisher that have been radio collared and intensively monitored within and outside of the 

project area, and information about what type of habitat conditions are preferred by denning 

females.

Alternative Description

Of the 9,600 total acres within the project boundary, approximately 3,575 acres were analyzed as 

areas where some form(s) of treatment are proposed (treatment areas). The remaining 6140 acres 

have no treatments proposed due to slopes greater than 35%, standard and guideline limitations 

on treatment and/or no treatment is needed to meet the purpose and need.

In Alternative 2 (proposed action) the treatments would include:

• Commercially thin from below 10 – 30 inch dbh mixed conifer, pine, and white fir stands 

on approximately 1535 acres (treats surface and ladder fuels, enhances heterogeneity in 

forest stand structure and reduces conifer stand density, increases the percentage and 

perpetuation of shade intolerant trees, increases diameter and height growth and vigor of 

residual trees, moves stands towards more historical composition as described in 

Chapter 1 Proposed Action);

• Remove hazard trees and commercially thin within three campgrounds on approximately 

31 acres (Reduce conifer stand densities within developed recreation sites for public 

safety and increased stand resiliency as described in Chapter 1 Proposed Action);

• Mechanically treat fuels and overstocked vegetation on approximately 882 acres (treats 

surface and ladder fuels, enhances heterogeneity in forest stand structure and reduces 

conifer stand density as described in Chapter 1 Proposed Action );

• Pre-commercially thin by masticating approximately 318 acres of conifer stands and 

brush covered areas (treats surface and ladder fuels, enhances heterogeneity in forest 

stand structure, reduces conifer stand density, ties restoration treatment areas and fuel 

breaks together, as described in Chapter 1 Proposed Action); 

• Plant and hand release treated openings within commercial thin and mastication 

treatment areas on up to 50 acres (prepare sites within failed plantations for reforestation 

and release needs as described in Chapter 1 Proposed Action)

• Treat slash concentrations within commercially thinned stands by a combination of 

tractor or hand piling and burning or mastication (enhances heterogeneity in forest stand 

structure, reduces natural and activity generated surface fuel loads, ties restoration 

treatment areas and fuel breaks together, as described in Chapter 1 Proposed Action);
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 17 Chapter 2

• Prescribe underburn on up to approximately 596 acres within 13 stands (prescribed fire 

only treatment) (enhances heterogeneity in forest stand structure, ties restoration 

treatment areas and fuel breaks together, restore production and enhance vitality of plant 

material as described in Chapter 1 Proposed Action); 

• Prescribe underburn within treatment areas H 2, 3 and 4, and T 1,2, 4, 5,7, 8, 9, 10, , 16,

17, 21, 26, 30, 31, 32, 33, 35, 38 and 39 on approximately 1855 acres (enhances 

heterogeneity in forest stand structure, ties restoration treatment areas and fuel breaks 

together, reduces fuel loadings toward pre-1900 levels, restores production and enhance 

vitality of plant material as described in Chapter 1 Proposed Action);

• Construct and reconstruct three existing fuelbreaks on approximately 325 acres(treat 

surface and ladder fuels to modify wildland fire spread and fire intensity levels, ties 

restoration treatment areas and fuel breaks together, restore production and enhance 

vitality of plant material as described in Chapter 1 Proposed Action)

• Improve and restore native plant communities important to local Native American tribes 

for traditional uses. This will be accomplished within the areas that are planned for 

prescribed burning and will be completed by using prescribed burning and hand pruning 

with tools (restore production and enhance vitality of plant material as described in 

Chapter 1 Proposed Action);

• Reduce fuel loading and fuel ladders from encroaching conifers within prehistoric and 

historic sites by thinning and prescribed burning on approximately 100 acres (improves 

the integrity that make cultural resources eligible for the NRHP as described in Chapter 

1 Proposed Action);

• Restore degraded meadows by reducing encroaching conifers on approximately 13 acres

(restores degraded meadows as described in Chapter 1 Proposed Action); 

• Restore hydrologic function through meadow stabilization on approximately 36 acres 

(restores degraded meadows as described in Chapter 1 Proposed Action);

• Manually pull and/or prescribed burn of noxious weed patches on approximately 10 acres 

(treats infestations of noxious weeds as described in Chapter 1 Proposed Action);

• Perform range stock drive maintenance by cutting out encroaching conifers and clearing 

stock drive tread over approximately 7.6 miles (improves and maintains resources for 

range management activities as described in Chapter 1 Proposed Action ;

• Perform maintenance on approximately 56 miles of forest system roads (improves and 

maintains existing forest transportation routes as described in Chapter 1 Proposed 

Action);

• Perform reconstruction on approximately 20.3 miles of forest system roads (improves 

and maintains existing forest transportation routes as described in Chapter 1 Proposed 

Action);

• Construct 0.25 miles of temporary road (Improve and maintain existing forest 

transportation routes within the project as described in Chapter 1 Proposed Action);

• Restore approximately 0.42 miles of user defined OHV tracks (restores user defined 

vehicle tracks and roads as described in Chapter 1 Proposed Action) ; and
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 18 Chapter 2

• Perform annual trail maintenance on 5.5 miles of designated OHV trails. (improve and 

maintain existing forest transportation routes within the project as described in Chapter 

1 Proposed Action)

More detail on these actions can be found in Chapter 1 Proposed Action (pg. 6).

Meadow Restoration Plans

This section outlines each meadow restoration plan in the project area. Table 2 can be 

referenced for meadow/WIN site location; however this Chapter also includes a site map showing 

the location of each WIN site, rock cache location, and potential ingress route into the meadow.

Ten meadows have been selected for restoration within the project area. (Table 2) These 

meadows were identified as having multiple restoration needs, which include the physical repair 

of Watershed Improvement Need (WIN) sites, removal of encroaching conifers, and management 

related issues such as Off-Highway Vehicle (OHV) and/or road impacts. 

Table 2. Meadows and WIN sites identified for restoration within the Project area (ND = no 

quantified measurement of encroachment).

WIN Site Meadow Number/Name Identified as 

top five in 

Conifer 

Encroachment 

Study?

Acres of 

Encroachment

Total Acres 

of 

Structural 

Meadow 

Restoration

51295 503M7 Yes 2.5 3.0

51104 503M8 No 3.5 3.5

51038 504M132/Meserve Meadow Yes 0.5 0.0

51246 504M198/Railroad Meadow No 2.4 3.5

51244 504M208 No 0.1 0.3

51036 504M209/Poison Meadow No 0.86 7.5

51037 504M211 Yes 0.0 3.3

None 504M212 Yes 0.75 0.0

51241 504M220/Chipmunk 

Meadow

No ND 3.6

51245/51015 504M292/504M293 Yes 1.25 5.3

Totals 11.86 30.0

Vegetation Treatments

Physically degraded meadows (i.e., meadows suffering from excessive gully erosion) will often 

have lowered ground water tables, which in turn can lead to accelerated conifer encroachment 

outside the range of natural variability. This phenomenon may also be related to or have been 

exacerbated by fire suppression over the last several decades. As the density of encroaching 

conifers increases, so will the rate of evapotranspiration, which will continue to lower the ground 

water table and encourage even more conifer encroachment. To stop this cycle and allow for 
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ground water recovery and more water availability, removal of conifers that are encroaching 

within the meadow should be done before or during other restoration activities. Thus it is 

proposed that conifers up to 12” dbh be removed from the meadows to help reduce the depletion 

of ground water. Select cedar and/or fir trees within the project meadow (>12” dbh) may be 

girdled for snag creation if the area is deemed snag deficient.

An internal Forest Service study of conifer encroachment was conducted for the project area 

(Gallegos, personal communication, 2011). Five meadows were identified as having significant 

encroachment since the late 1940’s (Table 2), and additional acreage estimates of encroachment 

were made for the other meadows. It is proposed that a total of approximately 12 acres of 

encroaching conifer be removed from the selected meadows (no other woody vegetation is 

recommended for removal). These treatments are consistent with the Sierra Forest Plan 

Amendment, Riparian Conservation Objects, Standard and Guide 105 (USDA, 2004). 
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Figure 1. Locations of meadow restoration sites within the Greys Mountain ERP (note: 

Meadows 504M292 and 293 have been combined into one site).
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Conifer Removal

Conifers will be removed by lop-and-scatter or chain saw within each meadow. Trees <6 feet tall 

will be lopped, scattered and left in place. Trees >6 feet tall will be bucked in place and the slash 

left to dry for a minimum of six weeks and then piled and burned. No mechanical treatment will 

occur. If applicable, 4” to 10” dbh trees will be cut into eight foot lengths and moved by hand 

with log carriers to the edge of the meadow where they will be cached for later use in restoration 

structures (see Log-and-Fabric Steps Falls under restoration methodology, (Appendix C). If no 

conifers are to be used for restoration purposes, they will be (depending on size) lopped and 

scattered, bucked in place, or bucked and moved to the meadow edge and left as biomass. 

Restoration methodology 

Physical restoration designs are detailed in Appendix B. The restoration methods and designs will 

address essentially three types of erosional feature:

• Vertical instabilities (knick points and headcuts)

• Lateral instabilities (channel banks)

• Incised channels and/or straightened channels 

Any or all of these erosional features may be present, and there are a variety of restoration 

designs that can be adapted or combined to each depending on factors of accessibility, 

environmental sensitivity, and cost. In some cases, rock will be conveyed by means of power 

wheel barrow, SWECO trail dozer, excavator or loader into and out of the meadows. Since there 

is a potential for ground disturbance, slash (from the vegetation treatments), ply wood, and/or 1⁄2” 

polyethylene mats will be placed along the ingress-egress routes to mitigate these impacts. 

To successfully design any restoration structure, reference reach data (e.g., Rosgen level II 

analysis) must be collected on streams within the watershed or a watershed in the same hydro 

physiographic province. As such, reference reach surveys will be conducted prior to 

implementation. The surveys are done by hand and have no associated ground-disturbing 

activities. 

WIN 51015 (504M292/293)

Headcuts and knick points would be repaired by installing rock step pool structures (Appendix 

C). Minimal ground clearing and brushing would be done for small tractor or power wheelbarrow 

access. Rock caches would be located off of FS Road 6S36 and 6S38 for each of the two large 

headcuts (Figure 2). Split rail fencing along FS Road 6S36 would be installed to discourage

OHV use in meadow. The east end of the meadow has very high conifer encroachment 

(approximately 1.25 acres). Physical restoration and/or stabilization efforts will restore/preserve 

approximately 5 acres of this meadow (Table 2).
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Figure 2. Map of WIN 51015 in meadow 504M292 and 504M293; red triangles denote main 

WIN features.

WIN 51036 (Poison Meadow 504M209)

Reconstruction and repair of existing structures would be done. A rock cache would be located in 

a very large turnout on Beasore road just south of the meadow. Minimal brushing and ground 

clearing would be done to allow access. There is a medium level of conifer encroachment in the 

northern portion of meadow approximately 0.86 acres (11%). Some split rail fencing and signage 

would be needed along track ML91 to discourage OHV use of the meadow. Physical restoration 

and/or stabilization efforts will restore/preserve approximately 7.5 acres of this meadow (Table 

2).
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Figure 3. Map of WIN 51036 in Poison Meadow (meadow 504M209); red triangle denotes 

main WIN features.

WIN 51037 (504M211/212)

Rock step pools would be built to address the two headcuts (P 328). Local rock could be used, or 

a rock cache could be located along FS Road 6S99 with easy access to the toe of the meadow. 

Meadow 504M212 is located 0.1 miles north of meadow 504M211. There are no WIN sites 

identified in this meadow (thus no physical restoration is planned), but there has been 0.75 acres 

of conifer encroachment identified through satellite and aerial photo review. Physical restoration 

and/or stabilization efforts will restore/preserve approximately 3 acres of meadow 504M211 

(Table 2).
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Figure 4. Map of WIN 51037 in meadow 504M211; red triangles denote main WIN features.

WIN 51038 (504M132)

Physical stabilization of this feature is not recommended at this time, but the structure should be 

monitored annually. The meadow was part of a historic ranch site and has many apple trees still 

in evidence. Additionally, the soil moisture conditions seem to have promoted the development of 

alder and willow trees throughout the meadow. There is some conifer encroachment by shade 

tolerant cedars and some small ponderosa saplings. There is an estimated 0.5 acres of 

encroachment. It is recommended that the existing conifers (up to 12” dbh) be removed, but no 

other woody vegetation is proposed for removal.
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Figure 5. Map of WIN 51038 in Meserve meadow (meadow 504M132); red triangles denote 

main WIN features.

WIN 51104 (Progeny Meadow 503M8)

Large ruts in southeast portion meadow from 4x4 truck use would be repaired. Primary access 

route is west of the meadow along a closed road/skid trail; this trail would be used to repair 

existing rock structures, and transport rock and equipment in to each headcut. The cache and 

access routes on the east side of the meadow are primarily to be used for the repair of the deep 

ruts in the meadow. Conifer encroachment is high throughout meadow (approximately 3.5 acres).
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Split rail fencing would be put up along FS Road 6S13 to discourage further degradation due to 

OHV use. Rock step pool structures would be built to stop headward erosion of the headcuts 

(Appendix C). Sand, native soil and local sod may be used to fill OHV ruts. Physical restoration 

and/or stabilization efforts will restore/preserve approximately 3.5 acres of this meadow (Table 

2).

Figure 6. Map of WIN 51104 in Progeny meadow (Meadow 503M8); red triangles denote 

WIN features.

WIN 51241 (Chipmunk Meadow 504M220)

A trail would be built through manzanita and buckbrush between the meadow and Beasore road

to allow access for power wheelbarrows or a small tractor. The most topographically suitable area 

for the trail has been depicted on the map (Figure 7). Due to the small dimension of the headcut, 

local rock would be used to create a step pool or a log step fall structure using trees from the 

surrounding area would be built. Physical restoration and/or stabilization efforts will 

restore/preserve approximately 3.6 acres of this meadow (Table 2).
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Figure 7. Map of WIN 51241 in Chipmunk meadow (Meadow 504M220); red triangle 

denotes main WIN feature.

WIN 51244 (504M208)

Access is easy from 6S38, and a rock cache would be located at the junction of 6S38 and 6S38X. 

Split rail fencing would be constructed along FS Road 6S38 to discourage OHV use in meadow. 

Rock step pools and rock rundowns would be constructed (Appendix 3). Physical restoration 

and/or stabilization efforts will restore/preserve approximately 0.3 acres of this meadow (Table 

2).
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Figure 8. Map of WIN 51244 in meadow 504M208; red triangles denote main WIN features.

WIN 51246 (Railroad Meadow 504M198)

Barriers would be installed to prevent access to the meadow. 

An existing breach in the railroad bed would be widened by several feet to lessen the impact from 

livestock trailing and allow overland flow to move from the west to east end of the meadow 

during high flow. Conifer encroachment is very high in the west end of the meadow near 6S11 

(head of meadow) at approximately 2.4 acres (~50%). Physical restoration and/or stabilization 

efforts will restore/preserve approximately 3.5 acres of this meadow (Table 2).
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Figure 9. Map of WIN 51246 in Railroad meadow (Meadow 504M198); red triangles denote 

WIN features.

WIN 51295 (503M7)

User created tracks will be barricaded and signage installed on both ends of the trail to prevent 

OHV access the track will be sub soiled to decompact the soils and allow regeneration of native 

vegetation Adequate water bars would be constructed to prevent surface erosion. Downed trees 

and slash along the track alignment that will be cut during the conifer encroachment treatment 

project would be distributed.

Conifer encroachment is very high in small pockets of the lower SE and upper NW ends of the 

meadow (approximately 2.5 acres). Physical restoration and/or stabilization efforts will 

restore/preserve approximately 3.0 acres of the true meadow segments (Table 2).
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Figure 10. Map of WIN 51295 in meadow 504M7; red triangles denote main WIN features; 

darker green polygons represent the true meadow components.

Meadow

Meadow
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Figure 11. Map showing the alignment of the OHV track through meadow 503M7. This 

track will be restored to improve soil productivity and allow for native vegetative recovery.

Alternative 3 – Lower and Limited Mid-Level Canopy 

Treatments, All Treatment Areas 

In Alternative 3, treatment areas would remain the same as in Alternative 2, treatments within 

these areas would include only those needed to reduce the surface and ladder fuels (within the 

lower and limited mid-level canopy levels) to achieve fire and fuels objectives. Under Alternative 

3 there would be no additional treatment (i.e. additional thinning in the mid-level canopy) so it 

would only partially address stand density and forest health objectives. In treatment areas where 

wild stands occur, the break-up of crown continuity would not be the main focus, but the ability 

to raise the height of the canopy base (the average height of the bottom layer of branches) where 
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Sierra National Forest – 32 Chapter 2

fire/fuels objectives are met. This includes the need to remove some material that is considered 

pre-commercial sized (i.e. less than 10 inches dbh). Maintenance and/or reconstruction of forest 

roads that were determined to not meet Forest Service standards would be brought back up to 

standard. Mechanical thinning would be completed within the first two to five years of 

implementation. Areas where follow-up treatments are needed, such as slash piling/burning, 

prescribed understory burning and noxious weed treatments, would be prioritized based on 

proximity to WUI and completed as appropriated dollars became available. Meadow restoration 

treatments would be completed as planned. Prescribe understory burning only areas would be 

completed as planned. 

A treatment area map (map 1) can be found in the Map Package in Appendix A. 

In Alternative 3, the treatments would include

• Precommercially thin trees 10” dbh mixed conifer, pine, and white fir stands on 

approximately 2417 acres. This would be accomplished by hand or mechanical 

(mastication) methods. 

• Plant and hand release treated openings within commercial thin and mastication 

treatment areas on up to 50 acres 

• Treat slash concentrations within precommercially thinned stands by a combination of 

tractor or hand piling and burning or mastication. 

• Prescribe underburn on up to approximately 596 acres within 13 stands (prescribed fire 

only treatment)

• Prescribe underburn as a follow-up treatment within treatment areas H 2, 3 and 4, and T 

1,2, 4, 5,7, 8, 9, 10, 16, 17, 21, 26, 30, 31, 32, 33, 35, 38 and 39 on approximately 1855

acres 

• Construct and reconstruct three existing fuelbreaks on approximately 325 acres

• Improve and restore native plant communities important to local Native American tribes 

for traditional uses. This will be accomplished within the areas that are planned for 

prescribed burning and will be completed by using prescribed burning and hand pruning 

with tools 

• Reduce fuel loading and fuel ladders from encroaching conifers within prehistoric and 

historic sites by thinning and prescribed burning on approximately 100 acres 

• Restore degraded meadows by reducing encroaching conifers on approximately 13 acres 

• Restore hydrologic function through meadow stabilization on 36 acres of 

• Manually pull and/or prescribed burn of noxious weed patches on approximately 10 acres 

• Perform range stock drive maintenance by cutting out encroaching conifers and clearing 

stock drive tread over approximately 7.6 miles 

• Restore approximately 0.42 miles of user defined OHV tracks 

• Perform annual trail maintenance on 5.5 miles of designated OHV trails.

• Manually pull and/or prescribed burn of noxious weed patches on approximately 10

acres.
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Design Criteria Common to All Action Alternatives

The design criteria listed by resource area below are included in and are an integral part of each 

action alternative analyzed in detail within this document. They directed the design of treatment 

areas, the design of treatment types and/or are direction to follow during implementation. In 

listing these as part of all action alternatives, they are considered when analyzing the direct, 

indirect and cumulative effects of each alternative and have been incorporated to minimize 

potential environmental impacts of the management actions proposed by alternatives. As listed, 

they are a subset of the management direction provided in the SNF-LRMP (USDA-FS 1992) as 

amended by the 2004 SNFPA (USDA-FS 2004b) and 2007 SNF MIS standard and guidelines

(S&G); applicable Forest Service Manuals and Handbooks; and Best Management Practices 

(BMP). The design criteria are also based on past implementation experience; the best available 

science and/or to address significant issues. 

Cultural Resources

Cultural resources would be protected through implementation of Standard Protection Measures 

of the Regional Programmatic Agreement (PA), the primary protection measure being avoidance 

for all project activities, including resource design criteria. The District Archaeologist would 

approve all landings; borrow sources, and temporary roads prior to Project implementation as 

needed.

In addition, where the proposed action is to reduce fuel loading and fuel ladders within prehistoric 

and historic sites, the cultural resources would not be managed under the above referenced 

measures. Instead the following design criteria would be followed in order to address the purpose 

and need, and comply with applicable regulation and policy.

1. For prehistoric and historic cultural sites with heavy fuel loading, treatment measures 

by way of hand thinning brush and understory would utilize chainsaws to thin fuels. 

Brush shall be piled for future burning outside site boundaries in prehistoric sites. 

Piles may be placed within historic sites where there are no wooden components and 

away from features. Pile locations would be delineated through coordination with 

the District Archaeologist and where necessary, hand lines shall be constructed 

around piles to contain fire. 

2. For prehistoric cultural sites with heavy fuel loading, treatment measures by way of 

low-intensity burning through cultural sites may occur. Handlines would be

constructed outside site boundaries where necessary to control direction of the fire. 

This would be done in coordination with the District Archaeologist and fuels 

personnel. Underburning would only occur in sites with a potential for a low 

intensity fire focused on cleaning out the understory. 

3. For prehistoric and historic cultural sites with heavy fuel loading, thinning of forest 

stands may occur through mechanical treatment. Should identified tree stands need 

to be thinned in order to meet forest stand health requirements, those trees that can 

be reached from the site edge by a feller-buncher and would be cut and removed 

from prehistoric sites without disturbing the ground. Mechanical equipment may 

enter historic sites to reach trees to be cut in areas with no observed cultural deposits 

or features in coordination with the District Archaeologist.

4. An archaeologist would monitor all fuel reduction activities within and around 

cultural resource sites during implementation.
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5. All cultural resource sites would be delineated prior to implementation.

6. Gathering areas would be improved through hand thinning and piling and 

underburning of fire-dependent species.

7. The cultural resource sites within WIN sites are currently unevaluated and must be 

treated as eligible. To mitigate the potential adverse effect, a determination of 

eligibility shall be conducted for these sites and any adverse effects mitigated prior 

to project implementation. 

8. Harvest activities of potential hazard trees would avoid historic campground features 

in accordance with Standard Resource Protection Measures of the Regional PA

Botany: Forest Service Sensitive Plants 

1. All short-leafed hulsea populations will be flagged for avoidance (SNF 1992 LRMP 

S&G #s 67 and 68, SNFPA 2004 ROD S&G # 125).

2. Open granitic and/or gravelly areas in or adjacent to units M2, T-8, T-17, and T-21 will 

not be driven through for project implementation (except for on existing system roads) 

nor used for parking of vehicles, heavy equipment nor used as log landings. This is to 

ensure protection of the Yosemite bitterroot (known to occur near units M2 and T8) and 

suitable habitat for the following sensitive plant species that have not been discovered in 

the project area but may exist: Mono Hot Springs evening primrose, and Kelloggs’ 

lewisia. (SNF 1992 LRMP S&G #s 67 and 68, SNFPA 2004 ROD S&G # 125).

Noxious Weeds

1. All heavy equipment used for implementing the project will be washed before arriving on 

site to remove soil and seeds of noxious weeds. This is to ensure that weed seeds or 

propagules are not inadvertently introduced into the project area (SNFPA 2004 ROD 

S&G # 38 and 39; USDA Forest Service FSM 2081.3, Timber Sale Contract Clause 

B.6.35). See Appendix D of this document for more details.

Geology/Soils

1. Leave a 100-foot wide buffer of 100 percent soil cover below large rock outcrops. These 

areas have a high potential to generate runoff that can cause accelerated erosion on soils 

down slope (FS Handbook).

2. Conduct mechanical equipment operations (mechanical thinning and biomass removal 

equipment, log skidders and tractor-piling operations) when the soil is sufficiently dry in 

the top 12 inches to prevent unacceptable loss of soil porosity (soil compaction). Field 

checking by a soil scientist would be done to determine if operations could continue 

under moist soil conditions. “Maintain 90% of the soil porosity over 85% of an activity 

area (stand) found under natural conditions” (BMP; FS Handbook). 

3. Subsoil and water bar skid roads and trails in areas where soil compaction exceeds 15% 

of a treatment area (BMP; FS Handbook).

4. Limit mechanical operations, where sustained slopes exceed 35%, except where 

supported by on-the-ground interdisciplinary team evaluation. Apply slope limitation to 

mastication treatment units (FS Handbook; SNF-LRMP S&G).
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5. Maintain 50% soil cover over all treatment areas. Where shrub species predominate, 

attempt crushing before piling to create small woody fragments left scattered over the site 

for soil cover and erosion protection (FS Handbook; SNF-LRMP S&G).

6. Maintain at least five well-distributed logs per acre as large woody debris (LWD) 

representing the range of decomposition classes defined in the Regional Soil Quality 

Standards and Guidelines (SNF- LRMP and SNFPA ROD S&G).

7. To avoid adverse soil disturbance, the soils would need to have soil moisture content 

below 14% to minimize the potential of detrimental soil disturbance.

Recreation/Lands/Special Uses 

 Lands and Special Uses

A number of the proposed activities may affect areas under special use permit. Forest 

Service project managers would notify permit holders and agencies, in person or writing, 

when Project activities including mastication, pre-commercial thinning and/or understory 

proscribed fire would be implemented that may affect their authorized special uses or 

agency jurisdictions. A list of permit holders is located in the Project record. Forest 

Service managers responsible for implementation would work with permit holders to 

ensure authorized improvements and/or right-of-ways are clearly identified on all 

contracts and visible during Project implementation. Appropriate protection measures 

would be put in place.

The following design criteria allow the Forest to meet commitments specified in special 

use permits:

1. Use of apiary site (in unit T39) for project activities would be upon notification to 

the permit holder prior to project activities occurring. 

2. If the apiary site would be used for staging or landing, the site would be cleaned of 

debris and brought back to pre-project condition. 

3. The apiary site consists of a flat area surrounded by an electric fence where up to 

100 hives of bees are located. The electric fence would be protected and any 

damage to fence or apiary site shall be repaired immediately. 

4. To avoid vibration disturbances to the occupied apiary site by project activities the 

permitted bee keeper would be notified in advance of project activities.

5. During project activities, continue to provide access to private property authorized 

under permit (located between units T28 and T29). The private road authorized 

under permit is native surfaced, 12-feet wide and approximately 950 feet long 

leading from road 6S10 to the Sturrock property at Soquel.

6. During project activities, continue to provide access to a Forest Roads and Trails 

Act (FRTA) easement providing access to private property located in unit T38. The 

easement would be used for project activities only after arrangements have been 

made to pay or perform pro-rata share of road maintenance. Project activities would 

not interfere with grantees use of road.

7. Ensure the culvert containing electronic equipment, satellite data transmitter and 

wooden walk way to the Madera Irrigation District stream gauging station (T16, T4, 
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Sierra National Forest – 36 Chapter 2

located on the stream bank of Willow Creek adjacent to a bridge near the Greys 

Mountain campground) continues to be accessible and is not damaged by project 

activities. 

8. During preliminary activities and during implementation of project activities, 

protection of Madera Irrigation District ditch tender cabin a wooden structure and 

gate off of spur road 6S10A is necessary (T29).

9. The Forest Service has permanent full public easements for Road 6S10 across 

private property in the Paradise Springs and Soquel areas. Commercial hauling 

would be allowed across the easement only after arrangements have been made to 

pay or perform pro-rata share of road maintenance.

Mining

1. One mining claim is located in the project area in units (T31, T33, T34, and T37). 

There are no active operations occurring at this time. Consultation and coordination 

with District Minerals staff regarding mining activity status would take place when 

activities occur in affected project areas.

Developed Campgrounds, Dispersed Camping and Use Areas, Designated 

Motorized trails.

Developed Campgrounds

The Forest Service operates 4 developed campgrounds in the project area; 

In developed campgrounds: 

1. To avoid conflicts with Forest visitors, a limited operating period (LOP) would be

established during the developed campgrounds’ peak season months which is 

between Memorial Day and Labor Day for Units T4, 7, 9, 38.

2. Outside the LOP and contingent upon the safety of the public, developed 

campgrounds would be fully accessible to the public on week-ends.

3. Stump cuts would be flush cut to ground and treated with borax.

4. Slash or fuels treatment would be completed soon after treatment to ensure 

developed campgrounds are clear of accumulated slash, limbs and cull logs, i.e. 

removed, piled, burned and/or chipped.

5. Any damage to developed campground structures such as fire rings, tables, bulletin 

boards, site barriers as a result of project activities would be repaired or replaced 

immediately, to pre-project condition.

6. The location of landings and staging areas for project equipment with in developed 

campgrounds would be in coordination with district recreation staff.

Dispersed Camping and Dispersed Use Areas 

Several heavily used, popular dispersed recreation sites including the Texas Flat 

Overflow, Soquel Overflow, and Madera Ditch dispersed area; Slide Rock and Moon 

Rock are located in the project area and are accessed by Forest Service system roads. 

1. During project activities, access to dispersed camping areas and/or dispersed use 

areas that are on designated roads or designated trails would continue contingent 

upon the safety of the Forest visitor. 
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Designated Motorized Trails

1. The designated motorized trails in the project area would not be used for skidding, 

hauling, or moving equipment. Note: All designated motorized trails are marked 

with a brown fiberglass carsonite post with decals showing trail number, skill level 

and vehicle type markers are posted at the beginning and end of the trail. 

2. If necessary, movement of equipment across designated trail would be only at a right 

angle to trail, only at selected areas of the designated trail and upon consultation with 

Recreation OHV Staff.

3. If “gouging” or berms occur as a result of moving equipment across a designated 

trail, trail would immediately be repaired to ensure the safe passage of the Forest 

visitor and brought up to Forest Service motorized trail standards.

4. A clearing limit of 3 feet (from each side of a designated trail) would be established. 

(FSH 2309.18 Trails Management Handbook) 

5. Designated trails would be kept clear of any debris or forest material, burned or 

otherwise. This includes material with-in trail clearing limits.

6. Directional felling and yarding away from designated trails is required.

7. Stump cuts adjacent to designated trails and within clearing limits, would be flush cut 

to ground and treated with borax. 

8. During project activities, access to the designated trails would continue contingent 

upon the safety of the Forest visitor.

9. A as a result of project activities, any damage to designated trails or associated trail 

head facilities, such as trail signs, bulletin boards, or barriers would immediately be 

repaired or replaced to pre-project condition.

Wildlife – Terrestrial

Specific Management Provisions

Forest Service requirements for managing Federally Listed and Forest Service Sensitive species 

and their habitats are defined in the following documents.

 National Forest Management Act (NFMA) 

 Forest Service Manual and Handbooks (FSM/FSH-2670) 

 Endangered Species Act (ESA)

 SNF-LRMP as amended by (2004 SNFPA)

In addition to the LRMP standards and guidelines, the following management actions would help

maintain and/or enhance important Pacific fisher and American marten habitat for all action 

alternatives considered. These measures include information from the 2008 Conservation 

Biology Institute Document “Baseline Evaluation of Fisher Habitat and Population Status and 

Effects of Fires and Fuels Management on Fishers In the Southern Sierra Nevada, Final Report to 

USDA Forest Service Pacific Southwest Region” (Spencer et al 2008); “An Ecosystem 

Management Strategy for Sierran Mixed-Conifer Forests” (North et al 2009); and Sierra Nevada 

Adaptive Management Study Integration Team discussions, fieldtrips to the project area, as well 

as Land Allocations.
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1. Maintain highest canopy cover possible to meet the prescription within stands, aim for 

60% immediately post-harvest.

2. Thinning would not remove any trees larger than 30-inch dbh (SNFPA ROD, pg. 50).

3. Protect all suitable fisher denning habitat with a (LOP) from March 1 through June 30. 

This LOP would protect reproductively active fisher and young that may be present in the 

project area from treatment actions during their denning and early rearing periods. 

4. Snags would be felled only if they meet the definition of a danger tree, have the potential 

to fall across prescribed fire control lines, and/or pose a threat to firefighter safety during 

prescribed fire implementation. Both OSHA 29 CFR 1910.266(c) and FSH 6709.11, 

glossary define a “danger tree” as “A standing tree that presents a hazard to employees 

due to conditions such as, but not limited to, deterioration or physical damage to the root 

system, trunk, stem or limbs, and the direction and lean of the tree.” Down logs created 

as a result of snag felling would remain in the stand where needed to meet down log 

requirements of S&G #10. Snags not meeting the criteria of a danger tree will remain as 

standing snags within the project area.

5. Retain dense groups of larger trees (greater than 30-inch dbh) with touching crowns at the 

rate of approximately one group per 2.5 to 3.5 acres. Ideally these groups would contain 

“defect” trees, those that have cavity and platform creating defects (mistletoe, rot, fork 

topped, broken limbs and tops) for pacific fisher denning and resting sites. Within these 

large tree groups, all trees over 20” dbh will be retained. These large tree groups will 

have a residual basal area of 240 ft2 or more for mixed conifer and 210 ft2 or more for 

pine and in many instances may reach 300 to 400 ft2 per acre. Retention of these large 

tree groups with higher basal areas and the inclusion of defect trees are designed to 

maintain the integrity of suitable fisher denning and resting sites throughout the treatment 

units. Non-treated areas within proposed treatment units, such as riparian areas and steep 

slopes, will also provide extensive areas of tree group retention as no treatments will be 

occurring in these areas. 

6. In certain incidences, small (five to ten acre) pockets or inclusions of decadent, high 

quality, dense fisher/spotted owl habitat that are identified in the field during project 

layout may be dropped from commercial treatment upon field review by the district 

biologist. A number of predominant trees are often observed within these types of 

inclusions, which may be remnant old forest pockets not previously logged during the 

extensive railroad logging that occurred on the district throughout the turn of the century. 

Due to the high habitat value present in these stands, and in accordance with Standard 

and Guideline #90 from the SNFPA ROD, this unique habitat inclusion may be removed 

from the treatment unit and will not be available for commercial entry.

7. Conifers with structural decadence, and/or the potential to become future dead tree snags, 

would be retained throughout the non-treatment areas of the project area. To maintain

decadent stand characteristics within the treatment units, conifers >16”inches dbh with 

structural decadence and/or the potential to become future snags would be identified for 

retention within the treatment areas. Standard and Guideline #11 provides direction for 

retention of these structural elements. Within treatment units, conifers with the greatest 

existing or potential for structural decadence will be retained at an average of 1 every 100 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 39 Chapter 2

feet. Conifers would be selected using the following characteristics listed in order of 

priority: evidence of known or potential cavities; broken top; conks or other heart-rot 

indicators; mistletoe or other abnormal witches broom formation or other diseased or 

insect damaged trees; teakettle branches; forked top; or broken large branches. 

8. All black oaks would be retained throughout the project area. Within the treatment areas, 

conifers would be removed that overtop those black oaks, or that otherwise restrict 

sunlight from reaching them (e.g. from the south and west) now or within 15 years 

following treatment; the amount of conifer removal will be limited by the overall basal 

area thinning prescription thresholds. Hiding cover around oaks, such as shrubs and 

small trees would be retained around 2-3 decadent oaks per acre. These oak retention 

areas will be protected with a buffer area 35 feet from the bole, or to the dripline, 

whichever is greater, where no thinning or fuels treatments would occur. 

 

9. Promote diversity in pine plantations by creating 1/10 acre openings associated with 

young black oaks between 1”inch and 12”inches dbh to encourage diameter growth of the 

oak through increased sunlight, release the oak from competition, and encourage future 

stand heterogeneity. To achieve this, Ponderosa and Jeffrey pine trees within pine 

plantations would be removed from a 180° swath on the Southern aspect around crowded 

young black oaks for a 50 foot radius. Additional Ponderosa and Jeffrey pine trees 

directly adjacent to the oak on the northern aspect may need to be cut to eliminate 

competition for space within the over-story and would be identified at the marker’s 

discretion. Other species that may be present within plantations such as cedar, fir, sugar 

pine, and giant sequoia would not be removed to maintain current diversity where it 

exists. (S&G #3; #26).

10. Shrub and understory diversity would be retained throughout the project area. All 

understory vegetation would be maintained in Old Forest Linkages associated with 

riparian areas (cooler, moister sites); black oak buffer zones; as well as areas where no 

treatment would be conducted such as heritage resource sites, botanical areas, slopes 

>35%, and rocky areas. Tree species associated with riparian areas, such as dogwoods, 

alders, and willows would not be removed. In addition, post sale treatments would retain 

pockets of understory growth spread throughout the treatment units so that an additional 

15-20% of the total understory growth would be maintained in 1/10 acre pockets within 

plantations and 1⁄4 acre pockets within wild stand treatment units.

11. The district biologist would be notified immediately if a nest or den of any TESCP 

species is discovered within or adjacent to a treatment area so that proper protection 

measures can be identified and implemented.

12. All temporary roads and skid trails necessary for project implementation would be 

obliterated or decommissioned according to the USDA Forest Service (BMP) 2-26 

(USDA 2000).

13. Standards and Guidelines 28 and 29 provide guidance for developing and maintaining 

adequate habitat connectivity within riparian areas. Recent studies (Spencer 2008; North 

et al 2009) have also shown that fisher utilize riparian areas as travel corridors between 

high quality habitat. To provide for this habitat connectivity, design criteria have been 

developed to incorporate and expand upon established riparian area management zones; 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 40 Chapter 2

i.e. Streamside Management Zones (SMZ) and Riparian Management Areas (RMA)

associated with perennial streams (Class I). The forest wildlife biologists have termed 

these zones (OFL). They incorporate and expand upon the measures required for SMZs 

and RMAs. OFLs consist of buffers measuring 300 feet total on either side of perennial 

streams. Design criteria for these Old Forest Linkages are detailed in Table 4 and Figure 

12

Table 3. Riparian Area Management Zones

*Distance from Perennial Stream is measured and applied to each side of the stream from bankfull left and bank-full right.

Figure 12: Associated Bounds and Treatments within Old Forest Linkages

Distance from 

Perennial Stream* 

Vegetation Management Activities 

Allowed within zone Zone Designation

0-50 feet No activities allowed SMZ/RMA/OFL

50-100 feet

No ground disturbing equipment 

allowed into area (dozers, skidders, 

etc.) Activities allowed include handfelling of trees smaller than 

12”inches dbh, pile-burning, and 

equipment reach-in with boom arm. 

Canopy cover is to remain ≥60%.

SMZ/RMA/OFL

100-150 feet

Mechanical entry is allowed. Trees 

≤12” dbh may be removed for fire 

and fuels reduction purposes by 

equipment. Canopy cover is to 

remain ≥60%.

OFL

150-300 feet

Mechanical entry is allowed. 

Thinning from below would occur. 

Canopy cover is to remain ≥60%.

OFL
Sierra National Forest – 41 Chapter 2

Wildlife – Aquatics

Current Known Information

Generalized SMZ designation is outline in Table 4 based on stream class and mapped in 

the Project Hydrology Report.

Table 4. Summary of Relationship between Riparian Area Criteria

Feature Type RCA 

Width

Stream 

Class

SMZ Width RMA Width

Perennial Streams 300 feet I At least 100 

ft

100 feet

Seasonally Flowing 

Streams 

150 feet II At least 75 ft N/A

III At least 50 ft

IV At least 25 ft

V None 

required

Streams in Inner Gorge Top of 

inner 

gorge

Varies

Special Aquatic Features 

(fens, bogs, springs, 

seeps, lakes, ponds, 

wetlands, etc.)

300 feet N/A N/A 100 feet

Streamside Management Zones (USDA-FS 1992 (S&G 33 and 71); USDA Forest Service 2000 

(BMP 1-8)) are mapped in the Project Hydrology Report. Activities within Class I streams are 

identified under the OFL prescription under Terrestrial Wildlife. Specific to MYLF:

Class I MYLF occupied (USDA-FS 1992 (Forest wide goal and objective 9, S&G 40): two 

known sites in analysis area (Soquel and Tex Flat). The extent of the populations will be 

delineated as part of the herpetology (amphibian) surveys. Occupied habitat would apply the OFL 

prescription of 150 feet.

1. Applicable to all SMZs:

1. Heavy mechanical equipment would not be allowed within SMZs.

2. To protect bank stability, do not cut stream bank trees (trees with drip line extending 

to or over edge of stream bank). 

3. Do not cut any tree located within a channel.

4. When lighting piles, start burn from one end only to allow escape route for any 

species inhabiting piles.

5. No prescribed fire lighting into SMZs, but fire can creep into zone.

For water drafting (USDA-FS 2000 (BMP 2-21), a screened intake device and pumps with low 

entry velocity would be used to minimize removal of aquatic species, including juvenile fish, 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 42 Chapter 2

amphibian egg masses and tadpoles, from aquatic habitats. A hydrologist or aquatic biologist 

would approve water-drafting sites. 

If newly listed or unknown occurrences of federally listed threatened, endangered, proposed, 

candidate or Forest Service sensitive aquatic species are found within the affected project area 

during sale preparation and implementation, additional species protection measures may need to 

be imposed by the district fisheries and aquatic biologist. 

Mountain Yellow-legged Frog:

1. Class I MYLF occupied (USDA-FS 1992 (Forest wide goal and objective 9, S&G 40): two 

known sites in analysis area (Soquel and Tex Flat). The extent of the populations would be 

delineated as part of the amphibian surveys. Occupied habitat would apply the OFL prescription 

of 150 feet. In addition to the above requirements for all SMZs:

1. Treatments within the outer 100 feet of the SMZ would be limited to those 

prescribed for Pacific fisher. 

2. Hand treatments of non-merchantable trees could be implemented within the inner 

50 feet of the SMZ, although piled material should not be left within 50 feet. 

3. Project activities would occur after June 15th. 

4. No heavy equipment would enter the SMZ. 

5. Treatments within the outer 100 feet would be limited to those prescribed for 

Pacific fisher. 

6. Hand treatments of non-merchantable trees could be implemented within the inner 

50 feet of the SMZ, although piled material should not be left within 50 feet. 

7. Project activities occur after June 15th. 

Special Aquatic Features (USDA-FS 2004 (S&G 91):

Do not allow mechanical equipment within 100 feet of meadows or other special aquatic

features. This requirement includes treatment areas: T2, 17, 26, 27, 32, 33, 36, 37, 38, 42, 

44, 46, 47, all Rx treatment areas.

Hydrology

Design measures to protect water quality and ensure watershed health are detailed by BMPs 

described in the Water Quality Management for Forest System Lands in California, (USDA, 

2000), the Riparian Conservation Objective Standards and Guides as set forth in the SNF LRMP

(USDA, 1991) as amended by the 2004 SNFPA . General project BMPs with their corresponding 

design measures are listed in Appendix B. 

Soil and Water conservation Practices Handbook, Sierra National Forest Supplement No.1, 

(FSH2509.22) provides standards for the establishment and management of SMZ’s. Included is 

the incorporation of RMA’s and their functional/hierarchical relationship to SMZ’s (Figure 12).

All stream courses in the project area would be protected and assigned SMZ’s (Figure 13). The 

stream courses mapped on the Project Area Maps provide information for development of 

watercourse protection measures such as: 

1. Skidding would be designed in a manner to skid logs away from the drainages and cross 

drainages at designated locations. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 43 Chapter 2

2. Skidding would not occur across perennial creeks, and limited treatment could occur in 

streams with riparian vegetation.

3. Any project generated material that would cause obstruction of storm flows would be 

removed. 

4. All channels have SMZ’s, which are equipment exclusion zones. Materials may be endlined out of this zone. 

5. Perennial streams would have a minimum SMZ of 100 feet; seasonally 

flowing/intermittent streams would have a minimum SMZ of 50-75 feet and ephemeral 

channels would have a minimum SMZ of 25 feet based on field investigations. The chart 

below provides a summary of SMZ by Stream Class (Table 5). 

6. Treatment in prescribed burn units would avoid direct lighting for prescribed fire within 

riparian vegetation and or within the SMZ of stream channel; prescribed fires may back 

into riparian vegetation areas or SMZ’s.

7. Within RCAs reduce as much as possible ground disturbing impacts (i.e., soil 

compaction, vegetation disturbance, etc.). 

8. Best Management Practices Evaluation Program form T01 would be utilized to evaluate 

implementation on those units with SMZ’s and other aquatic protection requirements.

Most units have avoided crossing stream channels. The exception is 4th order ephemeral draws. 

Fuels treatments should be laid out to utilize designated and/or existing crossings. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 44 Chapter 2

Table 5. Streamside Management Zone designation by stream class

Stream 

Class

Minimum 

Ground 

Cover Density 

(%)

SMZ 

Width (ft)

30% Slope

SMZ Width 

(ft)

40% Slope

SMZ 

Width (ft)

50% Slope

SMZ 

Width

(ft) 60% 

Slope

SMZ 

Width (ft)

70% 

Slope

I 50 100 130 160 190 220

II 50 75 105 135 165 195

III 50 50 80 110 140 170

IV 50 25 45 65 85 105

V 50 0 0 0 0 0

Figure 13. Associated Bounds and Treatments within Old Forest Linkages

Meadow Restoration

1. Wildlife and botanical surveys would be conducted prior to any restoration activity to 

ensure protection of those resources and compliance with all relevant BMP’s.

2. All encroaching conifers approved for removal (up to 12” dbh) would be felled, 

lopped-and-scattered, bucked in place, or bucked and carried to the meadow edge. 

All conifer material would be left as biomass, burned or used in the restoration 

structures.

3. In all cases, native vegetation (e.g., sod) removed during restoration activities would

be saved and preserved for later planting. Areas of bare soil in the floodplain would 

also be planted with native willows to expedite and enhance the stabilization process. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 45 Chapter 2

Willows would be either cultivated or harvested locally from the same meadow(s) or 

meadows in the same watershed and at the same elevation range.

4. Water would be dammed and diverted around the restoration areas during 

construction. This would be done either by pumping the water using a portable pump 

or by gravity draining impounded water using a 10” inch flexible corrugated plastic 

pipe. Diverted water would be put back into the channel at the bottom of the meadow 

or spread on the meadow surface.

Rock used to build step-pool structures would come from local forest stock piles. 

Currently, rock comes from the tunnel talus at Powerhouse 8 off Forest Road 8S03.

5. All ingress-egress by equipment would occur only when soil moisture conditions are 

low and the ground firm. If equipment does need to enter the meadow, it would only 

travel and work on the periphery (or dry portions) of the meadow, and in all cases, 

1⁄2”inch to 3⁄4”inch plywood and or 1⁄2”inch polyethylene mats would be laid down 

along the equipment route in order to distribute the load more uniformly over the 

meadow surface and mitigate any tread damage that may occur.

6. Any ingress routes enlarged and/or created for equipment to access to the meadow(s) 

would be obliterated upon completion of the project or properly closed if access to 

the project area is required for maintenance within the first five years after

completion.

7. Refueling of equipment would occur at least 100 feet from any riparian area.

8. To allow vegetation to recover and to protect the area(s) from trampling damage by 

cattle stock, enclosing the restoration areas would be done for two years. To offset 

the potential loss of available water for stock, offsite watering systems can be 

evaluated on a case-by-case basis and be installed in coordination with the Range 

specialist and the permittee.

Prescribed Fire: 

1. For the SMZ’s defined, a minimum protective ground cover of 50% would be established 

and continuously maintained from October 15th to June 15th of each year consisting of 

any combination of living plants, litter, slash, and duff.

• Living plants must be at least 5 feet high to qualify as protective ground cover.

• Litter and/or slash must be at least 2 inches deep and made up of material 4 

inches or less in diameter to qualify as protective ground cover.

• Duff or humus must be 2 inches deep to qualify as protective ground cover.

• The 50% ground cover would be determined by using a series of random 100 

point transects.

2. Where ground cover is less than the required 50% minimum, treatment would be applied 

to increase the protective efficiency of the SMZ/RCA to minimum standards. Treatments 

may include the establishment of living plants, introduction of litter, slash, or other 

treatments as prescribed by the district hydrologist or fisheries biologist. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 46 Chapter 2

3. Prescribed burning within SMZ/RCA may be implemented as follows: hand piling and 

burning, jackpot burning, and/or broadcast burning provided that the ground cover is not 

reduced more than 50%. If the protective ground cover is reduced more than 50%, then 

protective mitigation measures would have to be employed under the guidance of the 

district hydrologist or fisheries biologist.

4. Treatment in prescribed burn units would avoid direct lighting for prescribed fire within 

riparian vegetation and or within 5 feet of the edge of stream channel; prescribed fires 

may back into riparian vegetation areas. 

5. Living woody, riparian vegetation would not be willfully killed, destroyed or removed. 

Riparian vegetation includes but is not limited to the following species:

• Maples (Acer species)

• Alders (Alnus species)

• Dogwoods (Cornus)

• Poplars, cottonwoods, aspens (Populus species)

• Oaks (Quercus species)

6. Enough streamside shading would be maintained so as not to adversely affect the existing 

temperature regimes (confer with Phil Strand, Fisheries Program Manager for more 

information and guidance for shading requirements).

Roads

Forest Service system roads and temporary roads used for project activities would be constructed 

or brought to maintenance level 3 standards and follow relevant water quality protection BMP’s 

(Appendix C). Roads used in subdrainage 503.0056 would be repaired and rocked (especially at 

points of hydrologic connectivity and high stream bypass potential –Table 6, Figure 14) to 

mitigate the very high CWE potential in this subdrainage.

Table 6. Roads that have hydrologically connected drain points and culvert problems in 

subdrainage 503.0056.

Subdrainage Road Drain Points Hydrologically 

Connected to Streams or 

Meadows

Stream Crossings with 

Non-Functional 

Culverts

503.0056 06S011 3 3

06S013 6 0

06S013Y 4 0
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 47 Chapter 2

Figure 14. Points of hydrologic connectivity and bypass potential along system roads in 

subdrainage 503.0056. Repair of the crossings (i.e., culverts) and relocation of the 

hydrologically connected drain points should be part of the road maintenance plan for 06S0

Stream Crossings

The greatest potential for the proposed action or Alternative 3 to affect the hydrologic 

connectivity of streams and aquatic habitat exists at stream crossings. To minimize the potential 

for project-related effects on hydrologic connectivity, existing crossings would be used whenever 

possible. In the event that it is necessary to construct a temporary crossing, the methods used for 

construction would be selected to avoid or minimize detrimental soil and vegetation disturbance 

and to maintain hydrologic connectivity between upstream and downstream features. All 

temporary crossings would be removed following the completion of project-related activities and 

would be treated as necessary to restore to pre-project conditions (final approval of treatment to 

pre-project conditions would be done by the Timber Sale Administrator after consultation with 

the district hydrologist and/or forest fisheries biologist). Implementation of the activity-specific 

BMP’s (Appendix B) would further ensure that hydrologic connectivity in streams and special 

aquatic features not be adversely affected by the proposed action or Alternative 3.

Silviculture

1. An LOP would be imposed in well stocked stands heavy to fir (over 50% fir) where 

operations could begin August 1st or later when the sap is not running (fir bark is much 

more easily dislodged when the sap is running than later in the year). The District 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 48 Chapter 2

Silviculturist would determine which stands require a LOP during the thinning layout 

phase. 

2. Based on SNFPA ROD (USDA-FS 2004b) S&Gs for mechanical treatments, as well as 

design criteria, silvicultural prescriptions would be written utilizing thinning from below 

techniques with basal area levels for stand species composition.

3. To minimize the threat of insect attack, all pine logs created as a part of harvest 

operations would be removed from the sale areas as either logs or biomass material 

within 6 weeks of creation. Unutilized pine material would not be concentrated but 

spread to dry quickly or chipped and spread. Pine logs greater than 3 inches in diameter 

that are created between July 1st and October 15th and left in the stand would not exceed 8 

feet in length. 

4. Commercial thinning operations taking place before July 1st or after October 15 th in pine 

stands would require additional measures to minimize creation of pine slash 

concentrations. Additional bucking of slash may be needed to minimize creation of 

favorable insect breeding habitat. Any pine logs greater than 3 inches in diameter created 

after October 15th or before July 1st left in the stand should not exceed 4 feet in length. 

Precommercial thinning of pine stands should not take place before July 1st or after 

October 30th each year.

5. Where whole tree yarding is utilized, careful consideration must be given to the 

protection of the residual trees from damage. Rub trees (previously designated for 

removal) and/or rub logs should be retained where needed to minimize damage. These 

would then be removed upon completion of yarding. Skid trails should be as straight as 

possible and approved prior to skidding. Landing size should be kept to a minimum 

especially in areas where additional trees must be felled to create landings. To minimize 

landing size, logs/biomass should be removed as quickly as feasible from landings during 

skidding operations and not allowed to accumulate. 

6. During post sale treatments, 15 to 20 percent of the understory growth would be retained 

within plantations and wild stands in pockets approximately 1/10 acre in size. (When 

determining understory pockets to be retained, understory pockets around oaks, 

groupings of larger diameter trees, steep slopes, draws, etc. within treatment units would 

be included.) Understory pockets would not be retained in locations where they would 

jeopardize the effectiveness of planned fuels treatments.

7. To minimize damage to the residual stand, such as loss of canopy and hiding cover and 

reproduction needed to maintain stand structure and down logs, underburning in proposed 

T underburn stands should be undertaken during the spring when duff and down log 

moisture content is high and before actively growing trees become susceptible to 

excessive damage. Where concentrations of existing and/or created slash are present, 

spot piling may be needed prior to burning. Following thinning and prior to 

underburning, each stand proposed to be underburned should be reviewed by the District 

Silviculturist and the Fuels Officer to formulate prescriptions that ensure proper measures 

are in place to accomplish desired results. 

8. To minimize damage to the residual stand during slash piling, tractor size should be 

limited to a D-5 or smaller size tractor. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 49 Chapter 2

Fire/Fuels

SNFPA ROD (USDA-FS 2004b) S&G #1, 2, 3, 4, and 5 addresses fuels treatments. S&G #1, 2, 

3, 4, and 5 implementation criteria include: 

The utilization of prescribed fire to maintain appropriate levels of surface and ladder fuels to meet 

fire and fuels objectives would be conducted in prescribed fire treatment areas and units identified 

in the proposed action. To reduce the potential impacts (fire effects) that may occur with the 

implementation of prescribed fire, the following criteria would need to be considered in the areas 

where prescribed fire would be used:

1. Prescribed fire areas should be considered where there are larger residual trees (of size 

less susceptible to fire damage) with light fuel loadings, and/or areas where conifer 

reproduction is not being used for re-generation of openings.

2. Prescribed fire will be conducted as outlined in a burn plan, to minimize effects to trees 

during active growing period and within Spotted owl, Goshawks, and Pacific fisher 

denning habitat areas.

3.

4. The best available control measures (BACMs) for prescribed fire would be done as

required under Section 190 of the Clean Air Act, as amended in 1990.

5. Prescribed fire should be used during the late fall, winter, late spring or early summer, to 

minimize effects to trees during active growing period and within Pacific fisher denning 

habitat areas.

Air Quality

1. Avoid cumulative impacts to air quality by coordinating prescribed burning activities 

within the Forest, with burning activities conducted by others (SNF LRMP 1992 S&G # 

216)

2. Mitigate fugitive dust impacts on air quality by including dust abatement as a 

requirement for construction activities that have potential to generate dust (SNF LRMP 

1992 S&G # 217).

3. Avoid prolonged effects from prescribed burning activities on air quality by burning only 

on Air Quality Control Board (AQCB) approved burn days when satisfactory wind 

dispersion conditions prevail (SNF LRMP 1992 S&G # 218).

4. Participate with AQCB to qualitatively define air quality control regulations and 

guidelines and effects of air quality on the Forest, from sources outside the Forest (SNF 

LRMP 1992 S&G # 219).

5. Obtain appropriate permits prior to conducting prescribed burning activities (SNF LRMP 

1992 S&G # 220).

6. Incorporate air quality management considerations into fire management (SNF LRMP 

1992 S&G # 230).

7. Employ commonly used reduction techniques such as burning units after harvest before 

new live fuels appear; burning in the springtime prior to “green-up,” burning when 1,000-

hour fuels (woody debris larger than 3 inches in diameter) moistures are high, and 

burning when the duff is wet (after fall precipitation, or during winter and spring).

8. Employ avoidance techniques such as burning on cloudy days when the plume and 

residual smoke cannot be seen, burning during periods of atmospheric instability for 

better smoke dispersal, and burning during periods of low visitor use.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 50 Chapter 2

9. Employ techniques to optimize flaming combustion, including burning piled fuels rather 

than broadcast burning, reducing the amount of soil in piles, and employing rapid ignition 

to create a high intensity fire.

10. Ensure that all activities conform to the State Implementation Plan (SIP)

11. As part of prescribed fire implementation, burn bosses are to make observations on a 

regular basis of the smoke conditions that are being created by implementation. These 

include the travel direction and dispersion quality of smoke such as smoke settling into 

smoke sensitive areas and continued or potential for visibility degradation especially 

across main travel routes. When possible, lighting techniques and/or burn operations are 

changed to minimize the continuance of these impacts.

Engineering

1. Perform road maintenance, reconstruction, and new road construction activities to 

support project access needs in accordance with the standards and guidelines established 

in the Forest Plan, Forest Service Handbook 7709 and 6709, as well as the Bass Lake 

Ranger District Hazard Tree guidance (BLRD Hazard Tree EA 2006)..

2. Maintain all National Forest System roads to standards established in the.58. Insure 

drainage structures are functional and stable to prevent potential resource damage and 

degradation of water quality. (S&G #78, #79, #124, #206 and BMP’s)

3. Perform a final field review of project roads to determine reconstruction needs prior to 

project activities. Where economically feasible, place aggregate on existing native 

surface roads located in areas with high and very high soil erosion hazard ratings. (S&G 

#129)

4. Close all temporary roads required for unit access upon completion of use; remove all 

culverts, rip and ditch landings, construct waterbars, block the entrance with a log and 

dirt berm, and disguise the entrance with brush to discourage additional traffic. 

5. Roadways would be managed for safe passage by road users. This would include the 

management of hazards associated with roadside vegetation, including the identification 

and mitigation of danger (hazard) trees. A danger tree, as defined in Forest Service 

Handbook (FSH) 7709.59, Chapter 40, is a standing tree (live or dead) that presents a 

hazard to people due to conditions such as, but not limited to, deterioration or physical 

damage to the root system, trunk, stem, or limbs and the direction of lean of the tree (FSH 

6709.11, Glossary). Selection criteria guidelines for the marking and removal of danger 

trees would be tiered to the BLRD Hazard Tree Environmental Assessment, (USDA-FS 

2006a).

6. Water could be available for dust abatement during project activities; however, water 

may not be drafted from creeks if the stream flow is less than 1.5 cubic feet per second. 

Other methods of dust abatement such as trip restrictions, speed reductions, or approved 

dust oil may be considered as an alternative to using water. Disposal of clearing slash 

would be by pile and burn or chipping. Stumps may be treated by scattering beyond the 

toe-of-fill and below the road surface. When feasible, roads would be out sloped to 

reduce concentrations of water and soil erosion.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 51 Chapter 2

Monitoring Plan

Cultural Resources

Monitoring would be necessary to ensure that identified protection measures are effective 

(Regional PA, Stipulation IV and Interim Fuels Protocol, Stipulation VI) and proposed treatment 

measures have had no adverse effect to cultural resources. Monitoring shall occur within 1 year 

post-project implementation to assess short-term effects and then at intervals of once every three 

years for twenty years to assess long-term effects.

Botany 

Post project; monitor the Sensitive Plant occurrences within the project area to assess their 

presence and condition. Monitor for three to five years to ascertain that the noxious weeds have 

been eradicated successfully. 

Geology/Soils

Monitoring of soil conditions would be conducted on a selection of activity areas to determine if 

soil S&Gs and soil management objectives are being met. Eleven soil transects have been 

established in the project area to determine existing soil conditions. Six of these soil transects 

would be repeated after treatment is implemented. 

Monitoring would be accomplished in accordance with the National Forest Soil Disturbance 

Monitoring Protocol (USDA Forest Service, 2009). Soil monitoring would be conducted along 

transects according to the protocol after the proposed treatments. Soil monitoring should be 

designed to determine the extent of detrimental soil compaction from mechanical treatments. Soil 

cover should be determined from both mechanical treatment and prescribed fire. After 

implementation of the proposed action, pre-treatment soil transects should be re-established in 

activity areas and post-treatment soil transects should be repeated along the same transect that 

were established for the pre-treatment soil transect. Timing for conducting post-treatment soil 

transects is important to determine soil cover after prescribed fire, especially soil cover condition 

going into the following winter.

Monitoring of meadows would consist of establishing photo monitoring points that would record 

the extent of existing conifer encroachment. Photos would be taken initially before treatment and 

every three years for 15 years. Additional monitoring of the reclaimed OHV trail within meadow 

503M7 would be completed primarily looking for the regeneration of native plants and grasses 

along the trail and for the occurrence of unauthorized OHV usage.

Terrestrial Wildlife

It may be possible to lessen the potential effect of CWE in subwatershed 503.0056 by reducing 

the number of acres treated within the HUC8 subwatershed or reducing the miles of system road. 

In addition, correcting problems with road drainage and surface erosion of the road surface could 

reduce effects from a CWE. If all of the treatments proposed within this subwatershed are 

adopted, a Stream Condition Inventory Plot should be established downstream of the site and 

include V* (Hilton and Lisle 1993) to measure possible effects to aquatic habitat.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 52 Chapter 2

Range 

Establishment of additional long term meadow condition and trend monitoring plots for Texas 

Flat Meadow and Progeny Meadow sites are recommended in order to assess meadow ecological 

status and trend and trend and also to determine the effectiveness of the channel restoration and 

conifer removal on these ecological factors. 

Fire/Fuels

Monitoring of the conditions following initial treatments would be completed to determine if 

additional treatments are needed to meet fire and fuels objectives. Particular attention would be 

given to those treatment areas associated with SPLATs and DFPZs surrounding the identified 

communities, as these are the priority areas within the project for follow-up treatments to reduce 

surface fuels, if needed.

Air Quality

As part of prescribed fire implementation, burn bosses are to make observations on a regular basis 

of the smoke conditions that are being created by implementation. These include the travel 

direction and dispersion quality of smoke such as smoke settling into smoke sensitive areas and 

continued or potential for visibility degradation especially across main travel routes. When 

possible, lighting techniques and/or burn operations are changed to minimize the continuance of 

these impacts.

Alternatives Considered and Eliminated from Detailed 

Study

Federal agencies are required to rigorously explore and objectively evaluate all reasonable 

alternatives and to briefly discuss the reasons for eliminating any alternatives that were not 

developed in detail (40 CFR 1502.14). Public comments received in response to the Proposed 

Action provided suggestions for alternative methods for achieving the purpose and need. Some of 

these alternatives may have been outside the scope of the need for the proposal, duplicative of the 

alternatives considered in detail, or determined to be components that would cause unnecessary 

environmental harm. 

Four action alternatives were proposed, two of which were considered and eliminated from 

detailed study. 

An alternative was suggested that would use high intensity fire to create high severity fire effects 

to create and increase snag habitat for avian wildlife species. 

This alternative was eliminated because, the environmental conditions that would be required to 

produce the required fire behavior only occurs during summer month’s within fire season and the 

fire behavior that would be associated with these conditions could not be easily kept within the 

planned treatment units by holding forces. The benefits would be far outweighed by the resource 

damage that would happen should an escape occur

An alternative was suggested that would use landscape scale fires to manage fuels and vegetation 

instead of logging. 

This alternative was eliminated because; the use of prescribed fire alone would not meet the 

purpose and need for this project. On favorable terrain structural restoration needs would need to 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 53 Chapter 2

be completed mechanically with a follow-up with prescribed fire. Prescribed fire only treatments 

are planned for areas that are too steep for mechanical treatments and would link together treated 

areas to provide fuels modifications to help limit wildfire spread over large areas. This project 

has over 2300 acres of proposed prescribed fire.

An alternative was considered that would allow mechanical treatments in 100 acres of 

subdrainage 503.0056.

This alternative was eliminated because it has substantially similar consequences as alternatives 

considered in detail with the exception of hydrologic resource impacts; it is not significantly 

distinguishable from alternatives already being considered and it would require a SNF LRMP 

amendment due to CWE threshold exceedance. After considering the potential beneficial 

ecological effects of treatment (100 acres without an extreme forest health need) and the potential 

hydrologic impacts there was not sufficient ecological benefit to risk the CWE effects.

An alternative was suggested that would “within the acres of natural forest proposed for 

mechanical/commercial thinning, instead of the live trees over 16” dbh being removed, the trees 

that would otherwise be marked for removal would instead be girdled or killed in some other way 

in order to actively recruit more large snags for wildlife, or such trees would be felled to provide 

large downed log structure for small mammals, amphibians, and invertebrates”.

This alternative was eliminated because implementation of this alternative would lead to an even 

greater concentration of unnaturally high fuel levels, making the Project area and nearby human 

communities even more susceptible to impacts from an uncharacteristically severe wildfire and 

therefore it would not meet the following component of the purpose and need for the Project:

• “Protect human communities from moderate/high intensity wild fires as well as minimize 

the spread of wildfires that might originate in urban areas into the forested lands created 

by unnaturally high levels of fuel ladders and dead and downed fuels.” (pg. 6).

An alternative was considered that would limit treatments within fisher habitat, specifically the 

alternative would not allow treatments within the 0.4 and greater CBI predicted probability of 

occurrence model for fisher. This alternative was eliminated for several reasons: 

1. This alternative does not meet the first two objectives stated in the purpose and need which are 

to “Protect human communities from moderate/high intensity wildfires as well as minimize the 

spread of wildfires that might originate in urban areas into the forested lands created by 

unnaturally high levels of fuel ladders and dead and downed fuels”; and to “Improve resiliency in 

stands that are currently overstocked and are becoming more susceptible to attack from insects, 

diseases, drought conditions, and/or wildfire”. As more than 88% of the project area is within the 

CBI ≥0.40 predicted probability of occurrence, limiting treatments to the areas outside of fisher 

habitat would significantly compromise the ability of the project to meet its desired objectives, 

including the protection of human communities from moderate/high intensity wild fires. 

2. Since the effects of fuels reduction treatments on fire spread are relatively local, recent studies 

have shown that treatments inside fisher habitat may better protect that habitat from 

fragmentation and other effects of uncharacteristically large or severe wildfires (Spencer et al. 

2008; Scheller et al. 2011). Scheller et al. 2011 states “Under the baseline fire regime, the 

placement of simulated fuel treatments within primary fisher habitat provided the greatest net 

benefit to fishers....If treatments are placed too far from fisher habitat, they may only affect fires 

locally and not provide the indirect positive benefits that would occur from reducing the spread of 

severe fire near fisher habitat.” (Sheller et al. 2011).
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 54 Chapter 2

Comparison of Alternatives ___________________

The following table displays a summary of the alternatives and their environmental impacts in 

comparative form. As one can see in the table, there is little difference in overall treatment acres, 

however because Alternative 2 (Proposed Action) uses structural and process restoration 

treatments, the potential for meeting the desired conditions of ecological restoration is much 

higher than in Alternative 3 which uses limited levels of structural restoration treatments and 

process restoration treatments. 

Table 7. Comparison of the Components of the Alternatives

Proposed action Treatments Units of 

Measure

Alternative 

1

No Action

Alternative 

2

Proposed 

Action

Alternative 

3

Fire/Fuels

Structural Restoration 

Treatments

Commercial 

Thinning Acres 0 1535 0

Mechanical Fuels and 

Vegetation Treatments Acres 0 882 2417

Handwork Fuels and Vegetation

Treatments Acres 0 124 124

Mastication Fuels and 

Vegetation Treatments Acres 0 318 318

Fuel Break Construction and 

Reconstruction Acres 0 325 325

Reforestation Acres 0 50 50

Meadow Restoration

(Conifer Eradication) Acres 0 13 13

Meadow Restoration

(WIN Site Work) Acres 0 36 36

Developed Recreation Sites 

(Hazard Tree and Thinning) Acres 0 31 31

Cultural /Historical Site 

Restoration Acres 0 100 100

Noxious Weed Management Acres 0 10 10

Wildlife Habitat Restoration Acres 0 36075 3607

 5 Acres of wildlife habitat improved through: 1. reducing the risk of uncharacteristically severe, standeliminating wildfires. 2. Promoting stand heterogeneity of forest vegetation, thereby making it more 

resilient to natural disturbances, and enhancing native wildlife species habitat and diversity. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 55 Chapter 2

Range Maintenance

 (Stock Drive) Miles 0 7.6 7.6

Road Maintenance Miles 0 56 0

Road Reconstruction Miles 0 20.3 0

Temporary Road construction Miles 0 0.25 0

Designated OHV Trail 

maintenance Miles 0 5.5 5.5

User Defined OHV Trail 

Reclamation Miles 0 0.42 0.42

Process Restoration 

Treatments

Prescribed Fire 

(Initial Entry) Acres 0 596 596

Prescribed Fire 

(After structural restoration 

treatments have been 

completed)

Acres 0 1855 1855

Total Process Restoration Acres 0 2451 2451

∗ These acres represent an acre of each treatment. Many of these treatments occur on the 

same actual acre. For example, a single acre may have thinning, piling lop and scatter and 

underburn treatments all prescribed. For this reason, the total number of treatment acres 

may appear to exceed the total number of acres to receive fuels treatments. Treatments 

unit of measures are approximate. 
Sierra National Forest – 56 Chapter 2

Table 7a Comparison of the Effects of the Alternatives

Alternative 1

No Action

Alternative 2

Proposed Action

Alternative 3

Fire & Fuels 

Measures: 

Brush 

Areas

ForestMod. To

Heavy 

Fuel 

level 

Areas

Brush 

Areas

Mixed 

Conifer

Heavy 

Fuels/Sl

ash

Mixed 

Conifer

Fuels 

treated

Fir 

Stands

Fuels 

treated

Brush 

Areas

Mixe

d 

Conif

er

Heav

y 

Fuels

Mixed 

Conifer

Fuels 

Treated

Fuel Model (Resultant)

SH5 TU5

SB1,T

U1,SB

2

SB2 TL8 TL1, 

TL3 SH5 TU5 TL8

Predicted Rate of Spread 

(chains/hour) 68 11 3.3-19.4 19.4 7.6 1.2-2.2 68 11 7.6

Predicted Flame Length 

(feet) 16 8.5 2.0-7.3 7.3 4 0.7-1.3 16 8.5 4

Predicted Fireline 

Intensity (BTU/ft2) 2259 606 27-431 431 117 3-9 2259 606 117

Predicted Crown Fire 

Potential (Yes/No; Type) Yes

Crown

Yes

Crown

No 

Surface

Yes 

Torching

No 

Surface

No 

Surface

Yes

Crown

Yes 

Crown

No 

Torching

Resistance to Control 

(High, Moderate, Low) Extreme Mod/ 

High

Low/ 

Mod Mod Low / Mod Low Extreme

Mod/Hi

gh

Mod/ 

High

Conifer Mortality 

(%) Fir & Pine 99/80 34/44 0 to 

17/14 21/22 0/0 0 99/80 34/44 0/0

Estimated Range of 

Basal Area Remaining 

(ft2/acre) for >10-inch 

dbh trees

Wild Stands = 120 – 240ft2

(pockets to 360ft2)

Wild Stands = 120 – 510ft2

Estimated Range of 

Stems per Acre 

Remaining for >10-inch 

dbh trees (# trees/acre) Wild Stands = 40 to 85 trees W/Stands = 75 – 160 trees

Estimated Range of 

Canopy Cover 

Remaining (%)

Wild Stands = 39 – 85%

 (majority 60%+)

W/Stands = 39 – 85%

 (majority 75%+)

Estimated Range of 

Tree Diameter 

Remaining (> 10” dbh)

Wild Stands = 10” – 52”

Avg. dia. all stands will increase

W/ Stands = 10” – 52”

Avg. dia. all stands will 

remain the same
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 57 Chapter 2

Alternative 1

No Action

Alternative 2

Proposed Action

Alternative 3

Fire & Fuels 

Large Snag and Down 

Wood Standard for 

Treated Areas

In the event of an 

uncharacteristically 

severe wildfire, 

projected loss of nearly 

all current snags and 

down wood.

Maintain a minimum of 4 of the largest 

snags per acre. 

Listed in Design Criteria Common to All 

Alternatives (pages 24

Listed in Design Criteria 

Common to All 

Alternatives (pages 24)

Saw Log Volume/Value

ccf & $

0 15,184 / $2,958,401 0 / 0

Biomass 

Volume/ costs

tons & $

0 2211 / $64,107 2211 / $64,107

Road Reconstruction 

Cost

$

0 $133,012 0

Road Maintanence Cost

$

0 $44,945 0

Temporary Road 

Construction Cost

$

0 $1,822 0

Non Harvest Treatments 

Cost

$

0 $887,715 $887,715

Estimated Revenues 

$ 

0 $(339,502) $(951,823)

Fire Reduction Benefits 6

$

0 $1,678,014 $1,678,014

Jobs & Employee 

Related Income

#’s jobs & $

0 108 / $4,944,784 17 / $680,000

Numbers within parentheses are negative

 6 C. Larry Mason et al. Jan/Feb 2006. Investment in Fuel Removals to Avoid Forest Fires Result in 

Substantial Benefits. Journal of Forestry:27-31 (total of firefighting cost avoided and timber loss avoided)
Sierra National Forest – 58 Chapter 3

Chapter 3. Affected Environment and 

Environmental Consequences

This chapter describes aspects of the environment likely to be affected by the proposed action and 

alternatives. Also described are the environmental effects (direct, indirect, and cumulative) that 

would result from undertaking the proposed action or other alternatives. Together, these 

descriptions form the scientific and analytical basis for the comparison of effects in Chapter 2.

Past, Present and Reasonably Foreseeable Actions _

According the CEQ NEPA regulations, “cumulative impact” is the impact on the environment 

which results from the incremental impact of the action when added to other past, present, and 

reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or 

person undertakes such actions (40 CFR 1508.7). 

In order to understand the contributions of past actions to the cumulative effects of the proposed 

action and alternatives, this analysis relies on current environmental conditions as a proxy for the 

impacts of past actions. This is because existing conditions reflect the aggregate impact of all 

prior human actions and natural events that have affected the environment and might contribute to 

cumulative effects.

This cumulative effects analysis does not attempt to quantify the effects of past human actions by 

adding up all prior actions on an action-by-action basis. There are several reasons for not taking 

this approach. First, a catalog and analysis of all past actions would be impractical to compile and 

unduly costly to obtain. Current conditions have been impacted by innumerable actions over the 

last century (and beyond), and trying to isolate the individual actions that continue to have 

residual impacts would nearly be impossible. Second, providing the details of past actions on an 

individual basis would not predict the cumulative effects of the proposed action or alternatives. In 

fact, focusing on individual actions would be less accurate than looking at existing conditions, 

because there is limited information on the environmental impacts of individual past actions, and 

one cannot reasonably identify each and every action over the last century that has contributed to 

current conditions. Additionally, focusing on the impacts of past human actions risks ignoring the 

important residual effects of past natural events, which may contribute to cumulative effects just 

as much as human actions have. Third, public scoping for this project did not identify any public 

interest or need for detailed information on individual past actions. Finally, the CEQ issued an 

interpretive memorandum on June 24, 2005 regarding analysis of past action, which states, 

“agencies can conduct an adequate cumulative effects analysis by focusing on the current 

aggregate effects of past actions without delving into the historical details of individual past 

actions.”

The cumulative effects analysis in this EIS is also consistent with Forest Service NEPA

Regulations (36 CFR 220.4(f)) (July 24, 2008), which states, in part:

“CEQ regulations do not require the consideration of the individual effects of all past actions 

to determine the present effects of past actions. Once the agency has identified those present 

effects of past actions that warrant consideration, the agency assesses the extent that the 

effects of the proposal for agency action or its alternatives will add to, modify, or mitigate 

those effects. The final analysis documents an agency assessment of the cumulative effects of 

the actions considered (including past, present, and reasonably foreseeable future actions) on 

the affected environment. With respect to past actions, during the scoping process and 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 59 Chapter 3

subsequent preparation of the analysis, the agency must determine what information 

regarding past actions is useful and relevant to the required analysis of cumulative effects. 

Cataloging past actions and specific information about the direct and indirect effects of their 

design and implementation could in some contexts be useful to predict the cumulative effects 

of the proposal. The CEQ regulations, however, do not require agencies to catalogue or 

exhaustively list and analyze all individual past actions. Simply because information about 

past actions may be available or obtained with reasonable effort does not mean that it is 

relevant and necessary to inform decision-making. (40 CFR 1508.7)”

In determining cumulative effects, the effects of the following present and future actions were 

added to the direct and indirect effects of the proposed action and alternatives
Sierra National Forest – 60 Chapter 3

Table 8. Present and Reasonably Foreseeable Actions Contributing to Cumulative Effects by Resources this Action is likely to affect.

Activity Type Description Year Unit Of 

Measure

Air Quality

Aquatics

Botany

Fire/Fuels

Cultural Res.

Vegetation

Soil

Transportation

Watershed

Wildlife

Use of Roads/Trails 

USFS, County, State 

owned and 

maintained

Includes the network of 

inventoried road/trail 

systems within project 

subwatersheds 

On-going 62 (mi) X X X X X X X X

Use of Campground 

and other USFS 

Owned Facilities

Greys Mountain, 

Chilkoot, Soquel and 

Texas Flat 

Existing

and on 

going

4 sites X X X X X

Past/Current USFS 

Timber Sales within 

Greys Mountain 

subwatersheds

Includes:

• Green Timber 

Sales

• Salvage Harvest 

• Thinning

Existing 

and 

ongoing

Approx. 7415 

acres X X X X X X X X X X

Special Use Permits 

which include , 

buildings, corrals, 

and trails. 

Range Improvements

Existing

and 

ongoing

Approx. 25 

acres

X X X

Roadside Hazard 

Tree Removal

Removal of damaged, 

rotten, dead trees to abate 

roadside hazard using 

timber sale contracts. 

2003-

present 17 (mi) X X X X X X X X X

Fire/Fuels 

Management 

Activities

Includes Fuelbreak 

Construction and 

Maintenance, Prescribed 

Burning, ladder fuel 

1980spresentApprox. 493

acres

X X X X X X X X X
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 61 Chapter 3

Activity Type Description Year Unit Of 

Measure

Air Quality

Aquatics

Botany

Fire/Fuels

Cultural Res.

Vegetation

Soil

Transportation

Watershed

Wildlife

removal, mastication

Private Land 

Infrastructure for 

communities of 

Calvin Crest, Soquel 

Meadow and 

Paradise Springs

New home construction, 

power, water, private 

roads

Ongoing Approx. 378 

acres

X X X X X X X X

Private LandVegetation 

Management in 

communities and 

other private lands

Timber harvesting, land 

type conversions

Hazard fuels reduction

Ongoing

Individual 

Community 

Private Acres

X X X X X X X X

Special Use 

Permitted Activities

Apiary (1 sites),

Road Easments (2 sites)

Mining Claims (1 site)

Ongoing

Various 

MeasuresMapped 

Locations

X X

Motorized 

Recreation

Pleasure driving; 4x4, 

OHV, and snowmobile 

uses of system and 

temporary roads

Ongoing Approx. 100

mi X X X X X X X

Livestock Grazing Soquel and Central 

Camp Allotments Ongoing X X/X X X X X

Fish Camp Project Forest Health and Fire 

and Fuels Project

Outyear 

planning 5000 acres X X X X X X X X X
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 62 Chapter 3

Cultural Resources

The direct, indirect and cumulative effects to Cultural Resources below are summarized from the 

Greys Mountain Project Cultural Resources Report (Potter E., Mogge M., 2012).

Affected Environment

Existing Condition

All throughout the SNF are the remnants of past cultures that illustrate the centuries-old 

relationships between people and the land. These cultural resources hold clues to past ecosystems 

and human adaptations to them, provide links between living communities and the Forest’s 

unique prehistoric and historic land uses, and help transform a visit to the woods into an 

encounter with history. These cultural resources comprise an irreplaceable and non-renewable 

resource record of past human life and land use. This record is contained in properties with 

archaeological and historical research value, and locations of cultural importance to local Native 

American groups. 

Archaeological and Historic Values: 

Physical remains of over 10,000 years of human history are found throughout the SNF. Except 

for the last century and a half of written history, the only record of this long human use is the 

remains left by the original native people and their descendants. At the time of contact with 

Euro-Americans, in the late 1700s and early 1800s, the Fresno River was the boundary between 

the Southern Sierra Miwok to the north and west, and the Chukchansi Yokuts to the south and 

east. The Western Mono occupied the area around what is now Bass Lake up to the crest of the 

Sierra Nevada range. The boundaries between the groups were ambiguous, with a lot of overlap 

in the area between the Miwok, Yokuts and Mono. 

The processes of subsistence, the hunter-gatherer lifestyle, and the resulting indigenous land use 

are seen in the archaeological record with features common to the material culture of the native 

people of the Sierra Nevada (e.g., village sites, bedrock mortars, stone tool artifacts). Some of 

these sites have ethnographic documentation that indicates a fairly recent history of tribal use; in 

some cases, tribal use continues at sites that have an occupational history that spans thousands of 

years.

Historic-era cultural resources reflect particularly the cultural and economic products of the rapid 

pace of technological achievement in the last 150 years imposed on the terrain of the Sierra 

Nevada. These resources often reflect environmental changes resulting from industrial and 

technological advances in resource extraction, landscape use, and management. Sites include 

remnants of exploration and settlement, Forest Service administration, grazing/range 

management, mining, transportation, travel, tourism and recreation, and the forest products 

industry. Each of these themes has an array of associated sites and features. For example, 

features associated with railroad logging operations may be work camps, refuse dumps, railroad 

grades, trestles, and discarded equipment.

Native American Cultural Values: 

There is a deep and abiding concern with many Native American people about what occurs in 

their aboriginal territory. The SNF honors the traditional ties that many tribal communities and 

Native American people have to this portion of the Sierra Nevada. Access to and use of the 

Forest and other public lands is critical for many Native American people, as community identity 

and cultural survival are dependent on continued access to ceremonial and sacred places, 

cemeteries, traditional gathering areas, traditional cultural properties, and resources at a variety of 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 63 Chapter 3

locations on forest land. Certain plants, animals, and locations provide for many needs, including 

food, medicine, utilitarian type materials, and ceremonial items. Specific resources insure that 

significant cultural traditions, such as basket weaving, survive and continue. These areas 

contribute to the tribal communities’ way of life, their identity, their traditional practices and 

cohesiveness. 

Contemporary Native American interests can include traditional cultural properties (sites 

associated with cultural practices or beliefs that are rooted in history and important in maintaining 

cultural identity), and plant gathering sites for basket materials, medicines, and food resources. 

The SNF manages such known sites as cultural resources under the provisions of the NHPA. The 

location of these sites is kept administratively confidential. The SNF will maintain appropriate 

access to sacred and ceremonial sites, and to tribal traditional use areas, and has consulted with 

affected tribes and tribal communities to address access to culturally important resources and 

areas in this project analysis.

Current Condition:

Cultural resources are the buildings, sites, areas, architecture, and properties that bear evidence of 

human activity and use across the landscape, and have scientific, historic, and cultural 

importance. The results of 32 years of cultural resource surveys and investigations have 

identified approximately 72 historical and archaeological properties and numerous miles of linear 

segments related to logging history within the 9600 acre project area. Site types include 

prehistoric habitation and processing locales and historic railroad logging, mining, and 

homesteading. With new discovery upon almost every new survey effort, there continue to be 

many undiscovered cultural resources in the SNF.

The cultural resource landscape on the SNF is a complex arrangement of scattered archaeological 

and historical sites, dense district components, and an intricate network of linear sites (e.g., 

railroad grades, log chutes, mining ditches, water diversion ditches, etc.). Often, these varying 

components are overlapping in space, but not time. Other components are overlapping in time, 

spanning the proto-historic and historic periods where the same site will elicit artifacts typically 

designated either “prehistoric” or “historic”, but that were used contemporaneously. Though the 

NHPA was passed in 1966, a concerted effort to incorporate the law into Forest management 

practices throughout the nation did not occur until the late 1970s. Therefore, historic practices 

often had effects on prehistoric cultural resources, while subsequent historic practices had effects 

on earlier historic resources. With the implementation of Forest Heritage Resource Programs, an 

effort to protect resources 50 years old or older began with large scale surface inventories and 

recordation of cultural resource sites. To date, the SNF has recorded approximately 5,000 

cultural resource sites. Large expanses of the forest, largely in designated wilderness, remain 

unsurveyed but undoubtedly contain additional cultural resources.

For over 30 years, standard cultural resource management practices have focused on avoiding 

potential project impacts on cultural resources. While this is an effective method to mitigate 

potential project impacts, this practice has at times led to an unnatural density of ladder fuels (see 

Figure 15) and created the potential for significant damage in the form of partial or total loss of 

the resources should a high intensity fire occur, which can be devastating to resources with 

wooden components and quite detrimental to the non-wooden components (Deal 2002; Gassaway 

2011; Shultz 2004; Winthrop 2004). Additionally, the increase in fuels has altered the original 

setting for most cultural sites. Several prehistoric sites that had exposed features, access to water 

resources, and a viewshed have been encroached by an understory that detracts from its setting by 

obscuring features and the viewshed and has left the water resources difficult to access or has 

substantially decreased the amount of water available. Prehistoric artifacts such as obsidian and 

features such as milling stations and historic artifacts such as glass and features with wooden 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 64 Chapter 3

components can be damaged by high intensity fire to the extent that the artifacts and features may 

no longer contribute to the data potential of a cultural resource (Shultz 2004). 

Figure 15. Looking down cultural resource boundary within Greys Mountain Ecological 

Restoration Project area; previously treated unit to left of pine in center of photo; cultural 

resource site with heavy fuel loading to right of pine.

Historically, it was not uncommon for logging railroads and roads to be constructed through 

prehistoric archaeological sites. Similarly, many historic railroads and wagon roads were 

converted to FS system roads over time. While a road passing through or overlaying a cultural 

resource may have had some effect on that resource, this is not always the case and often 

prehistoric resources retain subsurface integrity, while historic linear systems often maintain 

many aspects of integrity including setting, design, location, association, materials, workmanship 

and feeling. 

Desired Condition 

The desired condition for cultural resources is based on the identified Indicator: preservation of 

those characteristics and values that qualify a cultural resource for National Register eligibility. In 

addition, enhancement of those values that contribute to National Register eligibility is sought. 

Environmental Consequences 

Methodology Data Sources

Existing information from cultural resource records, historic archives, maps, and Global 

Information System (GIS) spatial layers was reviewed to provide specific information about 

cultural resources, or the likelihood that unidentified properties might exist in the project area. 

Approximately 1/3 of the project area had been surveyed to current standards for prior projects 

between 1981 and 1987. Because the SNF does not shovel test during survey, the possibility for 

cultural resources buried under heavy duff and vegetation and/or cultural deposits buried by 

erosional activities does exist. For areas that had never been surveyed or required re-survey, 

current survey was conducted using an intensive (0 – 30 meter transects) coverage. 

Approximately 430 acres are located on slopes greater than 30% slope and/or are small pockets of 

impenetrable brush. Per the Interim Fuels Protocol, a non-intensive survey strategy including 

post-implementation monitoring is being utilized. Survey in areas of impenetrable brush would

be deferred until after project implementation per the Interim Fuels Protocol. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 65 Chapter 3

To evaluate candidate sites for proposed treatments, known sites within treatment units were 

visited to assess the density of fuels and the current setting. Proposed treatment within these sites 

would comply with stipulations and standard protection measures of the Regional PA and the 

Interim Fuels Protocol. Analysis is based on preserving and enhancing those characteristics and 

values that make a cultural resource site eligible for the NRHP.

Cultural resource compliance for this project is documented in Greys Mountain Ecological 

Restoration Project Archaeological Reconnaissance Report (Draft), ARR R2012051551005

(Potter 2012). This report, which describes the location and composition of the cultural resource 

sites within the project boundary, is kept administratively confidential under the provisions of the 

Archaeological Resource Protection Act of 1979, 36 CFR 296 and 36 CFR 800.11(c) 

Confidentiality.

Spatial and Temporal Context for Effects Analysis 

Spatial Analysis 

The location and extent of the cultural resource is the unit of spatial analysis when considering 

effects in action alternatives. For some cultural resources (e.g., Traditional Cultural Property), 

the setting beyond the cultural resource location must also be considered when determining 

whether an adverse effect would occur.

Effects Timeframes

• Short-term effects occur within one year. 

• Long-term effects occur up to 20 years. 

• Cumulative effects are analyzed at a 20-year interval.

Alternative 1 – No Action 

Direct and Indirect Effects 

Numerous studies have been conducted on fire effects to cultural resources. Typically, effects are 

categorized as direct, operational/suppression, and indirect (Shultz 2004; see also Gassaway 

2011) and can be the result of both wildland fire and suppression effects and effects from fire 

management of prescribed burns. The severity of effects on cultural resources is dependent upon 

the temperature of a fire and the amount of time those resources are exposed to heat. Usually, the 

higher the temperature and longer duration of heat exposure, the greater potential a cultural 

resource has to be irreparablely damaged. Experimental studies have shown that, in general, 

buried deposits are typically not adversely affected by burning (Deal 2002), but surface deposits 

both underneath the duff layer and above have been demonstrated to lose data potential. For 

example, a common dating technique used in Central California is obsidian hydration which 

measures the rate of water hydration on a worked surface (hydration rim). The hydration rim is 

used to determine relative age of an artifact. At 300 C (572 F) diffusion of obsidian bands begins 

to occur and the band is no longer visible at 400 C (752 F). At 760 C (1292 F), obsidian may 

melt altering the morphology of the artifact (Winthrop 2004). 

Direct effects from fire on cultural resources are caused by exposure to flame, proximity to heat 

or effects of smoke (Gassaway 2011). Indirect effects typically occur after a fire as a result of 

changes in soil and vegetation. These include an increase in soil erosion which can bury or 

displace cultural deposits, an increase in tree mortality which can also displace cultural deposits 

through uprooting or damage deposits through falling, and an increase in rodent activity which

also displaces cultural deposits and affects the soil structure (Gassaway 2011). Indirect effects 

can also occur in the form of looting and site vandalism due to increase exposure and ease of 

access to cultural resource sites. Operational/suppression effects occur from management 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 66 Chapter 3

activities associated with a fire including construction of fire lines through hand and mechanical 

methods and development of staging areas.

The degree of effects to cultural resources from burning is dependent upon type of fuel, fuel load, 

fuel moisture content, soil type and moisture content, weather, and terrain. In the project area, 

there is a combination of ground, surface and crown fuels. Many cultural sites have become 

overgrown with vegetation creating fuel ladders. 80 percent of the project area has significantly 

departed from historic fire regime intervals and developed a load of ladder fuels. The duration of 

heat exposure and temperature would be significantly increased during a wildfire.

Should a wildfire occur, indirect effects could occur as a result of increased access to and 

visibility of cultural resources, increasing the likelihood of adverse effects from artifact looting. 

Cultural resources severely affected by wildfire are also subject to effects from increased surface 

runoff and erosion, increased tree mortality which may displace artifactual and morphological 

context should a tree uproot, and an increase in rodent burrowing and insect populations which 

may affect vertical and horizontal distribution of artifacts (Gassoway 2011). Lack of road 

maintenance may also affect linear resources through erosion, blow-outs where culverts are 

plugged and effects to morphological features. 

Due to the policy of project avoidance of cultural resources, trees and brush within historic 

resources, including railroad grades, have grown substantially contributing to an altered setting 

and in some places have affected the integrity of the sites. For instance, the walls of through-cuts 

and the down slope of fill on railroad grades have been compromised where trees and their roots 

have grown through the side walls. When a tree falls, it often takes a part of the grade feature 

with it, thereby disrupting the design and solidity of the grade. The feature is no longer intact and

often continues to degrade through erosion and undermining of the resource. The spatial 

distribution of features is also a key element in a sitefts design. Where these features are 

obscured by underbrush or dense tree stands, a sitefts design is masked. Within the project area, 

there are a number of prehistoric and historic sites with an unhealthy increase in potentially 

devastating ladder fuels, and altered settings and designs. 

Cumulative Effects 

Cumulative effects on cultural resources can be variable as past, current and future actions within 

the project area have occurred and may continue in the future (i.e. logging activities, road 

construction). Historic logging, mining, homesteading and road construction activities did not 

account for the presence of prehistoric or earlier historic cultural resources. As no action would 

occur under this alternative, cumulative effects could result from benign neglect to address the 

fuel loading within cultural resource sites which could increase the potential for future adverse 

effects from high intensity wildfire resulting in a higher degree of erosion, looting resulting from 

increased visibility, and suppression effects, and would continue to adversely affect integrity of 

setting for cultural resource sites.

Compliance with Forest Plan and Other Relevant Laws, Regulations, 

Policies and Plans 

As no undertaking would occur in this alternative, compliance with Section 106 as outlined in its 

implementing regulations (36 CFR 800) and the Regional PA is not applicable. However, under 

Section 110 of the NHPA and Executive Order 11593, continued responsibility for protection, 

interpretation, evaluation, nomination, and preservation remain the responsibility of the Forest 

regardless of whether or not an undertaking occurs.
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Sierra National Forest – 67 Chapter 3

Summary of Effects 

This alternative has the potential for indirect effects on ~72 cultural resources and miles of linear 

historic resources since no land management activities would occur. As no action would occur 

under this alternative, cumulative effects are unlikely.

Alternative 2 – Proposed Action

Design Features and Mitigation Measures

Cultural resources would be protected through implementation of Standard Resource Protection 

Measures of the Regional (PA), the primary protection measure being avoidance for all project 

activities, including resource design criteria and through application of the Interim Fuels Protocol 

within selected cultural resource boundaries. 

Direct Effects 

This project seeks to restore the cultural resource landscapes for a limited number of sites closer 

to the time at which they were occupied. To accomplish this, proposed treatments would be 

utilized within site boundaries. A reduction in fuels through thinning of vegetation including 

hand and mechanical treatments and prescribed burning would not only enhance the setting, 

design and feeling of cultural resources, it would also protect these resources from the devastating 

effects of high severity wildfires enabling the future preservation of these resources. Future 

treatments may be required to maintain the desired condition within these resources.

There are approximately ~72 cultural resource sites and miles of historic linear resources that 

have the potential to be affected by implementing this alternative. Two of these sites are linear 

historic railroad logging and flume systems that have the potential to be adversely affected. 

These systems include railroad grades, spur grades, log chutes, and flume remains that retain 

intact earthworks and features such as sheave posts, trestle remains, retaining walls, and trash 

dumps. The majority of the cultural resource sites and features would be protected through the 

application of avoidance measures (Attachment B, Standard Resource Protection Measures, 

Regional PA). 

As noted in the fire history section, it has been determined that under certain burning conditions a

fire could severely affect the ecosystem within the project area beyond sustainable levels. This 

would be devastating to maintaining the characteristics and values of cultural resource sites 

necessary for NRHP eligibility. Several cultural resource sites within treatment units are 

proposed for treatment to enhance the setting of the cultural resources and reduce the adverse 

effects from a potential severe wildfire. Prescribed burning through designated cultural sites 

would reduce fuel loading and prevent future loss of data potential from excessive heat damage 

and minimize the need for suppression actions. In addition, Standard Resource Protection 

Measures of the Interim Fuels Protocol would be implemented to protect sites during prescribed 

fire implementation. 

Several of the WIN proposals may have an adverse effect to cultural resource sites, as they 

propose to remove or obliterate features of cultural resource sites and install new features. 

Reducing fuel loading along linear resources may inadvertently invite unauthorized vehicular 

groups to travel along them, potentially impacting their characteristic features. As these linear 

sites are not currently part of the designated motorized trail system, any such offense is subject to 

citation and closure signs shall be posted should a trail begin to develop. Post-implementation 

monitoring would be conducted to ensure unauthorized motorized travel is not occurring along 

these linear resources. 
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Sierra National Forest – 68 Chapter 3

Many roads within the project area would require heavy maintenance or reconstruction. This 

may include brushing, blading, construction of drainage dips, and replacing plugged or nonfunctioning culverts. As design criteria in the proposed action, prehistoric archaeological 

resources would be protected by padding in accordance with Standard Resource Protection 

Measures of the Regional PA. Where FS system roads overlay historic linear resources, 

continued use of FS system roads is consistent with stipulations of the Regional PA. Brushing 

typically does not affect, and may even enhance setting, of historic linear resources. Should a FS 

system road that overlays a historic linear resource within the project area require reconstruction 

that would alter the characteristics of the historic linear resource, that segment of the linear 

resource shall be evaluated for National Register eligibility prior to reconstruction. 

The four campgrounds in the project area were established between 1958 and 1960. Therefore, 

they qualify as cultural resources. For those campgrounds that still retain historic features, there 

is the potential for harvest operations to adversely affect these resources. In campgrounds 

proposed for thinning to improve stand health, Mechanical Treatment Stipulations of the Interim 

Fuels Protocol would be followed. Thus, harvest activities are not anticipated to have an adverse 

effect on this cultural resource type.

No historic values would be diminished as a result of implementing this alternative

Indirect Effects 

For those cultural resource sites with heavy fuel loading where no treatment is proposed, indirect 

effects are the same as Alternative 1. Indirect effects could occur as a result of mechanical 

treatment and prescribed burning operations through increased access to and visibility of cultural 

resources, increasing the likelihood of adverse effects from artifact looting. Follow-up patrols 

and monitoring should minimize this potential effect.

Cumulative Effects 

Cumulative effects could occur in the form of looting and vandalism through increased cultural 

resource visibility after project implementation. This can be mitigated through continued 

monitoring post-implementation. Cumulative effects could result from future vegetation 

management projects and road maintenance work. These potential effects would be mitigated 

through application of Standard Resource Protection Measures of the Regional PA and 

monitoring of site condition on a regular basis. Therefore, it is anticipated cumulative effects 

from this action alternative would be minimal.

Compliance with Forest Plan and Other Relevant Laws, Regulations, 

Policies and Plans 

Regulatory Framework

The FS is directed to identify, evaluate, treat, protect, and manage historic properties by several 

laws. The NHPA of 1966, as amended, provides comprehensive direction to federal agencies 

about their historic preservation responsibilities. Executive Order 11593, entitled Protection and 

Enhancement of the Cultural Environment, also includes direction about the identification and 

consideration of historic properties in Federal land management decisions. 

The NHPA of 1966, as amended, extends the policy in the Historic Sites Act of 1935 (49 Stat. 

666; 16 U.S.C. 461-467) to include resources that are of State and local significance, expands the 

NRHP, and establishes the Advisory Council on Historic Preservation (ACHP) and State 

Historic Preservation Officers. NHPA Section 106 directs all Federal agencies to take into 

account effects of their undertakings (actions, financial support, and authorizations) on properties 

included in or eligible for the National Register. The ACHP regulations (36 CFR 800) 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 69 Chapter 3

implements NHPA Section 106. NHPA Section 110 sets inventory, nomination, protection, and 

preservation responsibilities for Federally-owned cultural resources. 

Section 106 of the NHPA and the ACHP’s implementing regulations, Protection of Historic 

Properties (36 CFR Part 800), further requires that federal agencies provide the ACHP with an 

opportunity to comment on federal undertakings. Programmatic agreements (36 CFR 800.14(b)) 

provide alternative procedures for complying with 36 CFR 800. Region 5 has such an agreement: 

First Amended Regional Programmatic Agreement Among the U.S.D.A. Forest Service, Pacific 

Southwest Region, California State Historic Preservation Officer, and Advisory Council on 

Historic Preservation Regarding the Process for Compliance with Section 106 of the National 

Historic Preservation Act for Undertakings on the National Forests of the Pacific Southwest 

Region (Regional PA). This agreement provides specific standards for conducting cultural 

resources inventory, evaluation, and management, including Forest Heritage Program 

requirements, identification standards, standard procedures for protecting cultural resources, 

reporting and public participation. Attached to the Regional PA per Stipulation IX is the Interim 

Protocol for Non-Intensive Inventory Strategies for Hazardous Fuels and Vegetation Reduction 

Projects (Interim Fuels Protocol), allowing for non-intensive inventory and/or deferred inventory 

in areas of >30% slope and/or impenetrable brush in order to accomplish fuels objectives. 

Prescribed burning and mechanical treatments may occur within cultural resource boundaries in 

accordance with the stipulations and standard resource protection measures of the Interim Fuels 

Protocol.

Executive Order 11593 - Protection and Enhancement of the Cultural Environment, issued May 

13, 1971, directs Federal agencies to inventory cultural resources under their jurisdiction, to 

nominate to the NRHP all Federally owned properties that meet the criteria, to use due caution 

until the inventory and nomination processes are completed, and to assure that Federal plans and 

programs contribute to preservation and enhancement of non-Federally owned properties. 

In the Forest Land and Resource Management Plan (LRMP 1991), the SNF has identified three 

objectives to integrate cultural resource management with other multiple use management 

(LRMP 1991: 3.19):

1. Meet legal requirements for inventory, evaluation, and interpretation of cultural 

resources.

2. Assist local Native American communities in continuation and enhancement of their 

cultural traditions.

3. Interpret the culture history of the Forest for the public.

In accomplishing these objectives, the Forest needs to manage and protect cultural resources by 

monitoring activities and natural occurrences, and taking preventative and mitigative actions. 

Management direction emphasizes site identification, evaluation, and management (LRMP 1991: 

4.3.18) through a set of Standards and Guidelines (LRMP 1991: 4.5.2.15):

1. Identification: project-specific and forest-wide inventories for cultural resources (S&G 

193, 194).

2. Evaluation: National Register of Historic Places evaluations and nominations (S&G 193, 

195, 203).

3. Management: programs for contributions to research (S&G 196); coordination with 

Native Americans (S&G 197, 198); protection and preservation of sites (S&G 199, 200, 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 70 Chapter 3

201); development of management plans (S&G 202, 204); and interpretation of cultural 

history (S&G 205).

Federally Recognized tribal governments with interest in the SNF, as elsewhere in the United 

States, have a special political and legal relationship with the U.S. Government. Federally 

Recognized tribes are beneficiaries of a trust relationship with the Federal Government. In 

accordance with Section 106 of the NHPA, the SNF consults regularly with Federally Recognized

and Non-Federally Recognized tribes and other interested parties and is responsible for 

considering tribal interests. 

Consultation with tribes, the local Native American communities, and other interested parties to 

identify other cultural values, including contemporary Native American interests, was initiated 

with a Public Scoping Letter that was sent on May 31, 2011 to members and groups in the Native 

American community in accordance with NEPA policy. In addition, a consultation letter in 

compliance with Section 106 of the NHPA and Regional PA was sent to Native American 

community members and groups on September 9, 2011. Consultation has consisted of meetings, 

letters, and presentations, and is documented in the project record. At the time of publishing, the 

SNF has received no responses from the tribal community.

Summary of Effects 

By following the Stipulations and implementing the Standard Resource Protection Measures 

outlined in the Regional PA and the Interim Fuels Protocol and following cultural resource design 

criteria, no historic values would be diminished as a result of implementing this alternative. 

Potential effects to sites from proposed road reconstruction and WIN projects would be mitigated 

after SHPO consultation. Therefore, it is not anticipated there would be direct effects to cultural 

resources from this alternative. Potential indirect effects to cultural resources under Alternative 

2 are minimal and would be mitigated with post-implementation monitoring.

As all heritage resource sites would be protected through project design from current project 

activities and predictable future project activities, it is anticipated there would be no cumulative 

effects from this alternative.

Alternative 3 – Lower and Mid-Level Canopy Treatments, All 

Treatment Areas

Design Features and Mitigation Measures

Design features and mitigation measures would be the same as Alternative 2 with the exception 

of thinning through mechanical treatment within cultural resource sites under the Interim Fuels 

Protocol.

Direct, Indirect and Cumulative Effects 

Direct effects are the same as Alternative 2 with the exception of thinning through mechanical 

treatment within cultural resource sites. Indirect and cumulative effects will be the same as 

Alternative 2.

Compliance with Forest Plan and Other Relevant Laws, Regulations, 

Policies and Plans 

Compliance with Forest Plan and other relevant laws, regulations, policies, and 

plans for Alternative 3 is the same as Alternative 2.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 71 Chapter 3

Botany: Rare Plants and Noxious Weeds

The direct, indirect and cumulative effects to Botany below are summarized from the Greys 

Mountain Project Botany Report (Clines J., 2012).

Affected Environment

Existing Condition 

General description of the vegetation with an emphasis on rare plant habitat: The Greys 

Mountain project area is on the west slope of the central Sierra Nevada, and ranges in elevation 

from 3825 to 7160 ft elevation. The project area falls within the Sierra Nevada Ecological 

Section (M261E) in the USDA Forest Service National Hierarchical Framework of Ecological 

Units (Miles and Goudey, 1997). Vegetation varies from mixed chaparral, ponderosa pine and 

mixed conifer forest at low to middle elevations, to red fir and lodgepole forest at the higher 

elevations, with montane chaparral and montane meadows scattered throughout the area. 

The southern region of the project area has some areas of rock outcrops, which though often 

considered “barren” sites, are characterized by a suite of diverse native species adapted to live in 

the desert-like conditions of these exposed areas. These outcrops are not included in areas 

proposed for treatment as they do not have trees but they provide habitat for rare plant species, 

thus are protected from ground disturbance for this reason. 

The following summary of the vegetation within the Greys Mountain Project area sets the stage 

for analyzing effects of the alternatives on Forest Service Sensitive Plants by examining project 

effects on their habitat. 

CHAPARRAL: The lower elevations of the project area contain elements of foothill chaparral, 

dominated by mariposa manzanita (Arctostaphylos visicida ssp. mariposa) buckbrush (Ceanothus 

cuneatus), mountain mahogany (Cercocarpus betuloides), and foothill pine (Pinus sabiniana), 

but most of the chaparral in the project area is best classified as montane chaparral, dominated by 

greenleaf manzanita (Arctostaphylos patula), mountain whitethorn (Ceanothus cordulatus), 

deerbrush (Ceanothus integerrimus), littleleaf ceanothus (C. parvifolius), 

FORESTED AREAS: The lower reaches of the project area are forested by ponderosa pine forest 

dominated by a mixture of ponderosa pine (Pinus ponderosa), incense cedar (Calocedrus 

decurrens), and black oak (Quercus kelloggii) with an understory of mariposa manzanita, 

buckbrush, deerbrush, and canyon live oak (Quercus chrysolepis). Higher in elevation the forest 

changes to true mixed conifer forest with the addition of sugar pine (Pinus lambertiana) and a 

higher proportion of white fir. The understory shrubs are more typical of montane chaparral. At 

the highest elevations of the project area there are areas of red fir forest (Abies magnifica), with 

chinquapin in the understory and large areas devoid of herbaceous or woody plants in the 

understory. 

RIPARIAN VEGETATION: This vegetation type is adapted to wet or moist conditions and is 

found along streams and in meadows, springs, and seeps. Riparian vegetation along streams 

varies considerably within the project area, ranging from clearly defined bands of riparian forest 

dominated by white alder (Alnus rhombifolia), mountain alder (A. incana ssp. tenuifolia), willow 

(Salix spp.), and Oregon ash (Fraxinus latifolia) to simply a strip of herbaceous riparian plants 

with upland forest trees growing next to the stream. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 72 Chapter 3

MEADOWS AND FENS: There are several meadows within the project area: as well as several 

unnamed meadows. Meadows are defined as openings in forests which generally have high water 

tables dominated by herbaceous vegetation that is adapted to wet conditions. Meadows are 

typically heterogeneous, containing patches of different plant assemblages in response to 

variations in moisture, drainage, elevation within a given meadow. Overall, meadows can be 

classified as dry, moist, or wet; and montane, subalpine, or alpine (Ratliff, 1985). Some 

meadows contain areas of peat soils called fens. Fens are areas of perennial saturation where peat 

soils form because accumulation of organic matter exceeds decomposition (Cooper and Wolf, 

2006). Fens are of significance because of their contribution to hydrologic function in meadows 

and because they provide habitat for several rare plant species.

Forest Service Sensitive Plant Species in the Project Area

Sensitive species are those species that have been specifically designated by the Regional 

Forester as needing special management in order to prevent them from losing long-term viability 

or becoming federally listed as endangered or threatened; either because they are naturally rare or 

because their numbers have been reduced by human causes. In the SNF the former is generally 

the case. Much has been written about endemism and rarity in the California flora (e.g. Fiedler, 

2001: http://www.cnps.org/cnps/rareplants/inventory/rarity.php; and Shevock 1996: 

http://ceres.ca.gov/snep/pubs/web/PDF/VII_C24.PDF). Based on a review of the scientific 

literature, historical collections available through the Consortium of California Herbaria (an 

online search tool which allows viewing of specimens housed at most major herbaria in the state 

since scientific collecting began), there is no reason to suspect that the Forest Service Sensitive 

plant species known or suspected to be present in the Greys Mountain Project area were 

significantly more common in the past. 

Table 9 shows the Forest Service Sensitive Plants that are known to occur or that may occur 

within the Greys Mountain Project area based on the fact that suitable habitat is present. Species 

known to occur within the overall project boundary are shown in bold text:

Table 9. Forest Service Sensitive Plant Species Known or with Potential to occur within the 

Greys Mountain Project Area.

SPECIES

OCCURRENCE IN GREYS 

MOUNTAIN PROJECT 

AREA

HABITAT REQUIREMENTS

Bruchia bolanderi

BOLANDER’S CANDLE MOSS

None known to occur but 

suitable meadow / streambank 

habitat present. 

RIPARIAN/MEADOW. Vertical 

banks of streams, 5000-7500 feet.

Camissonia sierrae ssp. sierrae

MONO HOT SPRINGS 

EVENING PRIMROSE

None known to occur but 

rocky/gravelly habitat present. 

ROCKY/GRAVELLY. Gravel 

and sand pans and ledges 

associated with outcrops in 

chaparral, ponderosa pine, mixed 

conifer and red fir/lodgepole 

forests, 4500 – 8500 feet. 

Collomia rawsoniana

RAWSON’S FLAMING 

TRUMPET

Occurs along North Fork 

Willow Creek, which 

traverses unit T9. 

RIPARIAN/MEADOW. 

Streamsides and meadow edges 

2500 – 7000 feet. 

Cypripedium montanum

MOUNTAIN LADY’S SLIPPER 

ORCHID

None known to occur, many 

populations occur within 5 

miles of Greys Mountain 

Project area, but none were 

found during surveys in 2011 

FORESTED. Moist areas and dry 

slopes in late-successional conifer 

forest. Known from the vicinity 

of Nelder Grove to the west of the 

project, Mariposa Grove, 

Wawona, Sugar Pine, and Nelder 

Grove; 4000-7200 feet. 
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Epilobium howellii

SUBALPINE FIREWEED

None known to occur. The 

nearest occurrence is about 1 

miles away at Cold Springs 

Summit. 

RIPARIAN/MEADOW. Meadow 

edges, moist ditches and 

streamsides in conifer forest, 

5000-8800 feet. 

Fissidens aphelotaxifolius

BROOK POCKET -MOSS

None known to occur but 

habitat is present. 

RIPARIAN/MEADOW. Rocky 

substrate in streams, < 6300 feet. 

Helodium blandowii 

BLANDOW’S BOG-MOSS

None known to occur but fen 

habitat is present in several 

meadows. 

RIPARIAN/MEADOW. Wet 

meadows, fens, and seeps in 

coniferous forests, 6500 – 9500 

feet. 

Hulsea brevifolia

SHORT-LEAFED HULSEA

Four occurrences known, in 

dry forested habitat. 

FORESTED. Granitic or 

volcanic soils in openings and 

under canopy in mixed conifer 

and red fir forest, 5000 – 9000 

feet. 

Lewisia disepala

YOSEMITE BITTEROOT

Two populations occur in the 

Greys Mountain Project area, 

within or surrounded by 

Units M2 and T8

ROCKY/GRAVELLY. 

Granitic sand and gravel in 

ponderosa pine, mixed conifer, 

and upper montane coniferous 

forest, 4000 – 7500 feet.

Lewisia kellogii ssp. kelloggii

KELLOGG’S LEWISIA

None known to occur but rocky 

habitat present, mostly below 

elevation preferred by this 

species. 

ROCKY/GRAVELY. Open, 

gravelly flats in mixed conifer and 

subalpine forest, 6000 – 11,000 

feet. 

Meesia triquetra

THREE-RANKED 

HUMP-MOSS

None known to occur but fen 

habitat present in several 

meadows. 

RIPARIAN/MEADOW. Fens in 

montane meadows within conifer 

forest, 4500 – 8000. 

Meesia uliginosa

ONE-NERVED HUMP MOSS

None known to occur but 

suitable fen habitat present. 

RIPARIAN/MEADOW. Fens in 

montane meadows within conifer 

forest, 7500 – 9000 feet. 

Mimulus gracilipes

SLENDER-STALKED 

MONKEYFLOWER

None known to occur but 

potential habitat present in 

southern part of project, not in 

treatment units. 

ROCKY/GRAVELLY. Granitic 

sand and gravel usually associated 

with outcrops in foothill chaparral 

and ponderosa pine, forest, 1500-

4225 feet.

Peltigera hydrothyria

VEINED WATER LICHEN

None known within project 

boundary but potential habitat 

in streams of project area. 

Surveys focused on road 

crossings. 

RIPARIAN/MEADOW 

(AQUATIC)/Cold, clear, 

unpolluted streams in conifer 

forests, 4000 – 8000 feet. 

Trifolium bolanderi

BOLANDER’S CLOVER

None known, most likely absent 

due lack of detection during 

many surveys over the past 20 

years. 

RIPARIAN/MEADOW. Montane 

meadows in mixed conifer forest, 

6800-7300 feet. 

More information about the three Forest Service Sensitive Plants known to occur within the 

project area is found below:

Collomia rawsoniana - Rawson’s flaming trumpet

Rawson’s flaming trumpet is a perennial herb that spreads both by seed and via 

underground stems (rhizomes). The tubular flowers are bright orange red, pollinated by 

hummingbirds and several species of bee (Hevron, 1989). The entire distributional range 

of this relict species is confined to a 15 by 10 mile area between 2500 and 7000 feet 

elevation. All occurrences are within Madera County, and most are on the Bass Lake 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 74 Chapter 3

Ranger District. Populations occur along streams and around meadows within about 12 

major drainages (roughly equivalent to "occurrences" as defined by California Natural 

Diversity Database CNDDB) of the Department of Fish and Game (CNDDB, 2011) all 

but one of which flows into the San Joaquin River. The exception is the Nelder Creek 

occurrence, which flows into the Fresno River. Each major drainage may have over 5 

miles of patchily occupied flaming trumpet habitat. Estimates of population size are 

usually given as number of stems, which is a poor indication of number of individuals,

since what constitutes a ramet vs. a genet is just beginning to be understood for this 

rhizomatous perennial herb. It has been found that a large patch is often composed of 

many genetic individuals and that sexual reproduction is probably occurring at an

adequate rate to keep genetic variability high enough to sustain the species over time 

(Wilson, Clines, and Hipkins, 1999). 

Flaming trumpet populations are found both in ponderosa pine forest and in mixed 

conifer forest. Flaming trumpet is dependent on the cool, moist conditions found along 

streams in good hydrologic condition. Research has shown that there is a balance 

between light and shade at which flaming trumpet flowers optimally (Liskey, 1993). 

Some disturbance can be beneficial, especially if it simulates the loosening of soil and 

opening of canopy that would be present after natural windfall of forest trees. The 

populations of flaming trumpet on the Bass Lake Ranger District have been studied and 

monitored for many years (Hevron, 1989; Liskey, 1993; Wilson, Clines, and Hipkins, 

1999; Taylor et al. 1987). Populations of flaming trumpet occur along Chilkoot and 

North Fork Willow Creek within Tractor Unit T9, , but the stream will be buffered by a 

streamside management zone of at least 100 feet. 

 

Hulsea brevifolia – short-leaved hulsea

The short-leaved hulsea is a locally endemic herb found in montane forests of the central 

and southern Sierra Nevada (Hickman, 1993). Plants are 3 to 6 decimeters tall, with leafy 

stems. Leaves are toothed, and stems and leaves are covered with hairs, some of which 

are glandular, making plants sticky to the touch. Flowerheads are bright yellow-orange, 

less than 20 millimeteres in diameter (Hickman, 1993). Elevation range is from 5,000 to 

9,000 feet, but most occurrences are found above 6500 feet in the red fir forest type. This 

plant grows in dry forests and openings.

Short-leaved hulsea is a perennial herb. There are about 50 occurrences documented on 

the Sierra National Forest, and others on adjacent forests and in Yosemite National Park. 

Elevational range is 5000 to 9000 feet, from Tuolumne County south to Tulare County. 

Habitat for short-leaved hulsea is gravelly or sandy exposed areas as well as densely 

wooded sites in coniferous forest, usually red fir forest. Occurrences range in size from a 

few dozen plants to many thousand plants. Most occurrences appear to represent a 

variety of age classes, from the current year’s seedlings to older, well established plants.

Many populations consist of thousands of individuals.

There are six populations of short-leafed hulsea in the project area. Two of them occur in 

tractor units (T6 and T11), and the rest are along Roads 5S07 and 6S99.

Lewisia disepala – Yosemite bitteroot

This early blooming perennial herb is known from granite domes surrounding Yosemite 

Valley; locally abundant on Mt. Watkins, Basket Dome, and on the unnamed domes east 

and west of Mt. Starr King, and on granite domes as far south as Kern County. In 1980, 

Steve Botti estimated that about 20,000 plants were known from Yosemite National Park, 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 75 Chapter 3

and about 110 plants from Tulare County, 200 miles to the south. In 2004, USGS 

botanists found approximately 11,000 plants from three populations in Yosemite National 

Park. Populations found outside of Yosemite consist of as few as one hundred to over 

three thousand plants. As of November 2005, there were a total of 22 occurrences outside 

of Yosemite. Thirteen occurrences have been located on the Sierra National Forest: eight 

in Madera County and five in Fresno County. The Sequoia NF has seven occurrences: 3 

in the Scodie Mountains of Kern County, 2 in the Dome Land Wilderness and 2 west of 

the Kern Canyon in Tulare County. There are two Tulare County occurrences on BLM 

land east of the Sequoia NF boundary and west of Lamont Peak. The Sierra National 

Forest occurrences are at the lowest elevations for the species and face the most threats 

(off-highway vehicles, dispersed camping, target shooting, campfires, etc.). 

Two populations occur in the Greys Mountain Project area, within or surrounded by 

Units M2 and T8. These populations of Yosemite bitterroot were monitored in 2010 for 

another project. 

Noxious weeds and invasive non-native plants: Invasive non-native plants (weeds) are species 

which, if allowed to spread, cause ecological and economic damage. Invasive weeds may be 

officially listed as “noxious” at the federal or state level. The California Invasive Plant Council 

(Cal-IPC, 2006) assigns ratings of high, moderate, or limited ecological impact to weeds

statewide based on ecosystem impacts, potential for invasiveness, and ecological distribution. 

Weeds on the California Noxious Weed list with ratings of “A” or “B” are of highest priority for 

state and county weed managers (CDFA, 2011). New infestations of State A and B rated weeds 

are controlled promptly by county or California State Department of Food and Agriculture 

biologists or by Forest Service employees in cooperation with county agriculture department 

staff. 

Surveys conducted in 2011 for this project revealed that the primary invasive weed species in the 

Greys Mountain project area are bull thistle (Cirsium vulgare) and klamathweed (Hypericum 

perforatum). The bull thistle is mostly in meadows. Overall, the area is not heavily infested with 

weeds. No California State Noxious Weed species are currently known from this area. Figure 16

shows the locations of these species in relation to the treatment units within the project area. 

Details about the locations of these species and their impacts follow:

Bull thistle (Cirsium vulgare) - CIVU. There are infestations of bull thistle in or 

adjacent to units T4, T226, T29, T33, T37, and along access roads to and within the 

project area. There is also bull thistle in some of the meadows proposed for restoration: 

Meadow 504M293, 504M132 (Meserve Meadow), 503M8 (Progeny Meadow), 504M198 

(Railroad Meadow), and 503M7. Although not as highly invasive as other noxious 

thistles, bull thistle competes with and displaces native species and decreases forage 

values in meadows and uplands at elevations up to and 7,000 feet (Randall, 2000). CalIPC rates bull thistle as having moderate ecological impact statewide, but notes that this 

species can be very problematic regionally, and especially in riparian areas such as 

meadows (Cal-IPC, 2006). Bull thistle has recently been documented at elevations 

higher than 7,000 feet in the Sierra Nevada (e.g. up to 8795 feet at Sonora Pass on the 

Stanislaus National Forest (UC Berkeley, 2011). 

Klamathweed or common St. Johnswort (Hypericum perforatum) – HYPE. 

Infestations of klamathweed are found along Sky Ranch Road leading to the project area, 

and in T16, T17, and T31. This weed is also present in the following meadows proposed 

for restoration: 503M7, 503M8 (Progeny Meadow), and 504M132 (Meserve Meadow). 

Klamathweed is a perennial herb up to 4 feet tall with bright yellow flowers. The root 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 76 Chapter 3

system can extend up to 5 feet deep and up to laterally 1.5 feet. Leaves have tiny 

perforations (clear spots) throughout and black glands on the undersurface. Each plant 

can produce between 15,000 and 33,000 seeds each year, and seeds remain viable up to 

10 years (DiTomaso and Healy 2007). This weed originated in Europe and has been 

imported to numerous countries because of its medicinal properties. It is a pest because it 

displaces native plants by forming monocultures in wildlands, including rangelands and 

coniferous forests, and it is toxic to livestock (Piper, 2000). 

Figure 16. Locations of Noxious Weeds within the Greys Mountain Project Area.

Desired Condition 

For Forest Service Sensitive Plants the desired condition is to maintain the six short-leafed 

hulsea populations within the Greys Mountain project area at their current population numbers by 

maintaining or improving habitat conditions required by this species (openings in coniferous 

forest with intact (non-compacted) soil structure. The desired condition is also to maintain 

suitable habitat for Forest Service Sensitive plants that may exist undiscovered in the project area. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 77 Chapter 3

For invasive weeds, the desired condition is to maintain native plant communities with the 

absence or minimized presence of non-native invasive plants, and to use Integrated Weed 

Management to prevent, control, and monitor invasive weeds. 

Environmental Consequences 

Methodology 

Existing information from Sierra National Forest botany and noxious weed records and GIS files 

were reviewed to evaluate where to focus field surveys for this project. 

Surveys for the project were conducted in 2011, specifically looking for Forest Service sensitive 

plants and noxious weeds in the units proposed for treatment in the Greys Mountain project area 

and associated roads and meadows. The results were summarized in brief above (in Table 9 and 

in the noxious weed and rare plant descriptions) and are described in more detail in Appendix B 

of the Biological Assessment (BA)/Biological Evaluation (BE) (Clines 2011a) and the Noxious

Weed Risk Assessment (Clines 2011b). All rare plant information is maintained in a GIS 

database and survey forms are turned in to the California Natural Diversity Database. (CNDDB, 

2011). The noxious weed data is mapped in GIS and control efforts would begin prior to and/or 

during project implementation. 

Because there are 15 species of Forest Service Sensitive Plants that may occur in the project area 

or along access roads where they may be affected, but only three that are known to occur, this 

analysis would be based on effects to habitats for all of these species as shown in (Table 9 above): 

Riparian, Rocky/Gravelly, and Forested.

Spatial and Temporal Context for Effects Analysis 

For direct and indirect effects the timeframe is one to five years, based on the fact that monitoring 

of project effects on rare plant and invasive weed populations would be conclusive within this 

time frame. For cumulative effects, the timeframe is 20 years, over which the desired effects of 

the project activities would have a chance to take effect. 

Alternative 1 – No Action 

Direct Effects 

No direct effects would occur to FSS plants if the no-action alternative is chosen because project 

activities would not take place. 

Indirect Effects and Cumulative Effects 

Indirect and cumulative effects have the potential to occur to FFS plants under the no-action 

alternative primarily from the potential of uncharacteristically severe wildfire. 

Uncharacteristically severe wildfire has the potential to cause significant disturbance to soil, 

ground cover and canopy cover, placing FSS riparian species at risk, since these types of plants 

normally do not regenerate after unusually high-intensity fires. Through suppression actions, 

extreme fires can also allow the opportunity for the spread of invasive weeds, which can affect 

FSS species through competition of resources. The invasive weeds in the project area would 

continue to spread without the manual control proposed in the action alternatives.

In addition, riparian and meadow habitat in the nine meadows proposed for restoration would 

continue to deteriorate, thus suitable habitat for the nine rare plant species that occur in these 

types of habitats ( Table 9 above) would be reduced in quantity and quality over time. 

. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 78 Chapter 3

Compliance with Forest Plan and Other Relevant Laws, Regulations, 

Policies and Plans 

FS Manual 2672 provides standards for biological evaluations and provides a list of all Regional 

Forester designated sensitive wildlife and plant species occurring on NFS lands. Current policy as 

shown in the FS Manual (FSM 2672.4) is to conduct a pre-field review of available information, 

and in instances where there is evidence of sensitive plant species or habitat, conduct a field 

reconnaissance if necessary to determine whether the project poses a threat to sensitive plants. 

The results of surveys and conflict determination are documented in the BE (Clines 2011)

SNF-LRMP, as amended (USDA 1991, 2004). The Forest Plan direction for Sensitive species is 

to develop and implement management practices to ensure Sensitive species do not become 

threatened or endangered because of FS actions. Under Forest Plan Management S&Gs, the 

forest is to: a) develop sensitive plant species management guides to identify population goals and 

compatible management activities that would maintain viability (S&G 67) and b) manage 

sensitive plant species to avoid future listing as threatened and endangered. Standard and 

Guideline 68 directs the Forest to ensure maintenance of genetic and geographic diversity and 

viable populations of Sensitive plants. The Forest Plan also states that the Forest would conduct 

sensitive plant surveys and field investigations prior to any ground-disturbing activity in areas 

that sensitive plants are known or suspected to occur. Avoidance or mitigation measures are to be 

included in project plans and NEPA documents (USDA FS 1992). The Forest Wide Goals and 

Objectives identified in the Forest Plan for threatened, endangered, and proposed plant species 

and FS R5 sensitive plant species are: a) Manage fish, wildlife and plant habitats to maintain 

viable populations of all resident fish, wildlife and plant species, b) Manage habitat for State and 

Federally listed threatened and endangered fish, wildlife and plant species to meet the objectives 

of their recovery plans, c) Emphasize habitat improvement for sensitive, threatened, endangered 

and harvest species, d) Manage habitat for FS sensitive fish, wildlife and plant species in a 

manner that prevents any species from becoming a candidate for threatened or endangered status. 

Additionally, the Forest is directed to manage botanical resources to maintain present diversity of 

species.

The FS Manual (FSM 2080) outlines the laws and regulations guiding the FS’s noxious weed 

management (http://www.fs.fed.us/im/directives/fsm/2000/2080.txt).Alternative 1 is in 

compliance with the Forest Plan, FSM 2670, FSM2080, and other Regulations, Policies, and 

Plans relevant for FSS Plants and Noxious Weeds, although goals stated in these plans and 

policies would not be reached as quickly. 

Summary of Effects 

It is expected that under Alternative 1, the number of populations of FSS would remain the same 

and the number of plants per occurrence would remain constant or increase. The number of 

noxious weed infestations would increase directly as a result of no action being taken to limit 

spread.

Alternative 2 – Proposed Action 

Design Features and Mitigation Measures

This alternative has been designed to minimize or avoid negative effects to FSS plants. (See 

Chapter 2 Design Criteria Common to All Action Alternatives). 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 79 Chapter 3

Direct and Indirect Effects 

FOREST SERVICE SENSTIVE PLANTS

The following direct effects to sensitive plants are possible as a result of timber harvest or fuels

reduction activities: Direct killing of plants when equipment runs over them or parks on them, 

when logs are skidded or dragged over them, when slash piles block their light, and when piles 

are burned directly over them and the heat intensity is too great to survive. Mastication could 

directly kill plants by running them over or by covering them with a dense layer of chipped wood 

and limbs. The project has been designed to eliminate or minimize these effects.

Plants of Riparian, Meadow, and Aquatic Habitats: For the known occurrences of Rawson’s 

flaming trumpet along Chilkoot and North Fork Willow Creeks in Unit T4, there would be no 

direct effects because the project is designed specifically to prevent impacts to streamside 

management zones (see Hydrology Project Design Measures). For the other eight species of 

these habitats that might occur in the project area, project design measures for hydrology and 

aquatics would prevent direct and indirect effects to plants of meadows, streamside’s, and aquatic 

habitats listed in Table 9. The meadow restoration work would improve habitat conditions for 

any of these species should they might occur nearby. 

Plants of Rocky/Gravelly Habitats: The Yosemite bitterroot populations near units M2 and T8 

would not experience direct or indirect effects as the project is designed to avoid impacts to these 

populations. No plants of rocky habitats were found during surveys of the project area, but not all 

rocky areas were surveyed as no treatments were proposed within them. However, the project 

has been designed to prevent incidental effects to rocky/gravelly areas, thus no direct or indirect 

effects would occur to the three species that may be present: Mono Hot Springs evening 

primrose, Yosemite bitterroot, or Kellogg’s lewisia. 

Plants of Forested Habitats: The short-leafed hulsea populations in the treatment units and 

along access roads would all be flagged for avoidance, thus no direct effects should occur. 

Positive indirect effects may result from opening of the canopy near the populations as they 

respond positively to this type of disturbance as evidenced by observations of response to fire and 

thinning (Clines, personal observation). Thus no negative direct or indirect effects are expected 

for this species. 

NOXIOUS WEEDS AND INVASIVE NON-NATIVE PLANTS

Ecosystem health is threatened by the spread of invasive non-native weeds in a variety of ways. 

Dense infestations can reduce native biodiversity, compete with threatened, endangered and 

sensitive (TES) plant species, reduce wildlife habitat quality and quantity, modify vegetative 

structure and species composition, change fire and nutrient cycles, hybridize with native species, 

and degrade soil structure (Bossard et al, 2000). 

Because the project is designed to improve the ecosystems of the project area by removing known 

infestations of invasive weeds and preventing the introduction and spread of new infestations or 

species of weeds, there would be beneficial direct and indirect effects to ecosystems as a result of 

Alternative 2.

Cumulative Effects 

Past, present, and reasonably foreseeable actions within and near the project area are detailed in 

Table 8. For the Yosemite lewisia and other plants of rocky/gravelly habitats, use of Forest 

Roads and motorized recreation are currently having some impacts (individual plants are likely 

killed when driven over repeatedly based on botanical monitoring over the past 10 years), but the 

Greys Mountain project would not add to these impacts as the project is not occurring within 

these types of habitats and the project has been designed to prevent damage to rocky/gravelly 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 80 Chapter 3

soils. For Rawson’s flaming trumpet, which grows along streams, the populations within the 

project area are stable and thriving but there are occasional instances of motorized recreation 

damage or cattle grazing or trampling. The Greys Mountain project would not add to these slight 

impacts because there are SMZs along the streams inhabitated by flaming trumpet. For other 

Sensitive Plants of meadow, riparian and aquatic habitats that may occur within the project area 

past, current, or future effects experienced at some level could be from the following activities: 

motorized recreation use, cattle grazing and trampling, roadside hazard tree removal, and 

fire/fuels management activities. No negative cumulative effects are expected for plants of 

meadow, aquatic, and riparian areas because aquatic and hydrology project design measures will 

prevent damage to these habitats. For the short-leaved hulsea, use of Forest roads, motorized 

recreation, roadside hazard tree removal, and cattle trailing might affect the populations. No 

negative cumulative effects are expected because project design measures specify that this species 

will be flagged for avoidance during project implementation; in addition short-leafed hulsea has 

been observed to benefit from light disturbance (it flourishes after fire and along roadsides), and 

the populations in the project area were observed to be in good condition, thus there is no 

evidence that past activities have diminished the vigor of short-leafed hulsea. 

For noxious weeds, any activity listed in Table 8 could have spread weeds in the past and has the 

potential to spread weeds currently and in the future. Surveys for this project revealed that the 

area is relatively free of noxious weeds, especially considering the amount of historical and 

current activity occurring therein. The project will reduce the number of infestations of noxious 

weeds and thus no negative cumulative effects for noxious weeds are expected. 

No negative cumulative effects are expected for Botanical Resources as the project has been 

designed to reduce or eliminate direct and indirect effects to rare plants and to avoid the 

introduction and spread of noxious weeds. 

Positive cumulative effects for ecosystems are expected in that the project area would have a 

reduced number of infestations of invasive (noxious) weed species over the long term beginning 

with the actions proposed in this project. Rare plants reliant upon meadow habitat would have 

more suitable habitat to move into as a result of the meadow restoration actions proposed for this 

project

Compliance with Forest Plan and Other Relevant Laws, Regulations, 

Policies and Plans 

Alternative 2 is in compliance with the Forest Plan, FSM 2670, FSM2080, and other regulations, 

policies, and plans relevant for FSS plants and noxious weeds because botanical field surveys 

were conducted, and the project has been designed to protect FSS plants and prevent and control 

noxious weeds. 

Other Relevant Mandatory Disclosures

No federally listed TES plant species occur within the project area (see BA/BE for plants – Clines 

2011a). No consultation with US Fish and Wildlife Service was necessary. 

Summary of Effects 

It is expected that after implementation of Alternative 2, the number of populations of FSS would 

remain the same and the number of plants per occurrence would remain constant or increase. The 

number of noxious weed infestations would decrease directly as a result of project activities.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 81 Chapter 3

Alternative 3 – Proposed Action 

Design Features and Mitigation Measures

This alternative has been designed to minimize or avoid negative effects to FSS plants. (See 

Chapter 2 Design Criteria Common to All Action Alternatives). 

Direct and Indirect Effects 

FOREST SERVICE SENSTIVE PLANTS

The effects are the same as for Alternative 2. 

NOXIOUS WEEDS AND INVASIVE NON-NATIVE PLANTS

The effects are the same as for Alternative 2. 

Cumulative Effects 

Cumulative Effects are the same as for Alternative 2. 

Compliance with Forest Plan and Other Relevant Laws, Regulations, 

Policies and Plans 

Alternative 3 is in compliance with the Forest Plan, FSM 2670, FSM2080, and other regulations, 

policies, and plans relevant for FSS plants and noxious weeds botanical field surveys were 

conducted, and the project has been designed to protect FSS plants and to prevent and control 

noxious weeds. 

Other Relevant Mandatory Disclosures

No federally listed TES plant species occur within the project area (see BA/BE for plants – Clines 

2011a). No consultation with US Fish and Wildlife Service was necessary. 

Summary of Effects 

It is expected that after implementation of alternative 3, the number of populations of Forest 

Service sensitive plants would remain the same and the number of plants per occurrence would 

remain constant or increase. The number of noxious weed infestations would decrease directly as 

a result of project activities. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 82 Chapter 3

Geology/Soils _________________________

The direct, indirect and cumulative effects to Geology/Soils below are summarized from the 

Greys Mountain Project Geology/Soils Report (Gallegos A., Takenaka K. 2012).

Affected Environment

The following section addresses the affected environment or existing pre-treatment condition for 

soils within the project area, including selected meadows for conifer encroachment removal. This 

report addresses the environmental consequences of the proposed action to soil productivity, 

mitigations measures to reduce the impacts of the proposed action.

Data used to determine existing soil conditions and projected effects to the soil resource include: 

the Soil Survey of the Sierra National Forest, (Giger, 1993), site specific data from eleven soil 

transects collected in 2011 (see Appendix C), following the National Soil Monitoring Protocol 

(USDA Forest Service, 2009) and past monitoring of similar projects using BMP Monitoring 

Protocols (USDA, 2002) and the Region 5 Soil Monitoring Protocol.

Existing Condition 

Soils

Soils in the proposed project area vary in their sensitivity to management. Soils with higher clay 

content and soil moisture contents have the highest potential to reduced soil porosity. Soil 

compaction can occur down to 12” deep. 

Parent material of the area consists of biotite granites, granites, massive quartzite beds, and 

tonalites with sparse potassium feldspars and commonly interstitial to quartz and plagioclase 

(Bateman, 1989). Glacial till is present in minor occurrences around White Chief Mountain and 

Greys Mountain in the northeast area of the project area. Rock outcrop is present throughout the 

project area. With the presence of multiple parent materials, many different soil types have 

formed across the landscape making up the project.

The project area is underlain by six soil types and rock outcrop, which combine to form 11 soil 

map units. Those soil types formed from granitic rocks include Cagwin, Cannell, Chaix, 

Chawanakee and Holland. Holland is also formed from meta-sedimentary rocks and Neuns is 

formed from a combination of metamorphosed granitic and meta-sedimentary rocks. Description 

of soils within the Greys Mountain Project area include soil map units and soil types, (see Table 

10 and Table 11) and a project area map showing the proposed treatment units and soil map units, 

(in Appendix C).
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Sierra National Forest – 83 Chapter 3

Table 10. Soil Map Units for the Greys Mountain Project

Greys Mountain Soil Map Units

Map

Unit

Map Unit 

Name Acres Soil Erosion Hazard Sensitivity

Soil 

Compaction 

Hazard

Runoff 

Potential Treatment Units

116 Cagwin/Rock 

Outcrop 168.89 High High Low Mod/High T11 & M3

117 Cannell 45.70 Mod Low/Mod Low Low T11 & M3

120 Chaix 2071.12 Mod/High Low/Mod Low Low

Rx 1 & 2, H 5 & 

T 4, 5, 16, 26, 27, 

28, 29, 30, 31, 32, 

33, 34, 35, 37 & 

38

124 Chaix/Hollan

d 813.61 High Mod/Low Mod/High Low

Fx 9, H 6 & 7, M 

4 & T 9, 10, 17, 

18 & 39 

126 Chawanakee/ 

Rock Outcrop 360.01 High/Very High High Low Mod/High M 1, 2 & 4 & T 2, 6 & 22

139 Holland/Chai

x 61.52 High/Very High Mod/High High/Low Mod M 5, Rx 5 & T 7

140 Holland/ 

Chawanakee 1624.98 High/Very High Mod/High High/Low Mod

Fx 9, H 1, 4 & 6, 

M 1, 2, 4 & 5, Rx 

1, 2, 4 & 5 & T 8, 

9, 10, Rx15, 16, 

17, 18, Rx22, 

Rx23, Rx24 & 39

141 Holland/ 

Chawanakee 1572.48 High Low/High High/Low Mod

H 2 & 8, M 2 & 

4, Rx 1, 2, 3, 4, 5 

& 6 & T 2, 3, 7, 

8, 13, Rx15, 16, 

17, 19, 20, 21, 

Rx22, Rx23, 

Rx24 & 39

142 Holland/Neun

s 113.15 Mod/High Low/Mod High/Mod Low T 16

146 Neuns 2717.09 Mod/High Low/Mod Mod Low

M 4 & 6 & T 1, 2, 

3, 6, 10, 12, 14, 

20, 32 & 33

148

Rock 

Outcrop/ 

Chawanakee

131.28 High/Very 

High High Low Mod/High H 2 & 3 & T 8
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 84 Chapter 3

Table 11. Soil families for the Greys Mountain Project

Greys Mountain Soil Families

Soil Family Taxonomy Name Temp. 

Regime Texture Hyd Grp

Drainage 

Class

Cagwin Dystric 

Xeropsamments Frigid A: 0 to 5 inches, loamy coarse sand A

Somewhat 

excessively 

C: 5 to 17 inches, gravelly loamy coarse sand drained

Cannell Dystric 

Xerochrepts Frigid

A: 0 to 7 inches, gravelly coarse sandy loam

B Well 

drained Bw: 7 to 32 inches, gravelly coarse sandy loam

C: 32 to 50 inches, gravelly loamy coarse sand

Chaix Dystric 

Xerochrepts Frigid

A: 0 to 6 inches, coarse sandy loam

B

Somewhat 

excessively 

drained

Bw1: 6 to 18 inches, coarse sandy loam

Bw2: 18 to 36 inches, gravelly coarse sandy loam

Chawanakee Dystric 

Xerochrepts Mesic

A: 0 to 4 inches, coarse sandy loam

C

Somewhat 

excessively 

Bw: 4 to 19 inches, coarse sandy loam drained

Holland Ultic 

Haploxeralfs Mesic

A1: 0 to 3 inches, sandy loam

B Well 

drained

A2: 3 to 7 inches, sandy loam

AB: 7 to 14 inches, light sandy clay loam

BAt: 14 to 25 inches, sandy clay loam

Bt1: 25 to 34 inches, clay loam

Bt2: 34 to 51 inches, sandy clay loam

Bt3: 51 to 60 inches, sandy clay loam

C: 60 to 66 inches, sandy loam

Neuns Dystric 

Xerochrepts Mesic

A: 0 to 7 inches, gravelly loam

B Well 

drained

Bw1: 7 to 13 inches, gravelly loam

Bw2: 13 to 35 inches, cobbly loam

Bw3: 25 to 45 inches, very cobbly loam

C: 45 to 54 inches, extremely cobbly loam

Soils intermixed with high amounts of impervious surfaces such as rock outcrop or shallow soil 

are sensitive to management because they are susceptible to runoff, subsequent erosion of soil 

adjacent to rock outcrop and are sensitive to disturbance from displacement of the A horizon. 

Within the project area soil map units 116, 126 and 148 contain rock out crop. Proposed 

treatment units which contain rock outcrop and shallow soils, that will result in ground 

disturbance, include H 2 & H-3; M-1, M-2, M-3 & M-4; and T-2, T-6, T-8 & T-11 (Table 10). 

Rock outcrop has the potential to produce a large quantity of runoff during a storm, resulting in 

accelerated erosion below areas of the rock outcrop where shallow soils are located. Areas with 

high abundances of outcrop can have a large increase in accumulated erosion occurring.

Some areas are located on steep 25%-35% slopes where skidding may be adverse (uphill 

skidding) and ground disturbance could occur. Proposed treatments units which have steeper 

slopes are located in treatment units T-3, T-8, T-11, T-16 and T-18.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 85 Chapter 3

Cagwin, Chaix and Chawanakee soil families are considered shallow soils and the corresponding 

soil map units in the project area are 116, 120, 124, 126, 139, 140, 141, and 148. Units in the 

proposed treatment which lie on shallow soils include Fx 9; H 1, 2, 4, 5, 6, 7 & 8; M 1, 2, 3, 4 & 

5; Rx 1, 2, 3, 4, 5 & 6 and T 2 through 29. The majority of the shallow soils have formed from a 

granitic parent material providing the soils with a loamy to coarse-loamy soil texture primarily. 

With a coarser soil texture the likelihood of compaction occurring in these soils is much lower 

when compared to the other soils in the project area.

Soils with the highest susceptibility to compaction in the project area include only the Holland 

family. Soil map units 124, 139, 140, 141 and 142 contain Holland family soils. Units within the 

proposed treatment area which lie on these soils include Fx 9; H 1, 2, 4, 6, 7, & 8; M 1, 2, 4 & 5; 

Rx 1, 2, 3, 4, 5, 6, 22 & 24 and T 2, 3, 5, 8, 9, 10, 13, 16, 17, 18, 19, 20, 21, & 39. A sandy loam 

is present in the upper A horizons transitioning to a sandy clay loam throughout the B horizon 

down to the C horizon at 60 inches. A higher abundance of clay minerals causes the soil to have 

an increased chance of compaction occurring within the top 12 inches of the soil profile when 

moisture levels are above 14%. Most ground based operations rarely causes compaction below 

12 inches.

Soils with the highest sensitivity to management in the project area include Cagwin, Chawanakee 

and Chaix. These soils are sensitive to management based on the thickness of the A horizon, 

depth to bedrock and the Maximum Erosion hazard rating. These soils have a high sensitivity to 

management and have a high potential to loss of productivity under most soil disturbing 

activities, unless other than normal measures are applied (Giger, 1993). Soil map units 116, 126, 

139, 140, 141 and 148 contain Cagwin, Chawanakee or Chaix soil families. Units within the 

proposed treatment which lie on high sensitivity soils include Fx 9; H 1, 2, 4, 6 & 8; M 1, 2, 3, 4 

& 5; Rx 1, 2, 3, 4, 5, 6, 22, 24 and T 2, 3, 6, 8, 9, 10, 11, 13, 16, 17, 18, 19, 20, 21 & 39. These 

soils have a parent material consisting primarily of granitic rocks and are a much less mature soil 

when compared to Holland or Neuns. The soils can be categorized as being either an entisol or 

inceptisol. Entisols are the youngest of the 12 soil orders and are commonly found with only an 

A horizon over a C horizon, not enough time has occur to allow the formation of a mineral B 

horizon. Inceptisols however are slightly older and have enough time to allow the formation of 

the mineral B horizons in their subsurface profiles. A less mature soil has few horizons within its 

profile, commonly only an A horizon, as a result any displacement within the A horizon can 

result in decreased soil productivity in theses soils. 

Meadows

The meadows within the Greys Mountain project area are important ecological sites and are 

habitat to unique plants and animals. Conifer encroachment due to heavy grazing, logging, fire 

suppression, climate change, or a combination of factors can reduce meadow areas and have an 

effect on the meadow’s biology and hydrology (MacDonald and Kuitu, 2009). For the purpose 

of this analysis, a meadow is defined as “an opening in a forest, generally at higher elevations, 

that is exceptionally productive of herbaceous plants usually resulting from high soil water 

content, or a perched water table,” (Soil Conservation Society of America). 

Soil Productivity

Current pre-treatment soils conditions have been completed in the project area of the Greys 

Mountain Project using the National Soil Monitoring Protocol (USDA Forest Service, 2009a). A 

total of 11 soil transects in ten proposed areas proposed for commercial thinning using 

mechanical equipment were completed in the project area.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 86 Chapter 3

Within the Greys Mountain Project a majority of the completed transects were revealed to be 

class 0, with a few class 1’s and 2’s (Table 12). No class 3 disturbance levels were discovered in 

any of the completed transects throughout the project area. Mean forest floor depth was 4.80 

centimeters, mean slope was 16.65% and mean Large Woody Debris (LWD) points/acre was 

33.25, see (appendix C). 

Within four transects T11A, T29, T30 and T35 compaction was discovered and in only three 

units T11A, T29 and T30 was there an occurrence of platy soil structure. Unit T11A is the upper 

portion of unit T11 northwest of the Beasore Rd. With an 80 % confidence, the interval (0.00%, 

7.53%) has captured the true proportion of compaction (10-30cm) and platy structure (0-10cm) 

occurring within units; T11A, T29 and T30, table 10 & 11 (Appendix C) What this means is the 

interval from 0.00% to 7.53% will have captured the true proportion of compaction and platy 

structure occurring within the given unit eighty percent of the time. If the transects were reran in 

the same units, eighty percent of the time the interval 0.00% to 7.53% would capture the true 

proportion of compaction and/or platy structure occurring in these units. Only within one 

transect, T30 was bare soil discovered. With an eighty percent confidence the interval (2.98%, 

17.02%) has captured the true proportion of bare soil within this unit occurring, (Appendix C). 

This particular site had numerous undeveloped campsites found within and frequent non-system 

roads located through the unit.

Table 12. Soil transect summary for the Greys Mountain Project

Soil Transect Summary

Soil Transect

Soil Disturbance Class Mean 

Slope

Mean 

Forest Floor 

Depth

LWD 

Points/Acre Class 0 Class 1 Class 2 Class 3

GM T1 100.00% 0.00% 0.00% 0.00% 17.10% 4.40 22.50

GM T11A 97.00% 3.00% 0.00% 0.00% 26.57% 3.97 40.00

GM T11B 100.00% 0.00% 0.00% 0.00% 12.20% 4.13 N/A

GM T12 100.00% 0.00% 0.00% 0.00% N/A 5.07 32.50

GM T18 100.00% 0.00% 0.00% 0.00% 22.97% 7.30 70.00

GM T28 97.00% 3.00% 0.00% 0.00% 16.27% 4.80 27.50

GM T29 100.00% 0.00% 0.00% 0.00% 12.43% 3.70 22.50

GM T30 94.00% 3.00% 3.00% 0.00% 7.83% 3.97 20.00

GM T32 100.00% 0.00% 0.00% 0.00% 14.97% 5.23 22.50

GM T35 97.00% 3.00% 0.00% 0.00% 18.90% 5.80 42.50

GM Rx6 100.00% 0.00% 0.00% 0.00% 17.30% 4.47 32.50

Meadow Productivity

Conifer encroachment on the meadows in the Greys Mountain Project area was assessed using 

aerial photos in ArcGIS (Rossington, 2011a). An existing meadow GIS shapefile was used to 

identify 2008 meadows within the Greys Mountain project area. The meadow shapefile was 

compared to the 2008 NAIP aerial photos and some of the meadows were modified to more 

accurately represent boundaries shown in the aerial photo. The meadows in 1944 were mapped 

using scanned aerial photos of the Sierra National Forest and compared to the 2008 air photos to 

identify areas where conifer encroachment had occurred in the meadows.
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The meadows were classified into one of eight categories based on their percent change in area 

from 1944 to 2008 due to conifer encroachment, see Appendix C. Twenty-seven meadows in the 

Greys Mountain Project area were analyzed for conifer encroachment and classified but only six 

were chosen for a further field assessment. Five meadows were identified as encroached 

meadows and include Meserve Meadow (504M132); 504M293, 504M211, 504M212, and 

503M7, (Appendix C). A sixth meadow was initially identified in the aerial photo analysis and 

determined to not be encroached.

A field assessment was preformed for each of the six meadows identified in the aerial analysis. 

The assessment consisted of a combination of qualitative and quantitative data including general 

information; evidence of roads, OHV trails, and grazing; tree islands; areas of encroachment; 

knickpoints and incised channels; vegetation types in the meadow; hydrology and installation of

piezometers; and management issues and recommendations. The following is a summary of a 

report documenting the results of the field assessment (Rossington, 2011b).

At each meadow, identification of roads, OHV trails, dominate forest type and vegetation was 

completed around the perimeter. An estimate of conifer encroachment in each meadow was 

accomplished by counting the number of encroaching trees within the established meadow 

perimeter. Streams in the meadow were observed for the occurrence of any knickpoints or 

channel incisions. Soil transects at varying lengths were placed in each of the six meadows 

identified for field assessment. The purpose of these transects was to provide information on how 

soils changed to due conifer encroachment or meadow expansion and to aid in mapping the soils 

found within the meadow. In the encroached meadows, at least one end of the soil transect was 

placed in an encroached area. Whereas in meadows with distinct wet and dry areas the soil 

transects were positioned to transgress both the wet and dry portions of the meadow. 

Meserve Meadow (504M132)

Meserve Meadow is a riparian meadow with a perennial stream flowing through it. About 30 

percent of the herbaceous portion of the meadow is located within a wide section of the stream 

channel. Under the woody riparian vegetation, the stream is incised 20-30 centimeters and is 

presumed to be caused by a weir-like structure in the stream. 

Much of the area mapped as conifer encroachment during the original aerial analysis is woody 

riparian canopy with an herbaceous meadow understory. The meadow polygon in ArcGIS was 

modified to include this area and more accurately represent Meserve Meadow. After the 

modification, Meserve Meadow was determined to be 28.96% encroached and fell into class 5, 

extensive encroachment. This conifer encroachment is located on the eastern edge of Meserve 

meadow. About 70 small conifers (<2 meter (m) and 80 large conifers (>2m) are growing near 

the edge of Meserve Meadow in meadow soils with a high water table. These conifers are 

predominately cedar, white fir, and ponderosa pine. The proposed treatment area is approximately 

0.5 acres.

504M293

Young conifers were observed growing in the northern portion of the meadow above the dry lobe 

near transect point 504M293-A’. About 130 small conifers (<2m) and 50 large conifers (>2m) are 

growing in these areas and are dominated by incense cedar and white fir. There are five tree 

islands also present in the meadow.

Field assessment of conifer encroachment is consistent with the aerial analysis.
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504M211

Young conifers were observed growing on the east side of the meadow in addition to two tree 

islands near the same point, as well as on the southern end of the meadow. About 75 large 

conifers (>2m) and 30 small conifers (<2m) are growing in these areas and are dominated by 

white and red fir ranging from 1-12” in diameter.

The observed young conifers growing in the areas mapped were determined to be conifer 

encroachment during the aerial analysis. Although these portions of the meadow were mapped as 

encroached areas, no vegetative evidence such as rushes or sedges was observed in these areas 

that may indicate a previous meadow. It is possible the 1944 mapped meadow had been 

expanded past its original boundaries due to railroad logging. The soils in the area of 

encroachment near the western margin of the meadow showed no evidence of meadow migration.

504M212

Many small conifers encroaching at the northern end, especially near the meadow edge were 

observed in the field. Soils transect point 504M212-A was placed in this group of encroaching 

conifers. In total, about 150 large conifers (>2m) and 35 small conifers (<2m) are encroaching on 

the northern and southern ends of the meadow, predominately consisting of red and white fir. 

There is about one acre of encroachment in these two areas combined. The field assessment of 

conifer encroachment is consistent with the aerial analysis. Along with the areas of conifer 

encroachment, five tree islands were also identified during the field assessment.

There is a road present on the west side of the meadow to provide egress and ingress access to the 

area. 

503M7

The conifer encroachment in the lower main part of the meadow was consistent with the areas 

mapped during the aerial analysis. In the lower main portion, young cedars are encroaching the 

meadow near both ends of the soil transect. About 50 large conifers (>2m) and 20 small conifers 

(<2m) are encroaching in these areas. Along the neck portion of the meadow, it appears that the 

encroaching ponderosa pines were planted deliberately. About 0.28 acres of the upper lobe was 

encroached by about 50 small conifers not visible in the initial aerial analysis. 

During the initial aerial analysis, 503M7 was estimated to be encroached by 3.75 acres or 

31.69%. After including the area of encroachment in the upper lobe discovered during the field 

assessment, 503M7 is estimated to be encroached by 4.03 acres or 34.04%. Although the meadow 

was mapped throughout the neck, upon examination in the field, only a small area of meadow 

existed in the neck area. There seems to be meadow throughout the neck area in 1944 air photo,

but the meadow may have been expanded past its natural boundaries due to railroad logging in 

this area. 

Desired Condition

Thresholds and indicators have been identified to meet desired conditions for the soil resource. 

Use of thresholds and indicators provides a consistent method to analyze, describe, and report on 

soil condition throughout the region.

The following desired soil conditions are applicable to the project:

1. Soil loss should not exceed the rate of soil formation (approximately the long-term

average of 1 ton/acre/year). Maintain sufficient soil cover to prevent accelerated soil 

erosion from exceeding the rate of soil formation.
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2. Soil porosity should be at least 90% of total porosity found under natural conditions over 

85% of a treatment unit. A 10% reduction in total soil porosity corresponds to a 

threshold soil bulk density that indicates detrimental soil compaction.

3. Fine organic matter occurs over at least 50% of the area. Fine organic matter includes 

plant litter, duff, and woody material less than 3 inches in diameter. The dry weight of 

fine organic matter without woody material is about 0.2 to 3 tons per acre.

4. Large woody material is at least five well-distributed logs per acre representing the range 

of decomposition classes found. Desired logs are at least 20 inches in diameter and 10 

feet long. To alleviate the risk of adverse fire effects, dry weight should be less than 

about 3 tons per acre.

5. In meadow areas, where wet soils naturally occur, moist soil moisture conditions would

be maintained and water dependent vegetation would be sustained. 

Indicators of Effect

Areas proposed for ground based harvest have soils that are highly susceptible to reduction of soil 

porosity caused from compaction by heavy equipment operating when soils are moist or wet. 

Prescribed fire and tractor piling would reduce soil cover and accelerate erosion that could result 

in a loss of soil productivity.

Ground based harvest systems on slopes that are too steep or are on shallow soils would displace 

surface soil horizons that could result in accelerated erosion and/or reduce soil productivity.

Alternatives, Including the Proposed Action

The Forest Service analyzed a No Action alternative, the proposed action and an additional action 

alternative in detail. Action alternatives included the proposed action and a Lower and Limited 

Mid-Level Canopy Treatment alternative, which focused on limiting the quantity of material 

removed to just that needed to meet fire and fuels objectives in all treatment areas. 

Alternative 1 – No Action

Under the no action alternative, current management plans would continue to guide management 

of the project area. No restoration treatments would be implemented

Direct & Indirect Effects

Under the Alternative 1, soil conditions would not change from the existing conditions. Soil 

transect data indicates that soil cover and (LWD) are meeting Regional Soil Standard and 

Guideline thresholds. Both soil cover and levels of LWD would continue to increase due to no 

disturbance taking place. Only one unit T30 had areas of bare soil as previously discussed with 

the majority having no areas of bare soil. Average LWD was 33.25 points/acre, well above the 

guideline of 5 logs per acre. Only four units T11A, T28, T30 and T35 contained soil disturbance 

level one disturbance and of the four only one contained a level two disturbance, unit T30. Any 

non-system roads may eventually recover through implantation of the forest road and OHV 

programs and forest closure to areas not designated as official OHV trails. However, the user 

created trail in meadow 503M7 would continue to impact the Aquic soils and ground water 
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dependant vegetation present within the meadow, accelerated erosion from the trail would further 

decrease soil productivity and impacts to the heritage resource site could occur.

If vegetation is left in its current state of high fuels and high wildfire risk, it is inevitable that a 

wildfire would occur. Many areas within a potential wildfire area would not meet soil quality 

standards in terms of soil cover and surface erosion rates in a fire event. The estimated area of 

potential high soil burn severity is approximately 150 acres. Soil cover would be less than 20% 

and some soils would develop hydrophobic conditions. Accelerated erosion would occur, 

especially during precipitation events. Soil Productivity would be reduced in some areas by at 

least one site class. Past monitoring of wildfire areas on the nearby Stanislaus National Forest has 

found that bare ground averaged about 70% by spring of the first year and by spring of the second 

year bare ground averaged 27% (Janicki, 2003). In a study conducted by Berg and Azuma (2002) 

bare ground and evidence of surface erosion recovered to pre-fire conditions within four to five 

years after a wildfire. LWD would in all probability be consumed in a fire and long term soil 

productivity could be decreased as well.

Meadows would have continued conifer encroachment not just along the perimeter of the 

meadow but further transgression into the meadow itself. The water table would slowly decline 

from its current level, decreasing not only the productivity/sustainability of the soils for 

herbaceous plants but also the habitat for forest wildlife. 

Cumulative Effects

The project area was evaluated for Cumulative Watershed Effects (CWE) using the Region 5 

CWE Model. This model accounts for soil disturbance in terms of an equivalent roaded acre. 

The ERA model quantifies disturbance based on the degree of disturbance as compared to an acre 

of road and measured relative to disturbance in a given watershed. See the Project Hydrology 

Report for additional information on the Cumulative Watershed Effects Analysis. All the 

subdrainages have ERA values below the lower threshold of concern. Baseline CWE (ERA %) 

for subdrainage 503.0056 is high at 9.25%, which resulted from past timber harvest activity. 

With the no action alternative, no tractor related ground disturbance or prescribed fire would 

occur, which, (given sufficient time), would allow the subdrainage to recover and stabilize. 

Alternative 2 – Proposed Action

Direct & Indirect Effects

Treatment activity that has the potential to affect soil productivity includes commercial thinning, 

mastication operations, pre-commercial thinning w/ mechanical piling, tractor piling of slash, 

prescribed burning, meadow conifer removal and stabilization, and OHV trail restoration. Each 

activity has varying potential to produce impacts to soil resources via mechanical disturbance, 

soil compaction and reduced soil cover. 

The use of mechanical harvesters, rubber tired skidders, tractor piling, and masticators would

cause soil disturbance, which could result in detrimental soil disturbance and compaction, as well 

as accelerated soil erosion. Minor amounts of soil disturbance are already present within units 

T11A, T28, T30 and T35 however due to project design criteria, marginal soil disturbance would

occur. Shallow soils occur in units Fx 9; H 1, 2, 4, 5, 6, 7 & 8; M 1, 2, 3, 4 & 5; Rx 1, 2, 3, 4, 5,

6, 7, 15, 22, 23 & 24 and T 2 through 29. Soil with a high compaction hazard occur in units Fx 

9; H 1, 2, 4, 6, 7, & 8; M 1, 2, 4 & 5; Rx 1, 2, 3, 4, 5, 6, 22, 24 and T 2, 3, 5, 8, 9, 10, 13, 16, 17, 

18, 19, 20, 21, & 39. Sensitive soils occur in units Fx 9; H 1, 2, 4, 6 & 8; M 1, 2, 3, 4 & 5; Rx 1, 

2, 3, 4, 5, 6, 22 &24 and T 2, 3, 6, 8, 9, 10, 11, 13, 16, 17, 18, 19, 20, 21, & 39 Steep slopes occur 

in tractor units T4, 6, 10, 12, 14, 16, 17, 18 and 33 and mastication units M4 and 5.
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Commercial Thinning

Areas planned for commercial thinning, standard operating practice to leave at least 50 percent, 

well distributed soil cover for erosion protection on slopes under 35%. If slopes are greater than 

35%, soil cover should be at least 70%. Past observations on the Sierra NF have found that this 

amount of soil cover generally prevents accelerated erosion. A buffer of 100 feet would be 

provided around rock outcrop to prevent accelerated erosion of the adjacent soils from rapid 

runoff from rock outcrops. During times of increased soil moisture, increased amounts of soils 

disturbance would also occur. In addition an increased risk of soil compaction could also occur 

during times of increased soil moisture. Soils would need to have soil moisture content below 

14% to minimize the potential of detrimental soil disturbance and/or compaction. Areas located 

on steep 25%-35% slopes where skidding may be adverse (uphill skidding) could result in 

increased amounts of ground disturbance.

Pre-Commercial Thinning

Areas planned for pre-commercial thinning will be completed via mastication. Areas planned for 

mastication pose little risk of reducing soil productivity. The masticator equipment reduces 

erosion potential by increasing soil cover and generally causes little soil disturbance and 

compaction. Soil masticating equipment generally does not result in compacted soils because the 

equipment has lower ground pressures then conventional logging equipment and because this 

treatment creates a bed of chips that the masticator travels over. Most mastication treatment 

would be on slopes less the 35%; however some areas with slopes in excess of 35% would be 

treated. Some soil disturbance would probably occur where the masticator makes turns during the 

operations. During times of increased soil moisture, increased amounts of soil disturbance would

also occur however this would be minimized through the application of design criteria. 

Hand Piling

Hand piling and meadow conifer removal through hand piling would have no adverse affects on 

the soil resource. Hand cutting of conifers in meadows would maintain or increase aquic soils by 

removing conifers that are transpiring water out of meadow soils (Lesh, 2009 & Norman, 2005). 

Of the meadows selected for hand piling, Board Ranch and Meserve Meadows would have the 

most conifers removed from their interior and periphery.

Tractor Piling

In areas where tractor piling of slash is planned, it is a standard operating practice to leave at least 

50 percent, well distributed soil cover for erosion protection on slopes under 35%. If slopes are 

greater than 35%, soil cover should be at least 70%. Past observations on the Sierra NF have 

found that this amount of soil cover generally prevents accelerated erosion. A buffer of 100 feet 

would be provided around rock outcrop to prevent accelerated erosion of the adjacent soils from 

rapid runoff from rock outcrops erosion would be minimized. 

Mastication

Effects of mastication were addressed in the above discussion of precommerical thinning. 

Prescribed Fire

Areas planned for prescribed fire pose little risk of causing significant effects to soil productivity 

based on the past performance of the prescribed fire program on the Sierra National Forest. Past 

prescribed fires on the forest has resulted in low burn intensity in most areas. Prescribed fire 
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burns in a mosaic pattern leaving patches of unburned vegetation and patches of burned areas, 

where duff and litter is completely consumed. Most trees are left undamaged, except for a few 

small patches that have burned at moderate burn intensity with moderate burn severity. Soil 

quality standards have been met from past prescribed fires and are expected to be met from the 

proposed action. Soil cover of 50% is expected to be met in the prescribed fire treatment areas.

OHV Trail Restoration

Only one area is proposed for OHV trail restoration and it is located within meadow 503M7. 

Subsoiling the trail to de-compact the soil would allow the regeneration of native grasses and 

herbaceous plants and allow subsurface water to move freely down gradient. Roughly 10,065 

square feet (0.231 acres) of soil would be reclaimed back to its natural condition after subsoiling 

is completed. After subsoiling is completed water bar construction would aid in decreasing the 

amount of surface erosion occurring on the trail. Additional barricades and signs preventing 

OHV riders from using the trail would further advance the regeneration of the trail as well.

Cumulative Effects

Subdrainages over their lower TOC% have been inspected for CWE response potential in the 

field by an IDT or surveyed using various methods (e.g., SCI, Pfankuch). All of the subdrainages 

are considered sensitive to moderately sensitive to disturbance (i.e., 4 - 5% Lower TOC %). The 

baseline or existing condition of most of the subdrainages is below the Lower TOC %, but 

subdrainages 503.0056 and 503.3051 are over their Lower TOC %. When adding in the proposed 

action, none exceeded the Upper TOC of 14%.

Post harvest prescribed fire is proposed for many of the tractor units within the project area. Reentry could occur any time after the logging operation is complete, but since it is difficult to 

predict when this might occur, a three year re-entry was estimated (i.e., 2015) and used as a 

recovery factor for the CWE analysis. CWE response is low to unlikely for all subdrainages.

Alternative 3 - Lower and Limited Mid-level Canopy Treatments, All 

Treatment Areas

Design Features and Mitigation Measures

Same design features and mitigation measures occur for alternative 3 as for alternative 2; see 

design features and mitigation measures for alternative 2.

Direct & Indirect Effects

In alternative 3, treatment areas would remain the same as in alternative 2, treatments within 

these areas would include only those needed to reduce the surface and ladder fuels (within the 

lower and limited mid-level canopy levels) needed to achieve fire and fuels objectives. Under 

alternative 3 there would be no additional treatments (i.e. additional thinning in the mid-level 

canopy) to fully address stand density and forest health objectives. 

This alternative would limit treatments to mechanical clearing of ladder and surface fuels. 

There is no difference between the effects of alternative 2 and alternative 3 for the soil resource 

(see affects analysis for alternative 2). The same areas will be treated, but those acres proposed 

for commercial thinning in alternative 2 would be treated by pre-commercial thinning by 

mastication or hand-treatments instead in alternative 3. 
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Cumulative Effects

Subdrainages over their lower TOC% have been inspected for CWE response potential in the 

field by an IDT or surveyed using various methods (e.g., SCI, Pfankuch). All of the subdrainages 

are considered sensitive to moderately sensitive to disturbance (i.e., 4 - 5% Lower TOC %). The 

baseline or existing condition of most of the subdrainages is below the Lower TOC %, but 

subdrainages 503.0056 and 503.3051 are over their Lower TOC %. When adding in the proposed 

action, none exceeded the Upper TOC of 14%.

Post harvest prescribed fire is proposed for many of the tractor units within the project area. Reentry could occur any time after the logging operation is complete, but since it is difficult to 

predict when this might occur, a three year re-entry was estimated (i.e., 2015) and used as a 

recovery factor for the CWE analysis. CWE response is low to unlikely for all subdrainages.

Compliance with the Land and Resource Management Plan

Compliance, with the LRMP measures, is built into the design criteria of the project. As 

documented in the effects analysis, the action alternatives would avoid tractor logging on steep 

slopes with high erosion hazard, erosion control measures would be applied appropriately, and 

ground cover and LWD would be sufficiently maintained. With implementation of the project 

design features, the action alternatives would be in compliance with LRMP requirements for the 

soil resource.

In addition, soil cumulative effects were assessed per S&G #94 to determine if more than 25 

percent detrimental ground disturbance is proposed in the RCA or more than 15 percent of a 

CAR. Ground disturbing activities are defined in the SNFPA ROD (2004) as “activities that 

result in detrimental soil compaction or loss of organic matter beyond the thresholds identified by 

soil quality standards”. This soils analysis concludes that soil productivity would not be affected 

because of soil design criteria, including Soil Design Measures 3 and 4, which limits detrimental 

soil disturbance to no more than 15% of a treatment unit. Based on this information, ground 

disturbance would not exceed these percentages in RCAs, and there are no CARs in the project 

area, so a peer review is not required. 

Effects to Soils from proposed changes in treatments

Data

A 30 point soil transect was completed for Unit T-18 for the Greys Mountain Project. Data for 

this soil transect is available in the Greys Mountain Soils Report (USDA Forest Service, 2011). 

Unit T-18 is undisturbed with a forest floor depth of 6.37 cm. Unit T-18 and Fx-9 are located on 

sensitive soils. These soils are sensitive to management because of their susceptibility to soil 

compaction. Unit T-18 and Fx-9 are underlain with Holland family soils that have a high 

susceptibility to compaction from mechanical operations occurring under moist soil conditions. 

A sandy loam is present in the upper A horizon, transitioning to a sandy clay loam throughout the 

B horizon down to the C horizon at 60 inches. A higher abundance of clay minerals causes the 

soil to have an increased chance of compaction occurring within the top 12 inches of the soil 

profile when moisture levels are above 14%. Most ground based operations rarely causes 

compaction below 12 inches.

Unit T-18 has some areas with steep 25%-35% slopes where skidding may be adverse (uphill 

skidding) and ground disturbance could occur if the area was to be thinned. This is no longer the 

case with Prescribed burning as the proposed action. 
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Conclusions

The original thinning prescription would have resulted in detrimental soil disturbance associated 

with skid trails and landings, which could have been approximately 5-7 % of the treatment areas. 

Soil disturbance includes soil compaction and displacement of surface soils (A Horizon) from 

adverse skidding (dragging logs uphill). Under the proposed new Prescribed Fire prescription, 

Units T-18 and Fx-9 will have minimal disturbance associated with prescribed fire. Most 

prescribe fire areas have low soil burn severity and soil cover is at least 50%. The overall soil 

disturbance effects to Units T-9 and Fx-9 will be very minimal. Soil management objectives and 

soil related standard and guidelines will be met.

 
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Lands/Special Uses/Recreation ___________

The direct, indirect and cumulative effects below are summarized from the Greys Mountain 

Project Lands/Specials Uses/Recreation Report (Nooney K., McPhail L. 2011).

Affected Environment

Lands and Special Uses

Land Uses and Mining Claims (See Lands and Recreation Uses Greys Mountain Project Area 

Map, 08/08/11)

Most of the National Forest System (NFS) lands inside the project area have Reserved Domain 

status. There are five Land-type special-uses authorized within the project area including: an 

apiary site (in unit T39); a road to private property authorized under permit (located between 

units T-28 and T29); a Forest Roads and Trails Act (FRTA) easement providing access to private 

property located in unit T38; the (MID) stream gauging station at Willow Creek west of Greys 

Mountain Campground, and a ditch tender cabin both authorized under Special Use Permit 

(located in unit T-29) .

• The apiary site consists of a flat area surrounded by an electric fence where up to 100 

hives of bees are located. 

• The private road authorized under permit is native surfaced, 12-feet wide and 

approximately 950 feet long leading from road 6S10 to the Sturrock property at Soquel.

• The FRTA easement was granted to provide access to private property. The easement 

may be used by the FS for protection and administration of (NFS) lands as long FS 

activities do not interfere with the Grantees use of the road.

• The MID stream gauging station is located on the stream bank of Willow Creek adjacent 

to a bridge near the Greys Mountain campground. The station is made out of a large 

culvert and contains electronic equipment that measures stream depth on a year round 

basis. 

• The MID ditch tender cabin is a wooden structure is located off the 6S10A spur road. The 

native surfaced road is 14 feet wide and approximately 1⁄4 mile long. A gate is located at 

the beginning of the A spur. 

All of these uses have been authorized under permit for years and are easily recognizable features 

on the landscape. 

MID also operates a siphon or ditch that is used on occasion to deliver water to Willow Creek. 

MID periodically performs maintenance on the ditch to keep it in a serviceable condition. The 

siphon was constructed prior to the Forest proclamation and does not require a special use 

authorization.

The Forest Service holds permanent, full public easements for Road 6S10 across private property 

located east of Highway 41 in the Paradise Springs and Soquel areas.
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There is one locatable mining claim in the project area. Willow Creek #1 is located in the 

vicinity of the Texas Flat Overflow dispersed recreation area. There are no active operations 

occurring at this time.

Developed and Dispersed Recreation

Recreation: See Lands and Recreation Map in Appendix A.

The Forest Service operates the Soquel, Greys Mountain, Texas Flat and Chilkoot developed 

campgrounds in the project area. The Soquel Campground 17.73 acres, is a developed 

campground located on Forest road 6S40 with 11 sites that can accommodate up to 66 people 

overnight. The use season for this facility is June through September. The campground is full 

most weekends from June through August. Greys Mountain Campground 17.42 acres, also 

located off Forest road 6S40, with 25 sites that can accommodate up to150 people overnight. This 

site is used heavily on weekends June through August. Texas Flat Group Campground 6.65 acres, 

is located off Forest road 6S08 with four group sites that can accommodate up to 48 people 

overnight. This site is used heavily on weekends June through August. Chilkoot Campground

5.29 acres, located off Forest road 6S07,has 15 sites that can accommodate 90 people overnight. 

This site is used heavily on weekends June through August. California Land Management, a state 

agency, manages these campgrounds for the SNF under a concessionaire permit. All four 

campgrounds total 47 acres.

Several dispersed recreation sites including the Texas Flat overflow and Soquel Overflow are also 

located inside the project area. Dispersed recreation uses are common in the project area 

including snow shoeing, cross-country skiing, and snowmobiling in the winter months. In the 

other seasons of the year, the project area is popular with horseback riders, motorized vehicle 

recreationists, hikers, and other general forest users.

Motorized Recreation

There are 5.5 total miles of designated motorized trails in various treatment units.

Man made features that are creating a degraded resource condition are forest roads in poor 

maintenance condition and user created vehicle trails that are not on the National Forest 

Transportation System (NFTS). These user created areas are a cause of high soil erosion during 

water runoff events which leads to reduced water quality and a reduction in soil production 

capacity. Unmanaged OHV use has resulted in unplanned roads and trails, erosion, watershed 

and habitat degradation and impacts to cultural sites; “Four Key Threats Facing the Nation’s 

Forest’s and Grass Lands”; USDA-FS June 2004). In March of 2010 the SNF completed the 

Travel Management Final Environmental Impact Statement (FEIS), which amends the SNF 

LRMP and implements the 2005 Travel Management Rule (36 CFR Part 212). This decision 

prohibits motor vehicle travel by the public, off designated NFTS facilities (roads, motorized 

trails and areas) except as allowed by permit or other authorization (this prohibition would not 

apply to snowmobiles.
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Environmental Consequences

Alternative 1 – No Action

Direct, Indirect and Cumulative Effects

Under the no action alternative, current management plans would continue to guide activities in 

the project area. This includes all ongoing recreation activities, lands uses and mining claims with 

existing decisions or permits, and would not change if this alternative was selected. 

While special-use permittees (including Forest Service campground concessionaires) would 

continue to perform hazardous fuels reduction around the facilities they operate, they would be 

limited to the standard 30 feet required by the Forest Service. Under consultation and in 

coordination with the Forest Service, permit holders may be able to extend fire clearances around 

their facilities to meet the 100 foot requirement of the State of California. There would be little 

protection from moderate to uncharacteristically severe wildfire. 

The continuation of natural fuels build-up would pose a wildfire threat to campgrounds and 

permit holder improvements as well as loss of revenue for commercial permit holders. 

Overstocked stands have the potential to be effected by epidemic infestations of bark beetles in 

combination with disease, and/or drought-induced mortality, in forested areas, risking the 

livelihood of commercial permit holders (including Forest Service campground concessionaires) 

Commercial permit holders (including Forest Service campground concessionaires) would likely 

experience loss of revenue because recreationists and other forest visitors they depend on, may 

be hesitant to visit parts of the forest that have high tree mortality. As public safety concerns 

increase (mainly from snag densities and high fire danger) the potential need would arise for 

areas and trails to be closed to public access. The overall aesthetic landscape viewing value would 

also be significantly reduced.

Alternative 2 – Proposed Action

Direct Effects 

Implementation of alternative 2 would not change recreation related management or permitted 

activities within the project area. The activities associated with the proposed action would include 

commercial, pre-commercial and biomass thinning of conifer stands and prescribed burning 

(understory and pile) with associated post-activity treatments. Implementation of this alternative 

may have direct effects to permitted operations and general recreation inside the project area if 

activities occur during Peak Season (Memorial Day to Labor Day) when campgrounds are most 

occupied by recreation visitors. Intrinsic values, much appreciated by the recreating public would 

be affected as well as an atmosphere of “quiet”, “peaceful”. The result would be “the lessening 

of the experience of natural sounds and the absence of mechanical and “industrial” sounds on 

forest lands (Russell, 2006).

. 

Design criteria for recreation have been developed to minimize the impacts that could occur from 

the implementation of this alternative. The overall aesthetic landscape viewing value would be 

improved because forest visitors believe forests have intrinsic values and are valued for what they 

are rather than what they produce. These intrinsic values are ones that exist about forest 

resources in general as well as about a particular place. The view or scenery is believed to attract 

those from urban areas, is a value that attracts new residents and is appreciated by long-term 

residents (Russell, 2006).
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 98 Chapter 3

While special-use permittees (including Forest Service campground concessionaires) would 

continue to perform hazardous fuels reduction around the facilities they operate, they would be 

limited to the standard 30 feet required by the Forest Service. Under consultation and in 

coordination with the Forest Service, permit holders may be able to extend fire clearances around 

their facilities to meet the 100 foot requirement of the State of California. There would be 

improved protection from moderate to uncharacteristically severe wildfire, increasing the area 

that is more fire resistant. The activities associated with the proposed action would reduce 

wildfire severity and develop a more fire resistant forest structure around developed 

campgrounds, dispersed areas and along designated OHV trails.

Indirect and Cumulative Effects 

Indirect effects are predicted to be minimal, limited to aesthetic perceptions of changes noted by 

forest visitors. There are no anticipated cumulative effects to Lands and Recreation Special Uses, 

developed and dispersed recreation or designated OHV trails resulting from this action because

with the implementation of associated recreation design criteria, it would not change recreation 

related management or permitted activities within the project area. 

Alternative 3

Direct, Indirect and Cumulative Effects

The effects of this alternative would be similar to that of alternative 2. 

Effects to Lands/Special Uses/Recreation from proposed changes in 

treatments

The change from Light Thinning (tractor thin under 20” dbh) to Prescribed Burn Only in Units 

T-18 (30 acres) and Fx-9 (97 acres) will have no effect on the Lands and Special Use resources 

in the Greys Mountain project area.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 99 Chapter 3

Terrestrial Wildlife

The direct, indirect and cumulative effects to the terrestrial wildlife species are summarized from 

the Biological Evaluation/Biological Assessment (BE/BA) for the Grey’s Mountain Ecological 

Restoration Project (Otto, 2012)

Affected Environment

The Greys Mountain Project is located within Madera County on the Bass Lake Ranger District 

of the Sierra National Forest. The project boundary encompasses 8,323 acres within the Willow 

Creek sub-watershed and 1,261 acres within the Upper Fresno River sub-watershed. The project 

area lies between two major forest road travel corridors: Beasore Road and Sky Ranch Road. The 

northern and western portions of the project area include [WUI]) defense and threat zone forest 

designations. The proposed project ranges from 4,000 feet to 7,000 feet in elevation. Primary 

vegetation types include: Sierra mixed conifer (68% of the project area), ponderosa pine (16% of 

the project area), and montane hardwood and hardwood conifer (9% of the project area). 

Montane and mixed chaparral habitat is present in 4% of the project area. The remaining habitat 

types each represent less than 1% of the project area and include: Jeffery pine, wet meadow, 

rocky outcrop, annual grassland, and lacustrine areas. 

Methodology for Analysis

A total of 13 terrestrial wildlife species were identified as Federally listed, or are candidates for 

listing, or are FSS Species, and that also may inhabit the project area or nearby areas. Federally 

listed species were determined by reviewing the USFWS on-line data base on September 9, 2011, 

(http://www.fws.gov/sacramento/y_old_site/es/spp_lists/auto_list_form.cfm). FSS Species were 

determined by reviewing the USFS Pacific Southwest Region’s (R5) Sensitive Species List of 

June 8, 1998, as amended on March 6, 2001, May 7, 2003, and October 15, 2007. 

The 13 species were evaluated to determine whether they or their habitats exist, or potentially 

exist, in or near the project area. If the species or their habitats do exist in the area, then they 

were further assessed to determine whether there was potential for the species or its habitat to be 

directly, indirectly, or cumulatively affected by the project. Seven of the 13 species met these 

criteria; therefore they were analyzed in detail. The following terrestrial wildlife species are 

either Federally listed, or candidates for listing, or Forest Service Sensitive Species, that are 

known, or believed to be, in or near the project area:

• California Spotted Owl (Strix occidentalis occidentalis) Forest Service Sensitive (R5)

• Great gray owl (Strix nebulosa) Forest Service Sensitive (R5)

• Northern goshawk (Accipiter gentilis) Forest Service Sensitive (R5)

• Pallid bat (Antrozous pallidus) Forest Service Sensitive (R5)

• Western red bat (Lasiurus blossevillii) Forest Service Sensitive (R5)

• American marten (Martes americana) Forest Service Sensitive (R5)

• Pacific fisher (Martes pennanti pacifica) Forest Service Sensitive (R5)

6 of the 13 species were not analyzed in detail within the Greys Mountain Project Biological 

Assessment/Biological Evaluation because they either do not occur in the project area, or do not 

have habitat within or adjacent to the project area, nor are affected directly, indirectly, or 

cumulatively by this project. Table 13 summarizes these species habitat, area of consideration, 

and the rationale for not including them in detailed analysis f. The Greys Mountain Ecological 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 100 Chapter 3

Restoration Project would have no effect on the following six species or their habitat, therefore 

they were not analyzed in detail in this BEBA:

• Valley Elderberry Beetle (Desmocerus californicus dimorphus) Federally Threatened

• Bald Eagle (Haliaeetus leucocephalus) Forest Service Sensitive

• Wolverine (Gulo gulo) Federal Candidate Species; Forest Service Sensitive

• Willow flycatcher (Empidonax trailli) Forest Service Sensitive

• Sierra Nevada red fox (Vulpes vulpes necator) Forest Service Sensitive

• Townsend’s big-eared bat (Corynorhinus townsendii) Forest Service Sensitive

Table 13. Special Status species on the Sierra NF and a summary of their habitats, area of 

consideration, and rationale for inclusion/exclusion from detailed analysis within the 

project BE/BA.

Species

(Elevation 

Range in 

Feet)

Habitat Analysis 

Boundary Rationale a

California 

wolverine

(Elevation 

7,000’-

12,000’)

Uses a variety of habitats within remote, 

undisturbed wilderness areas including 

alpine coniferous forests dominated by fir, 

spruce, hemlock, Douglas-fir, or lodgepole 

pine. Dens include snow-covered roots, 

standing or down logs with large cavities, 

holes under coarse woody debris, old 

beaver lodges, bear dens or rocky areas.

Not known to 

occur in 

Sierra 

National 

Forest; 

potentially 

extirpated 

from 

California

There are no known 

locations and no suitable 

habitat for California 

Wolverine in or adjacent 

to the project. The project 

area is within front 

country WUI and does not 

possess the remote 

wilderness characteristics 

associated with wolverine 

habitat. This species 

would not be analyzed 

further in this document.

Bald eagle

(< 10,000’)

Winter habitat in the Sierra NF, day 

perches, roost sites and foraging sites 

along large open waters with abundant 

prey. Known nest sites are at Bass Lake 

and Shaver Lake.

1⁄2 mile from 

large water 

bodies

There are no known 

locations and no suitable 

habitat for Bald Eagle in 

or adjacent to the project. 

This species will not be 

analyzed further in this 

document.

Valley 

elderberry 

longhorn 

beetle

(< 3,000’)

Habitat consists of elderberry shrubs in 

Great Valley Oak Riparian Forests below 

3000 feet in elevation

Within 1⁄4 

mile of 

project area

The project ranges from 

3,800’ to 7,200’ in 

elevation which is above 

the elevational range of 

the Valley elderberry 

longhorn beetle. This 

species would not be 

analyzed further in this 

document.

Willow 

flycatcher

(WIFL)

(2,000’-

8,000’)

Western Sierra Nevada's

Found in willow-dominated riparian areas, 

including moist meadows with perennial 

streams and smaller spring-fed or boggy 

areas

Within wet 

meadows 

with 

extensive 

willow 

The meadows within the 

project are either not of 

the size, or do not contain 

the extensive patches of 

willow required by WIFL 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 101 Chapter 3

Species

(Elevation 

Range in 

Feet)

Habitat Analysis 

Boundary Rationale a

patches for breeding. Further, 

there are no recorded 

observations of willow 

flycatchers on the Bass 

Lake Ranger District. 

This species will not be 

analyzed further in this 

document.

Sierra 

Nevada red 

fox

(7,000’-

12,000’)

Red fir and lodge pole pine in subalpine 

and alpine fell-fields of the Sierra Nevada. 

Dens seem to be in rock/talus slides or 

earthen excavations/holes.

3 mile radius 

around 

project area

There are no known 

locations and no suitable 

habitat for Sierra Nevada 

red fox in or adjacent to 

the project. The project 

area is within front 

country WUI and does not 

possess the remote 

wilderness characteristics 

associated with SN red 

fox habitat. This species 

will not be analyzed 

further in this document.

Townsend's

big-eared 

bat

(<10,000’)

Found throughout the Sierra Nevada. 

Inhabits isolated mines/caves with low 

human disturbance.

1⁄4 mile 

around 

project 

boundary

There are no caves or 

other suitable habitat for 

the Townsend’s big eared 

bat within the project. 

This species will not be 

analyzed further in this 

document.

California 

spotted owl

(>8,000’)

Sierra Nevada province in CA. Need at 

least 40% canopy closure and an average 

dbh of 11 inches

1⁄2 mile 

around 

Project 

boundary

Potential impacts to the 

California spotted owl 

and/or its habitat will be 

analyzed in this document

Northern 

goshawk

(<10,000’)

Dense mature conifer and deciduous 

forests interspersed with meadows, other 

openings and riparian areas. Found in 

mixed conifer to lodge pole pine

1⁄2 mile 

around 

Project 

boundary

Potential impacts to the 

Northern goshawk and/or 

its habitat will be 

analyzed in this document

Great 

gray owl

(4,500’-

7,500’)

Found in large moist montane meadows 

surrounded by dense forest of medium to 

large mixed conifer and red fir.

1⁄2 mile 

around large 

meadows 

(15 acres +) 

or meadow 

complexes

Potential impacts to the 

Great Gray Owl and/or its 

habitat will be analyzed in 

this document

Pallid bat

(<6,000’)

Uses a variety of habitats. Depends on oak 

woodlands for foraging. Roosts in mines, 

snags, and in crevices in oaks

1⁄4 mile 

around 

project 

boundary

Potential impacts to the 

pallid bat and/or its 

habitat will be analyzed in 

this document

Western 

Red Bat

(<3,000’)

Uses a variety of habitats. Prefers edges or 

habitat mosaics that have trees for roosting 

and open areas for foraging

1⁄4 mile 

around 

project 

Potential impacts to the 

Western red bat and/or its 

habitat will be analyzed in 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 102 Chapter 3

Species

(Elevation 

Range in 

Feet)

Habitat Analysis 

Boundary Rationale a

boundary this document

American 

marten

(>7,200’)

Found in mesic, late successional 

coniferous forests. Dens are in trees, 

snags, downed logs and rocks in 

structurally complex old forests.

3.1 mile 

radius 

around 

project area

Potential impacts to the 

American marten and/or 

its habitat will be 

analyzed in this document

Pacific 

fisher

(5,000’-

8,500’)

Coniferous and mixed forests with high 

canopy closure and late successional oldgrowth forest structural elements. Den and 

rest sites associated with water or riparian 

habitats. Rest sites include large standing 

conifers or hardwoods (snags or live trees). 

Dens occur in cavities of standing large 

diameter conifers or hard-woods (snags or 

live trees)

3.1 mile 

radius 

around 

project area

Potential impacts to the 

Pacific fisher and/or its 

habitat will be analyzed in 

this document.

Environmental Consequences

Mitigation and Monitoring

This project integrates management design measures that help mitigate potential impacts to 

wildlife habitat. These measures include, but are not limited to, LOPs which restrict treatment 

operations to avoid breeding seasons, Riparian management areas, streamside management zones, 

and OFL’s for perennial streams. Project design criteria common to all alternatives were 

developed through the collaborative process of the SNAMP Integration Team meetings. These 

design criteria were developed to maintain habitat connectivity, special habitat elements for 

terrestrial wildlife species, and limit the amount of behavioral disruption during project 

implementation and post-treatment. Project design criteria are outlined in Chapter 2 of this 

document.

Monitoring of fisher and high quality fisher habitat within the Greys Mountain Project area and 

the adjacent four key-subwatersheds are being conducted by Rick Sweitzer, UC Berkeley fisher 

team, as part of the (SNAMP). (More information regarding SNAMP can be found on-line at 

http://snamp.cnr.berkeley.edu/).

Alternative 1 – No Action

Alternative 1 is the no action alternative. Under the no action alternative, current approved 

management plans would continue to guide management of the terrestrial analysis area. This 

includes all ongoing activities with existing decisions or permits that would not be changed if this 

alternative were selected including: roads and trails; plantation maintenance, cattle grazing, and 

recreation. No project associated treatments would be implemented.

Direct Effects

There would be no direct effects to any terrestrial wildlife species under this alternative because 

there would be no new activities conducted that would change habitat conditions.
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Indirect Effects

There may be indirect effects to terrestrial wildlife habitat if alternative 1 is selected as no fuels 

treatments would occur and the continued immediate threat of uncharacteristically severe, standreplacing wildfire would remain unabated. Additionally, in failing to reduce stand density, 

drought stress and subsequent insect and disease mortality would exacerbate the threat of 

uncharacteristically severe wildfire. Furthermore, the high probability of a drying climate change 

in the Western United States would potentially further compound these effects.

Cumulative Effects

Alternative 1 would not produce impacts to the environment that add to cumulative effects.

Alternative 2 – Proposed Action and Alternative 3-Lower and Limited 

Mid-Level Canopy Treatments, All Treatment Areas

Direct Effects

Direct effects from the implementation of alternative 2 or alternative 3 may occur to California 

spotted owl, great gray owl, northern goshawk, American marten, Pacific fisher, western red bat, 

and pallid bat, although the potential effects would be limited to short-term noise disturbance of 

the project management, which potentially could lead to an energetic expense from avoidance 

reactions. No direct mortality from project activities is expected to occur to these species because 

LOPs restricting project activities would be implemented, for a variety of species, to protect nest 

and den sites, as described in the BE/BA. In particular, a fisher LOP would be implemented for 

all suitable fisher denning habitat, throughout the project area, regardless of whether a den site

buffer is present. This would protect fisher den sites that may be occupied, but not identified 

through the SNAMP project.

Indirect Effects

Habitats in the project area are defined according to the “California Wildlife Habitat 

Relationship” (CWHR), as shown in Map 17 in the Map Package. Detailed CWHR assessment 

can be found in Appendices C and G of the Greys Mountain Terrestrial Wildlife BE/BA (USDA 

Forest Service 2011b). Species specific habitat needs as well as the habitat availability within the 

project area are listed within the following effects analysis. The effects analysis further describes 

the changes to this habitat for each alternative. Special project design measures for the Greys 

Mountain Project were developed in concert with the Bass Lake District interdisciplinary team, 

Pacific Southwest (PSW) Research scientists, and concerned public participation groups. These 

design measures would be implemented under either of the two action alternatives. Within this 

project area special considerations have been given to maintaining higher levels of heterogeneity 

and stand diversity through actions such as delineating OFLs surrounding perennial streams. 

Higher levels of biodiversity have also been planned for by marking retention groups of large 

diameter trees in which higher basal areas will be retained. Between 500 to750 of such tree 

groups were identified in the project area. These tree groups are composed of a cluster of three or 

more trees, 30” dbh or greater, with touching crowns, and would benefit those species which 

utilize dense groupings of large trees. Ideally these groups would contain “defect” trees, those 

that have cavity and platform creating defects including: mistletoe, rot, forked top, broken limbs, 

and broken tops. Another project design measure which would maintain biodiversity is the 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 104 Chapter 3

identification of retention areas around large oaks within treatment units. Two to three large oaks 

per acre were identified and marked with a dot of paint. These oaks would retain a zone of no 

activity around them measuring 35 feet, or dripline circumference around the oak (whichever is 

greater). A total of 1,429 oaks were identified throughout the project area for this understory 

retention treatment.

The delineation of OFLs, retention of large tree groups, and oak no treatment zones would ensure 

a heterogeneous post treatment landscape resulting in the continued accessibility of both hiding 

cover and prey availability within these areas of biodiversity. As this project proposes thinning 

from below, very few changes in California Wildlife Habitat Relationship (CWHR) habitat type 

are expected to occur throughout the entire Greys Mountain Project area. 

Effects to Terrestrial Wildlife Habitat: The Existing Vegetation GIS feature class was refined 

for the Greys Mountain Project using existing structure analysis from 292 stand examination plot 

data collected in 2011 throughout the project boundary, as well as forest aerial photography 

interpretation from the 2001 flight-line, and 1 meter resolution satellite imagery from the National 

Agricultural Imagery Program (NAIP). Plantation CWHR vegetation typing was refined through 

field verification as well as aerial photo interpretation by the district silviculturist. Based on past 

experience with similar situations and professional judgment, the district silviculturist was able to 

estimate the anticipated changes to CWHR habitat throughout the treatment units based on the 

various stand prescriptions and proposed alternatives. A summary table is shown below for the 

CWHR vegetation changes that are expected to occur through the implementation of Alternative

2 or 3. 

Table 14. Action Alternatives Summary of changes to CWHR Forest Type within 

treatment units of the Greys Mountain Project

Alternative 2 Alternative 3

CWHR Habitat 

Type Pre-treatment

CWHR Habitat 

Type Post-treatment

Number of Acres of 

Density Change

Number of Acres of 

Density Change

PPN4D PPN4M 5 acres 2 acres

PPN5D PPN5M 3 acres 2 acres

MHC4D MHC4M 1 acre 1 acre

SMC4D SMC4M 111 acres 47 acres

SMC4D SMC4P 1 acre 1 acre

SMC5D SMC5M 2 acres 2 acres

Total Acres CWHR Habitat Density Change 123 acres 55 acres

Total planning area acreage for the Greys Mountain Project is 9,581 acres, and treatments units 

are planned for approximately 3,565 of those acres. A total of 121 acres, or 4% of the total 

acreage of treatment units, are anticipated to have changes in CWHR density under Alternative 2, 

and 53 acres or 2% under Alternative 3. These changes in CWHR habitat density are spread 

across the treatment units as detailed in Appendix C of the Terrestrial Wildlife BE/BA (USDA 

2011a). 

The projected changes to CWHR habitat under the proposed Alternative 2 may result in short 

term effects in the way terrestrial wildlife species utilize the habitat. Individuals may leave 

treatment areas during project implementation, and would likely rely more heavily on other areas 

of their home range. The canopy cover in the project area is expected to convert to higher quality 

habitat within 5-15 years after completion of the management actions as the remaining tree 

crowns grow and the understory develops. The resulting stand also should show increased health, 

growth rate, and resistance to large scale stand replacing wildfire.
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Sierra National Forest – 105 Chapter 3

There are no expected indirect effects to the following species due to lack of suitable habitat 

within the project area: Great gray owl, Townsend’s big-eared bat, and western red bat.

Indirect Effects are summarized below for the following species: Pacific fisher, California spotted 

owl, Northern goshawk, Pallid bat, and American marten.

Pacific Fisher: CWHR type changes are projected for 123 acres for Alternative 2 and 55 acres 

for Alternative 3. Alternative 2 is the most aggressive management alternative and shows the 

greatest amount of change in CWHR 2.1 fisher habitat scores. These changes are relatively minor 

however, and the percentage of CWHR 2.1 habitat retained would be greater than 95%. 

Five female fishers have home ranges (95% use kernel calculated by R. Sweitzer, unpublished 

SNAMP data) which overlap with the boundary of the Grey’s Mountain Ecological Restoration 

Project. The percentage of home range overlap with the Grey’s Mountain Ecological Restoration 

Project boundary ranges from 1.9% to 85%, averaging 45% for all five female fishers. The 

overlap between female fisher home range and treatment unit boundaries for the Grey’s Mountain 

Ecological Restoration Project is much lower, ranging from 0.05% to 29%, averaging 17% for all 

five female fishers. All female fisher home ranges extend beyond the project boundary. 

Due to project design criteria designed to maintain high canopy closure (not below 50%, with a 

preference for greater than 60%) throughout the treatment units, CWHR type changes are 

projected for 123 acres (3% of the total treatment area) if Alternative 2 is implemented. There 

will be minor change to CWHR 2.1 habitat scores across the treated landscape. Post-treatment 

percentage of habitat retained within female home ranges for this Alternative ranges from 99.5% 

to 100%, with an average of 99.68% habitat retained at current CWHR 2.1 values. The Home 

Range for Fisher F39 is most affected by proposed activities, with a loss of 0.5% of habitat value 

that would occur over 28% of her documented range. 

Disturbance to breeding females during project implementation will be minimized by the 

application of a limited operating period for all suitable fisher denning habitat. Breeding season 

movements should not increase due to project implementation due to the application of the LOP. 

Important legacy structures and potential denning and resting sites such as large diameter black 

oaks and conifers should remain in sufficient numbers for resting and denning sites so females 

should not have to expand their home ranges in search of these features.

There are currently four standing dead conifers per acre ≥16” dbh which may be used as fisher 

denning and resting sites throughout the project treatment units. Snags would only be removed if 

they meet the definition of a danger tree. There are additional black oaks throughout the project 

area that may serve as denning or resting sites that are not accounted for in these numbers of trees 

per acre. Conservation of large diameter trees is important to ensure adequate resting/denning 

sites for fisher as these structures are thought to be most limiting across the environment. Each 

treatment unit retains far more than 17 large live conifers per acre (trees >20”dbh) that may be 

used as denning or resting sites by Pacific fisher, with an average of 33 live conifers per acre 

remaining that are greater than 20”dbh across all the treatment units. This number does not 

include the extensive numbers of black oaks that are present within the Grey’s Mountain 

Ecological Restoration Project (Otto personal observation), nor does it account for any snags 

present within the units. As the majority of large trees >20”dbh would be retained through the 

implementation of Alternative 2 or 3, and all snags that do not meet the definition of a danger tree 

would be retained, the Greys Mountain Project area would continue to provide adequate numbers 

of resting and denning structures for fisher.
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Sierra National Forest – 106 Chapter 3

There may be a short-term reduction in prey availability within some areas of the treatment areas; 

however, long-term positive effects of treatment should promote the growth and re-growth of 

understory vegetation, which provides forage for prey species, as well as hiding and thermal 

cover. The horizontal and vertical diversity of forest vegetation structure and species also may be 

improved in some sites as a result of partially opening the forest overstory, particularly with 

Alternative 2. This in-turn would bring greater biodiversity into the stands, promoting greater 

prey species abundance and diversity.

Habitat connectivity would be maintained throughout the implementation of this alternative by 

design criteria common to all alternatives including OFLs, retention of shrub understory 

throughout treatment units, large tree groups, and areas between units where no treatments would

occur. The inclusion of untreated areas along steep sloped regions and riparian corridors 

(primarily Willow Creek, Chilkoot Creek, and several unnamed perennial tributaries) would

maintain habitat connectivity and fisher dispersal routes.

The untreated areas, interconnected with OFLs would accommodate daily fisher movements as 

well as dispersal movements, providing habitat connectivity throughout the Greys Mountain 

Project area and dispersal routes to the north and south. Fisher should also retain movement 

opportunities between adjacent high quality habitat areas such as Nelder Grove. These areas of no 

treatment are mapped in the project BE/BA and provide a visual representation of movement 

capabilities throughout the project area during project implementation and post-treatment. 

Additionally, with Design Criteria Common to All Action Alternatives, the inclusion of large tree 

groups and the preservation of understory vegetation in cooler, moister sites within treatment 

units would maintain heterogeneity of the habitat post treatment and aid in fisher movements.

Design criteria common to all action alternatives includes a LOP restricting project activities 

from March 1 through June 30 which would be applied to all potential fisher denning habitat and 

should limit potential disturbance to females during denning and kit rearing. Units with a fisher 

LOP are outlined in the project BE/BA.

Disturbance of habitat may result in short term effects in the way fisher utilize the habitat. Fisher 

may leave treatment units during project implementation, and would likely rely more heavily on 

other areas of their home range. Individual energetic expenses may be increased if fishers have to 

travel farther to forage, however with areas of adjacent suitable habitat outside treatment areas 

but within their home range, it is unlikely this would result in individual mortality.

Habitat disturbance in the project area may lead to increased predation of fisher by mountain lion, 

bobcat, or coyote. Predation potential could increase if an individual fisher were to move into 

unfamiliar habitat, although this would be unlikely as all male and female home ranges extend 

beyond the project boundary. Habitat disturbance in the project area may also exacerbate 

individual fisher mortality induced by disease. The degree of these potential effects are unknown, 

but may be illuminated through the SNAMP research.

Alternative 3 would focus solely on treating surface and ladder fuels (within the lower and 

limited mid-level canopy levels) needed to achieve fire and fuels objectives. There would be no 

additional treatments to address stand density/forest health objectives. 

Without density management of the stands for forest health purposes, insect and disease induced 

mortality of trees throughout overstocked stands would remain a threat to fisher habitat. Minor 

outbreaks of disease or insect infection can be beneficial in creating decadent habitat 

characteristics; however extensive outbreaks which can occur during drought periods can 

drastically affect large contiguous blocks of land. Habitat effects could be similar to those that 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 107 Chapter 3

would occur with severe wildfire and could ultimately lead to habitat fragmentation or vegetation 

type conversions. 

Long-term positive effects of fuels treatments (due to the reduction of fire hazard) outweigh the 

short-term negative effects of fuel treatments (due to immediate loss of forest biomass) on fisher, 

especially when assuming a more severe fire regime in the future (Spencer et al. 2008) 

Vegetation treatment has short-term impacts to habitat quality, particularly over the first year, 

however, new understory growth within the first two years by herbaceous, as well as woody 

vegetation, can also lead to habitat enhancement for a variety of wildlife, including fisher and 

fisher prey species, in the form of new forage and hiding/thermal cover. Habitat recovery 

following an uncharacteristically severe wildfire would take considerably longer—based on the 

silvicultural report prepared for this project an estimated 90-110 years if brought back to 

conditions similar to the historical logging that occurred throughout the project area in the late 

1800’s. 

California Spotted Owl: Suitable spotted owl foraging habitat consists of mature conifer stands 

with a minimum average dbh of 11”, a minimum canopy cover of 40%, and high quantities of 

down logs and standing snags. Suitable nesting habitat has canopy cover of ≥60%, and large 

diameter trees with cavities, mistletoe brooms, and other structures suitable for nesting platforms. 

Within the project boundary there are approximately 7,603 acres of high and moderate quality 

CWHR California spotted owl habitat (nearly 80% of the project area).

A total of 3,033 acres within the project area are within California spotted owl Protected Activity 

Centers (PACs) or Home Range Core Areas (HRCAs) (Map 6, EIS map packet). This constitutes 

over 30% of the project area. Of these 3,033 acres, 1,084 are proposed for treatment in the Greys 

Mountain project, primarily within the HRCA designations. Fuels treatments have been designed 

for these areas to reduce the risk of uncharacteristically severe wildfire.

Eight separate owl activity centers are currently known within the project area, with seven of 

those activity centers falling within treatment units. These are displayed in Table 15. 

Additionally, there are several PACs and HRCAs within a 1.3 mile buffer of the project area 

where no work is proposed but owls could experience some noise disturbance from project 

implementation. These include portions of the following PAC/HRCAs: MAD0002, MAD0003, 

MAD0010, MAD0078, MAD0085, MAD0076, and MAD0089. This noise disturbance would be 

minimized by geographic features such as ridgetops and canyons that would buffer mechanical 

noise. 

The project proposes to maintain the highest canopy closure possible while still meeting fire and 

fuels objectives, and under Alternative 2 managing for forest health and stand density as well. 

The prescriptions aim for a canopy closure of not less than 50%, with a preference for 60% or 

greater immediately post treatment. All S&Gs from the SNF LRMP as amended by the SNFPA 

ROD (USDA 2004) would be followed in the implementation of this project. As this project 

proposes thinning from below, very few changes in CWHR habitat type are expected to occur 

throughout the entire project area. 

Proposed treatment units overlap seven California spotted owl PACs (Table 15). Canopy cover 

would not be reduced below 60% within PACs and 50% within HRCAs, where currently 

available, to meet S&G 7; in most treatment units, canopy cover will be maintained at much 

higher levels as shown in the table below. Additionally, a LOP from March 1 through August 15 

would be applied to all treatment units within a quarter mile boundary of all active spotted owl 

nest sites to minimize disturbance to breeding owls. Appendix C in the Terrestrial Wildlife 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 108 Chapter 3

BE/BA (USDA Forest Service, 2011b) provides additional habitat information for CWHR 

changes expected to occur for each proposed project alternative.

A change in proposed treatments T-18 and FX-9 has taken place since the DEIS was circulated 

for public comment. The units T-18 and Fx-9 (128 acres total) were originally planned for 

precommercial and commercial thinning by hand and or mechanical methods, but the WUI land 

allocation was removed during the planning process after field verifications showed the private 

property did not possess the criteria to keep it as such. After the land allocation was changed, the 

treatments proposed were not modified to reflect this change. Public review of the DEIS pointed 

out this error and the treatments were changed to the correct method that was allowed for that 

land allocation which was prescribed burning only. Additionally, the thinning prescriptions have 

been changed for several units including T-35 and the portion of unit T-37 within Spotted Owl 

PAC. The prescription has been modified to not remove trees ≥20”dbh within the PAC areas. 

Prescriptions for other units in Spotted Owl habitat, including T-33 and T-38, have also been 

modified to remove fewer large trees in the 20-25 and 26-29 inch dbh size classes. These changes 

in thinning prescription will help maintain larger trees, higher canopy closure, and important 

Spotted Owl habitat structure.

The effects assessment for California spotted owls has been updated to reflect these changes and 

includes additional literature citations. This new data did not significantly change the conclusions 

of the spotted owl analysis, nor did it change the effects determinations for spotted owl under any 

of the proposed alternatives.

Table 15. Greys Mountain Project Proposed Treatment Units within California spotted owl 

PACs or HRCAs

SNF

PAC/

HRCA ID

Treatment 

Proposed 

for area

NEPA 

Unit # of 

Trtment

Acreage of 

PAC/

HRCA 

proposed for 

treatment

Projected CWHR 

Changes Comments

MAD0026 

PAC

Tractor 

thinning and 

post harvest 

underburning

T37

T35 78 acres

4 acres of SMC4D are 

projected to convert to 

SMC4M through 

thinning and 

underburning 

treatments. No trees 

≥20” dbh will be 

removed from PAC

Canopy closure 

would be maintained 

at 70% or greater 

where currently 

available.

MAD0026 

HRCA

Tractor 

thinning and 

post harvest 

underburning

T33 213 acres

10 acres of SMC4D are 

projected to convert to 

SMC4M through 

thinning and 

underburning 

treatments

Canopy closure 

would be maintained 

at 50% or greater 

where currently 

available.

MAD0031 

PAC

Underburnin

g, hand 

thinning, and 

post harvest 

underburning

Fx9

T18

H7

H6

155 acres

2 acres of PPN4D are 

projected to convert to 

PPN4M through 

thinning and 

underburning 

treatments

Canopy closure 

would be maintained 

at 60% or greater 

where currently 

available.

MAD0031 

HRCA

Tractor 

thinning and 

post harvest 

underburning

T8

T9 65 acres

3 acres of PPN5D are 

projected to convert to 

PPN5M through 

thinning and 

underburning 

treatments; changes 

would occur primarily 

in the fuelbreak areas

Canopy closure 

would be maintained 

at 70% or greater 

where currently 

available.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 109 Chapter 3

SNF

PAC/

HRCA ID

Treatment 

Proposed 

for area

NEPA 

Unit # of 

Trtment

Acreage of 

PAC/

HRCA 

proposed for 

treatment

Projected CWHR 

Changes Comments

MAD0042 

PAC

Hand 

thinning, 

tractor 

thinning, 

underburning

H5

T5

T16

72 acres

2 acres are projected to 

convert from SMC4D 

to SMC4M through 

thinning and 

underburning 

treatments

Canopy closure 

would be maintained 

at 60% or greater 

where currently 

available.

MAD0042 

HRCA

Tractor 

thinning T16 214 acres

20 acres are projected to 

convert from SMC4D 

to SMC4M through 

thinning and 

underburning 

treatments

Canopy closure 

would be maintained 

at 60% or greater

where currently 

available.

MAD0043 

PAC

Tractor 

thinning, 

Mastication

T8

M2

M1

71 acres

3 acres of PPN5D are 

projected to convert to 

PPN5M through 

thinning and 

underburning 

treatments; changes 

would occur primarily 

in the fuelbreak areas

Canopy closure 

would be maintained 

at 70% or greater 

where currently 

available.

MAD0043 

HRCA

Mastication, 

Prescribed 

burning, 

tractor 

thinning, 

post 

treatment 

underburning

M1

M2

Rx4

Rx6

T21

Rx22

160 acres

8 acres of SMC4D are 

projected to convert to 

SMC4M and 4 acres of

PPN4D are projected to 

convert to PPN4M 

through prescribed 

burning, and 

thinning/underburning 

treatments

Canopy closure 

would be maintained 

at 60% or greater 

where currently 

available.

MAD0076 

HRCA Mastication M3 23 acres

No Changes to CWHR 

area projected to occur 

within CWHR Spotted 

Owl habitat. 

Decadent chaparral 

would be converted to 

early seral stage 

chaparral through 

mastication activities

MAD0087 

HRCA

Tractor 

thinning/ 

underburning

T6 28 acres

1 acre of SMC4D is 

projected to convert to 

SMC4M through 

thinning and 

underburning 

treatments

Canopy closure 

would be maintained 

at 50% or greater 

where currently 

available.

MAD0089 

HRCA

Tractor 

thinning/ 

underburning

T5 5 acres

No changes to any 

CWHR types are 

projected for this 

treatment unit

Canopy closure will 

be maintained at 50% 

or greater where 

currently available

Total acres 

within 

treatment 

areas: 1,084

Total of 53 acres 

projected CWHR 

density change

NOTE: 

PPN=Ponderosa Pine; 

SMC=Sierra Mixed 

Conifer
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 110 Chapter 3

Table 16. Stand Attributes for units in California Spotted Owl PAC's and HRCA's

WUI 

Area Unit Owl Habitat

TPA >10”dbh

TPA Removed 

(by dbh range 

(inches))

Basal Area 

(ft2/acre) Canopy Cover

Before After 16”-

19”

20”-

25”

26”-

29” Before After Before After

Threat 

Zone T8 PAC/HRCA 105 81 3 1 0 192 167 74(D) 70(D)

N/A

Rx9 

(was 

Fx9)

PAC Data not avail. 0 0 0 Data not avail. Data not avail.

Threat 

Zone T16 HRCA 120 72 13 9 1 294 220 77(D) 67(D)

N/A

Rx18

(was

T18)

PAC 79 79 0 0 0 205 205 77(D) 75(D)

Threat 

Zone T33 HRCA 105 64 9 6 1 273 220 70(D) 61(D)

Threat 

Zone T35 PAC 117 64 24 0 0 334 270 75(D) 72(D)

Defense 

Zone T37 PAC 134 72 20 0 0 401 326 80(D) 76(D)

The project forest vegetation types are primarily Sierra mixed conifer and Ponderosa pine, which 

as part of S&Gs, requires maintaining four of the largest snags per acre distributed irregularly 

across the landscape (USDA 2004b). The project would retain an average of Nine snags ≥10” dbh 

and four large snags ≥15” dbh across the treatment units, which meets the requirements set forth 

in the SNFPA ROD. The project would also retain adequate numbers of large (≥20” dbh) live 

conifers to serve as replacement snags in the future as some of these large trees receive 

environmental damage and decadence or succumb to disease and/or insect attacks.

Quantitative information on the ideal levels of coarse woody debris (CWD) retention levels are 

limited, however a synthesis of the available literature is available in RMRS-GTR-105 “Coarse 

Woody Debris: Managing Benefits and Fire Hazard in the Recovering Forest” (Brown et al. 

2003). This study examined available literature on the ecology of CWD, its importance to wildlife 

and soils, its contribution to potential fire behavior, historical stand structures and large fuel 

accumulations, and potential re-burn severity as a basis for identifying optimum quantities of 

CWD (Brown et al. 2003). CWD is typically defined as dead standing and downed pieces of 

wood larger than 3 inches in diameter (Harnon et al 1986, Brown et al 2003). For warm, dry 

ponderosa pine and Douglas-fir forest vegetation types, Brown et al. (2003) recommend retaining 

between 5-20 tons per acre of CWD ≥3” dbh. Larger logs (≥8” dbh) are used more frequently by 

a variety of wildlife species, while also posing a lower fuels loading threat for high severity fire 

since they are classified as >1,000 hour fuels. Prescribed burning proposed for the Greys 

Mountain Project is of low intensity, and generally does not consume fuels >1,000 hours (≥8 

dbh). Therefore nearly all logs ≥11 dbh should remain as CWD within the Greys Mountain 

treatment units.

This project proposes to thin from below, mostly reducing understory vegetation. There is a 

potential for noise disturbance to spotted owls during project implementation from an increase in 

human presence, operating equipment, and transportation of materials. Owl activity centers or 

nests near unit operations would be protected by a 1⁄4 mile LOP during the breeding season from 

March 1-August 15. This LOP would minimize disturbance to breeding owls. California spotted 

owls in proximity to work crews and vehicles during project implementation may be disturbed 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 111 Chapter 3

sufficiently to leave the immediate area, resulting in a small energetic expense. Owls may also 

experience a missed feeding opportunity due to increased anthropogenic activity in the area. 

These potential effects are expected to be of short duration during the period of active vegetation 

removal.

Low intensity prescribed burning is planned for post-thinning treatment throughout nearly all of 

the tractor thinning units as a secondary fuels maintenance treatment. Roberts et al (2011) 

indicate that low to moderate severity fires are important for maintaining habitat characteristics 

essential for spotted owl site occupancy. They suggest “managed fires that emulate the historic 

fire regime may maintain spotted owl habitat and protect this species from the effects of future 

catastrophic fires.” (Roberts et al 2011). Understory burning and commercial thinning activities 

may eliminate some woodrat nests within the project area, which could lead to a decrease in 

available prey items and therefore an indirect effect to the California spotted owl. Woodrats and 

other spotted owl prey species have evolved in the presence of frequent, low-to moderateintensity fires, and any burning occurring as a secondary fuels treatment would be of 

low/moderate intensity. Therefore, any potential effects from prescribed burning in the treatment 

units would be negligible. Although there may be a short term decreases in woodrat numbers, it is 

anticipated that woodrats would return to treated areas from adjacent areas within a few years. 

Additionally, availability of other prey items such as flying squirrels should remain constant as 

their nests/dens occur higher in the canopy and would not be affected by an understory burn.

Northern goshawk: Within the project boundary there are approximately 7,840 acres of suitable 

foraging habitat, and 5,795 acres of suitable nesting habitat. There are two historic Northern 

goshawk (PACs) located within the boundaries of the project: SIEGH43 and SIEGH45 (Map 7, 

EIS map packet). Northern goshawk survey visits were conducted throughout all suitable habitat 

including both PACs within the project area from July 20, 2011 through August 28, 2011. This 

constitutes the first year of surveys in a two-year protocol as per the protocol: Survey 

Methodology for Northern Goshawks in the Pacific Southwest Region, U.S. Forest Service 

(2002). The second year of surveys for northern goshawk in the project will take place in the 

summer of 2012.

A northern goshawk nest was found occupied on July 27, 2011 just east of the 6S36A road near 

Texas Flat campground in PAC SIEGH43. Two nests were found in this nest stand, although, 

only one of the nests appear to have been utilized in 2011. This nest sight and any future nest sites 

located within the Greys Mountain project would be protected with a LOP from February 15 

through September 15 as outlined in S&G #76 (USDA Forest Service, 2004).

An historical PAC survey was conducted within Soquel SIEGH45 from July 20, 2011 through 

August 4, 2011. It is believed that no Northern goshawks nested in PAC SIEGH45 during the 

2011 season, and that red tailed hawks nested within the boundary of that PAC.

Table 17. Greys Mountain Treatment Units within Northern Goshawk PAC’s

SNF

PAC ID

Treatment 

Proposed for 

area

NEPA Unit # 

of Trtment

Acreage of PAC 

proposed for 

treatment

Projected CWHR 

Changes PAC Status

SIEGH45 Tractor thinning, 

underburning T1, T3 50 acres

3 acres of SMC4D 

are projected to 

convert to 

SMC4M through 

thinning and 

underburning 

treatments

Not currently 

occupied by 

Northern Goshawk. 

Red tailed hawk nest 

documented in 2011.

SIEGH43 Tractor thinning, 

underburning T35 33 acres 2 acres of SMC4D are projected to 

Successful Northern 

Goshawk nesting 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 112 Chapter 3

convert to 

SMC4M through 

thinning and 

underburning 

treatments

documented in 2011

All goshawk nest sites within the project area would be protected by an LOP. Outside of the 

LOP, portions of both goshawk PACs would be thinned to the degree allowed under the SNF 

LRMP as amended by the SNFPA ROD (USDA 2004b). Less than 25% of the total PAC area is 

proposed for treatment. The PACs would not be reduced to less than 60% canopy cover,

therefore, would not be diminished to less than nesting habitat. All snags would be retained 

during project implementation except in those cases where they pose a hazard.

Goshawks in proximity to work crews and vehicles during project implementation may be 

disturbed sufficiently to leave the immediate area, resulting in a minor energetic expenditure. All 

Northern goshawk nest sites located within the project area would be protected by a 1⁄4 mile LOP

during the breeding season from February 15 through September 15. This would minimize 

disturbance to breeding goshawks. There may be a disturbance to northern goshawk prey base 

during project implementation. Birds, squirrels, and other small animals may leave treatment 

areas for the short term period when lower canopy fuels are being removed. However, these 

animals should return to the area shortly after work is completed.

Pallid Bat: Bats roosting in proximity to a treatment unit could be disturbed by project activity. 

Noise from chainsaws, and the noise and vibration of skidders and log trucks is probably 

sufficient to disturb bats roosting in close proximity to the work activity. Suitable roosting and 

maternal cavity habitat may be affected in treatment areas where trees from 20” to 30” dbh may 

be harvested, since conifer trees in that size class may have suitable cavities for pallid bat roosts 

and maternal sites. As this project proposes to thin from below, a relatively small number of trees 

in that size class have been proposed for removal. Potential suitable habitat occurs across the 

majority of the project area, so it is possible that some suitable roost or maternal trees may be 

removed. Post-treatment foraging opportunities should be enhanced or not significantly changed 

because understory vegetation would be cleared in some areas and retained in others which would

provide a diversity of microhabitats for ground dwelling insect prey. 

American Marten: The project ranges from 4,000 to 7,000 feet in elevation, considerably 

limiting the potential impacts to martens which are most often found above 7,200 feet in 

elevation. At the far eastern edge of the project boundary there are approximately 330 acres, (3% 

of the project boundary) that are considered suitable marten habitat based on elevation and 

CWHR habitat typing. Mastication unit M-3 and tractor harvest/under burn units T12 and T11 are 

within suitable marten habitat. 

Status and trend monitoring for fisher and American marten was initiated in 2002 by the SNFPA 

carnivore monitoring program. The monitoring objective is to be able to detect a 20 percent 

decline in population abundance and habitat (USDA Forest Service 2006). From 2002 – 2008, 

439 sites were surveyed throughout the Sierra Nevada on 1,286 sampling occasions, with the bulk 

of the sampling effort occurring within the Southern Sierra fisher population monitoring study 

area (USDA Forest Service 2009). Sampling for this program occurs throughout late spring and 

into fall, with no sampling occurring during the winter months. There are nine sample stations 

located within a 3 mile radius of the project boundary. One of these stations are within the project

boundary and has not detected marten presence from 2000-2009. Of the remaining eight sample 

stations, seven have not detected marten to date during the SNFPA monitoring program and one 

station to the northeast of the project has occasionally detected marten. (USDA Forest Service 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 113 Chapter 3

2009). The nearest marten detection from the SNFPA carnivore monitoring program is over 1.5 

miles northeast from the project boundary (USDA Forest Service 2009).

More intensive camera sampling (concentrating primarily on locating Pacific fisher) has been 

conducted by the UC Berkeley fisher crew beginning fall 2007 throughout the project and the 

surrounding area. This sampling effort is active year-round. Cameras have detected marten 

activity in a few 1km2 grids adjacent to the project area. A 1km2 grid cell was considered to be 

marten active when a marten was detected at one or more camera stations within the grid cell 

(Rick Sweitzer, UC Berkeley SNAMP Fisher Study). There are 24 marten active grid cells 

within a 3 mile radius of the Project boundary. All detections occurred at or above the 6,000’ 

elevation level. The three marten active grid cells in the project boundary were all winter 

detections, well outside of the breeding season for American marten. 2 detections were made in 

March of 2009 and one detection was made in March of 2010. (Rick Sweitzer, unpublished 

SNAMP data). Much of the project area receives heavy volumes of snow throughout the winter, 

and no proposed vegetation management activities would occur in the winter months, limiting 

potential disturbance to marten. 

The Existing Vegetation GIS feature class was refined for the project using existing structure 

analysis from 292 stand examination plot data collected in 2011 throughout the project boundary, 

as well as forest aerial photography interpretation from the 2001 flight-line, and 1 meter 

resolution satellite imagery from the (NAIP). Plantation CWHR vegetation typing was refined 

through field verification as well as aerial photo interpretation by the district silviculturist. Based

on past experience with similar situations and professional judgment, the district silviculturist was 

able to estimate the anticipated changes to CWHR habitat throughout the treatment units based on 

the various stand prescriptions and proposed alternatives. Summary tables are shown below for 

the CWHR vegetation changes that are expected to occur through implementation of Alternatives 

2 and 3. 

Treatment acres relative to existing vegetation were based on mapping and field visits conducted 

by the district silviculturist. These field visits refined the base vegetation layer and determined 

the net acres of treatment. Table 14 displays the CWHR vegetation changes that are projected to 

occur with the implementation of Alternatives 2 and 3. None of the CWHR changes are projected

to take place within marten habitat.

Marten in proximity to work crews and vehicles during project implementation may be disturbed 

sufficiently to leave the immediate area or may miss a foraging opportunity, resulting in an 

energetic expense. However, this is unlikely as the entire project area lies below the primary 

elevational range of marten, and marten activity within the project area as detected by the 

SNAMP fisher crew appears to be confined to the winter months when no vegetation 

management activities would occur.

Habitat connectivity would be maintained throughout the implementation of all action 

alternatives by design criteria common to all alternatives including OFLs and areas where no 

treatments would occur. The inclusion of untreated areas along steep sloped regions and riparian 

corridors (primarily Willow Creek, Chilkoot Creek, and unnamed perennial tributaries) would

maintain habitat connectivity and marten dispersal routes. 

Marten habitat preferences and structure is similar to fisher habitat, though martens have a higher 

elevational range. Project design criteria, specifically for fisher habitat, would ensure that 

sufficient legacy structures (large trees with defects, large snags, and large downed logs) would 

remain after treatment and follow-up treatments to maintain habitat suitability for martens as 

well. An LOP from May 1 to July 31 would be applied to a 100-acre buffer around known 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 114 Chapter 3

marten den sites which would reduce potential disturbance to martens during the reproductive 

season. There are no currently known marten den sites within the project area.

The project proposes to maintain the highest canopy closure possible while still meeting fire and 

fuels objectives, and under alternative 2 managing for forest health and stand density as well. The 

prescriptions aim for a canopy closure of >50%, with a preference of greater than 60% 

immediately post treatment. All S&Gs from the SNF LRMP as amended by the SNFPA ROD 

2004 (USDA 2004b) would be followed in the implementation of this project. As this project 

proposes thinning from below, very few changes in CWHR habitat type are expected to occur 

throughout the entire Project area. Under the most aggressive Alternative (Alternative 2) 121

acres of CWHR habitat would experience a density type change spread across the treatment units. 

All changes to CWHR habitat would occur in units below 7,000 feet in elevation. No habitat that 

is currently suitable for denning would be reduced below suitable denning habitat. Habitat 

disturbance in the project area may lead to increased predation of marten by mountain lion, 

bobcat, or coyote. Habitat disturbance in the project area may also exacerbate individual marten 

mortality induced by disease. The degree of these potential effects are unknown, but may be 

illuminated through the SNAMP research.

Long-term positive effects of fuels treatments (due to the reduction of fire hazard) outweigh the 

short-term negative effects of fuel treatments (due to immediate loss of forest biomass) on 

marten, especially when assuming a more severe fire regime in the future. Habitat within the 

project treatment areas is expected to recover within 5-10 years post-treatment, and should reach 

current conditions within 15 years. Habitat recovery following a severe wildfire would take 

considerably longer—based on the silvicultural report prepared for this project an estimated 90-

110 years if brought back to conditions similar to the historical logging that occurred throughout 

the project area in the late 1800’s.

Cumulative Effects and Determinations

Potential Cumulative Effects by Species

The following is a cumulative effects assessment for terrestrial wildlife species considering past, 

present, and reasonably foreseeable activities. Additional details of the cumulative effects 

assessment can be found in the Terrestrial Wildlife.

Pacific Fisher

Our fuels reduction / forest restoration treatments provide net positive benefits to fisher habitat 

and populations by retaining and developing fisher habitat, while simultaneously creating forests 

that are more resilient to large-scale, severe wildfires and drought. This is especially important 

when considering that the historical fire return interval (prior to fire suppression) of fisher Sierra 

Mixed-Conifer Forest habitat was an average of 7-12 years. Therefore, without periodic fuels 

reduction, these forests will become highly susceptible to large-scale, high-severity wildfire, and 

these types of fires are uncharacteristic compared to the historical low-severity fires. Such highseverity fires can significantly reduce mature and older aged forests, which are crucial for 

sustaining fisher and spotted owl populations. This management approach of reducing wildfire 

risk while also retaining fisher habitat has been shown to be an effective means for conserving 

fisher over the long-term (Spencer et al. 2008 and Scheller et al. 2011).

Our treatments often include individual tree thinning management (not clear-cutting) based on an 

ecosystem management approach that retains forest structure and biological integrity (An 

Ecosystem Management Strategy for Sierran Mixed-Conifer Forests (North et al. 2009)). These 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 115 Chapter 3

treatments have been designed to retain and develop habitat characteristics that are important for 

fisher, such as: (1) retaining a majority of the large live trees greater than 20 inches dbh; (2) all 

large snags greater than 15 inches dbh, unless they are a safety hazard; (3) all oaks; (4) retaining 

large portions of the project areas with high canopy cover; (5) implementing Limited Operating 

Periods (LOPs) during the breeding season that minimize the potential for direct impacts to 

fisher; and (6) retaining many other important habitat features, such as trees with cavities, large 

woody debris, understory shrubs, and riparian conservation zones. 

Our project-level and multi-scale cumulative assessment of the effect of our treatments on fisher 

habitat shows that these projects will not have a significant impact to fisher habitat or fisher 

populations. Rather, these carefully designed and professionally implemented treatments will help 

sustain habitat for this species. Specifically, during the 5 year period from 2007 through 2011, the 

Sierra National Forest has implemented, or is proposing to implement, fuels reduction / forest 

restoration treatments on approximately 3.8% of the total fisher habitat on Sierra National Forest 

(refer to details following this narrative). The percentage decreases to 3.7% when we only 

consider treatments in habitat defined as having ≥40% fisher probability of occurrence. These are 

reasonable and sustainable rates, yet they fall short of the rates of treatment recommended by the 

Conservation Biology Institute (CBI) for significantly reducing fire sizes and fire severity, which 

is necessary to help sustain fisher habitat. In their comprehensive report entitled: Baseline 

Assessment of Fisher Habitat and Population Status & Effects of Fires and Fuels Management on 

Fishers in the Southern Sierra Nevada (Spencer et al., 2008), the CBI states (pg. 98): 

“Our simulations suggest that treatment rates on the order of 4% to 8% of treatable area every 5 

years can significantly reduce fire sizes and fire severity and thereby benefit fishers.” (Spencer et 

al., 2008).

The CBI report (pg. 99) goes on to state:

“Our simulation results suggest that placing treatments inside fisher habitat is not necessarily 

detrimental to fisher (at least for the limited range or treatment types and at the scale we 

simulated). The positive indirect effect of treatments in reducing fire size and severity can help 

protect fisher habitat value despite potential short-term, localized, negative effects on fisher. 

Because treatment effects on fire spread are relatively local, treatments inside landscape-level 

fisher habitat (areas of large tree biomass) may better protect fisher habitat than those placed 

outside fisher habitat (at least under the baseline fire regime). However, treatments in high 

biomass areas should still strive to maintain sufficient overstory canopy and avoid removing 

fisher habitat elements, such as large old trees that provide resting structures.” (Spencer et al., 

2008) [emphasis added]

Our rates of treatment within fisher habitat are slightly higher when we analyze the northern half 

of the Sierra National Forest and focus solely on the Bass Lake Ranger District, yet those rates 

are still within the CBI recommended rates of 4%-8%. Specifically, we are implementing, or are 

proposing to implement, fuels reduction / forest restoration treatments on approximately 6.0% of 

the total fisher habitat on the Bass Lake Ranger District (refer to details following this narrative). 

The percentage increases to 7.6% of treated habitat when we only consider treatments in habitat 

defined as having ≥40% fisher probability of occurrence. These are reasonable and sustainable 

rates that comply with the CBI recommendations, particularly when considering that these 

percentages are higher than what would actually occur if we only included projects implemented, 

rather than just approved with a NEPA decision, between 2007-2012. The proposed Grey’s 

Mountain Ecological Restoration treatments are projected to be implemented beginning in 2013, 

which is a 6 year period from 2007-2013. Regardless, the current and projected rate of fuels 

reduction / forest restoration treatments on the Bass Lake Ranger District, including the Grey’s 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 116 Chapter 3

Mtn. Project, as well as for the entire Sierra National Forest is reasonable and necessary to sustain 

fisher habitat from the increasing threat of uncharacteristically severe wildfire. 

Assessment of Forest Restoration Treatments in 

Fisher Habitat on the Sierra National Forest.

Treatments in Fisher Habitat on the Sierra National Forest

1. The Sierra National Forest has 336,525 acres of fisher habitat, defined as CWHR 2.1 

fisher habitat between 3,000 and 8,000 ft. elevation. Of that total, 3.8% (12,903 acres) is 

within areas treated or proposed to be treated for fuels reduction and forest restoration 

since 2006a

, including the proposed Grey’s Mtn. Restoration Project. Two additional 

restoration projects proposed for 2013 (Soaproot and Whisky Ridge Restoration) do not 

have finalized treatment boundaries at this time, however, if we assume the treated fisher 

habitat in Soaproot will be 2,261 acres and the Whisky Ridge treated habitat will be 

2,500 acres (for a total of 17,664 acres since 2006), this would result in only 5.2% of 

suitable fisher habitat on the Sierra NF receiving treatment or proposed to be treated since 

2006.

2. A total of 300,501 acres (89%) of the total 336,525 acres of Sierra NF fisher habitat is 

defined as having ≥40% fisher probability by the Conservation Biology Institute (Spencer 

et al., 2008). Only 3.7% (11,182 acres) of that habitat has been treated or is proposed to 

be treated with projects since 2006a

. That percentage increases to 4.9% (14,841 acres) if 

we also include the habitat defined as having >40% fisher probability that may be treated 

for the proposed 2013 Soaproot Project (2,261 acres) the proposed 2013 Whisky Ridge 

Project (2,000 acres). 

3. These are reasonable and sustainable rates that are correspond with the CBI 

recommendations (treating 4-8% of the treatable landscape every 5 years), especially 

when considering that the percentage of treatment would be lower if only calculated for 

5 year rolling periods (i.e., between 2007-2011, 2008-2012, or 2009-2013). 

 

a Projects since 2006 in Sierra National Forest: Sonny Meadows N&S; Cedar Valley; Sugar 

Pine; Fish Camp; Dinkey N; Dinkey S; KREW; and Grey’s Mtn. 

Treatments in Fisher Habitat in the Bass Lake District

1. The Bass Lake Ranger District has 156,935 acres of fisher habitat, defined as CWHR 2.1 

fisher habitat between 3,000 and 8,000 ft. elevation. Of that total, 6.0% (9,395 acres) is 

within areas treated for fuels reduction and forest restoration since 2006b

, including the 

proposed Grey’s Mtn. Restoration Project. That percentage increases to 7.6% (11,895 

acres) when we add the estimated 2,500 acres of fisher habitat that may be treated for the 

2013 Whisky Ridge Restoration project.

2. A total of 129,933 acres (83%) of the total 156,935 acres of fisher habitat in the Bass 

Lake District is defined as having ≥40% fisher probability of occurrence by the 

Conservation Biology Institute (Spencer et al., 2008). Only 5.7% (7,422 acres) of that 

habitat has been treated or is proposed to be treated with fuels reduction/forest restoration 
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projects since 2006b. That percentage increases to 7.3% (9,422 acres) if we include the 

estimated 2,000 acres with >40% probability that may be treated for the 2013 Whisky 

Ridge project. 

3. These are reasonable and sustainable rates that correspond with the CBI 

recommendations (treating 4-8% of the treatable landscape every 5 years), especially 

when considering that the percentage of treatment would be lower if only calculated for 

5 year rolling periods (i.e., between 2007-2011, 2008-2012, or 2009-2013). 

b Projects since 2006 on the Bass Lake Ranger District: Sonny Meadows N&S; Cedar Valley; 

Sugar Pine; Fish Camp; and Grey’s Mtn. (proposed). 

Assessment Area: For this cumulative effects analysis of past, present, and reasonably 

foreseeable activities on the fisher we will use three levels of analysis. The first assessment level 

is at the multiple home range scale. 95% use contours were provided by SNAMP fisher team for 

all male and female fishers whose home ranges overlapped or were adjacent to the Grey’s 

Mountain project boundary. A total of 12 fishers throughout populations years one through four 

have home ranges that meet these criteria. Analyzing current conditions and vegetation 

management within those home ranges will show any potential cumulative effects to individual 

male and female fishers surrounding the Grey’s Mountain project area.

The second level of assessment for cumulative effects encompasses all suitable fisher habitat on 

the BLRD ranging from 3,500 to 8,000 feet in elevation. This boundary represents the portion of 

the Southern Sierra Fisher Conservation Area (SSFCA) that is present on the Bass Lake RD and 

equates to approximately 156,935 acres, or approximately 35 adult female fisher home ranges. 

This boundary is consistent with the genetic data reported by Tucker et al. (2009) which used the 

program “Geneland” to assign genetic subpopulations within the larger SSFCA encompassing the 

Sierra and Sequoia National Forests. Through analysis of genotypes three distinct 

“subpopulations” emerged: (1) the North population which encompasses most of the BLRD

including the Chowchilla Mountains and Shuteye area, (2) the Central population which 

encompasses a small eastern portion of the BLRD, the entire High Sierra Ranger District of the 

SNF, and the northern portion of the Sequoia NF, and (3) the South subpopulation which 

encompasses the Southern Sequoia NF and Kern Plateau (Tucker et al. 2009). Therefore, this 

second level boundary of assessment for cumulative effects for the Greys Mountain Project

encompasses 100% of the North subpopulation and around 10% of the Central subpopulation 

nearest to the San Joaquin River. This should show any potential cumulative effects to the North 

subpopulation.

The third and final level of assessment is at the range of the entire SSFCA. The SSFCA 

encompasses the known occupied range of the Pacific fisher in the Sierra Nevada and measures 

1,018,000 acres. We would tie all three assessment levels together and show any potential 

cumulative effects to the Southern Sierra fisher population as a whole. 

Greys Mountain Project: As discussed in the direct and indirect effects section, the most 

aggressive management action alternative (Alternative 2) of the project would have minimal 

effects to fisher habitat (CWHR 2.1 habitat). Specifically, all action alternatives would retain a 

high degree of overstory forest canopy cover (>50% with a preference of greater than 60%, when 

conditions allow); all trees >30 inches dbh, and all snags, would be retained during mechanized 

treatments, except where they pose an immediate safety hazard. Trees >20 inches dbh would be 

retained, in adequate quantity, to help assure availability of resting and denning structures now 
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and into the future. Black oaks also would be retained, as well as large tree groups. The project 

would not impede movement or dispersal to other currently connected suitable habitat areas 

because habitat connectivity would be maintained within and adjoining the project area. And no 

treatments would occur throughout suitable fisher habitat during their breeding season (refer to 

the effects analysis of the BE/BA (USDA Forest Service, 2011b).

All action alternatives also may result in long-term positive effects to the fisher by: 1) reducing 

the potential for catastrophic, stand eliminating wildfires; and 2) promoting the growth and regrowth of understory vegetation, which provides forage for prey species, as well as hiding and 

thermal cover. The horizontal and vertical diversity of forest vegetation structure and species

also may be improved in some sites as a result of partially opening the forest overstory, 

particularly with Alternative 2. This in-turn would bring greater biodiversity into the stands, 

promoting greater prey species abundance and diversity, including promoting the establishment 

and improved growing conditions of black oaks, which are important components of fisher 

habitat. All of these factors combined outweigh the short-term negative effects of treatments (due 

to immediate partial loss of forest biomass and disturbance), especially considering that a more 

severe fire regime is predicted for the future, and without fuels reduction, large scale, stand 

replacing wildfires would most likely cause serious and significant impacts to the population. 

Other Current and Future Land Management Projects on the Bass Lake RD: Currently 

there are four land management projects on the Bass Lake District that are of the size that could 

influence the cumulative effects on fisher habitat. Thinning treatments have been completed for 

three of the four projects, including: Sonny Meadows North (with 955 acres of treatments), Sonny 

Meadows South (with 1,400 or more acres of commercial thinning), and Rush Creek 

(approximately 500 acres of commercial thinning). Post-harvest follow-up treatments are still in 

the implementation phase for these three projects. It was determined that treatments for Sonny

Meadows North, South, and Rush Creek would not result in loss of suitable habitat, although 

temporary, activity-related disturbances were expected within proximity of management 

activities. Overall habitat suitability would increase over the long term as a result of the 

completed treatments, and these projects would not increase habitat fragmentation since postharvest habitat would remain suitable.

The Cedar Valley Project (approximately 915 acres of commercial thinning) is nearing the end of 

the implementation phase. It was determined that the Cedar Valley Project may result in a shortterm reduction of denning habitat quality on approximately 628 acres. However, this habitat 

would remain suitable as foraging habitat, and is expected to recover within 10-15 years to higher 

quality fisher habitat. The Cedar Valley Project would not impede movement or dispersal to 

other currently connected suitable habitat areas. 

There is also one reasonably foreseeable project; Fish Camp Project, (with approximately 1200

acres of treatments). The Fish Camp project has been analyzed in NEPA under the Fish Camp 

Environmental Impact Statement with the Record of Decision being completed in 2011, This 

project would incorporates provisions similar to those proposed for Greys Mountain for fisher 

conservation. Treatments within this project could begin in 2012.

Timing of Vegetation Management Projects on the Bass Lake RD: It is expected that 

implementation of the Sugar Pine Project will be completed before any ground operations occur 

on the project. This is due to the fact that the Sugar Pine project is part of the SNAMP, and is 

therefore restricted by the time limitations of research being conducted as a part of the on-going 

research for SNAMP. Treatments for the Sugar Pine Project are expected to commence in the 

summer of 2011 and would be completed under a service contract that would last approximately 
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2 years. A LOP from March 1 through June 30 is being implemented for all suitable Pacific fisher 

denning habitat within the Sugar Pine Project.

Commercial thinning treatments in Sonny Meadows North and South, and Rush Creek have been 

completed. Some follow-up mastication and prescribed burning would be conducted over the next 

few years. Commercial thinning treatments in Cedar Valley are nearing completion, and are 

projected to be completed before project implementation begins. Some follow up mastication and 

prescribed burning activities would occur over the next few years throughout the Cedar Valley 

units. The few remaining Cedar Valley commercial thinning treatment areas are likely to be 

conducted concurrently with the Sugar Pine treatments. Since treatment units occur throughout a 

total of 25-35% of the project boundary area for all vegetation management projects on the 

BLRD, and few of these projects are occurring simultaneously, fishers should retain movement 

capabilities throughout all suitable habitat areas. The BE/BA (USDA Forest Service 2011b)

shows the past, present, and reasonably foreseeable actions on the BLRD. District-wide, less than 

4% of fisher habitat is within a present vegetation management project boundary. 

Provided the vegetation management projects on the BLRD have habitat management goals 

which include retention and promotion of large trees and oaks, as well as project design criteria 

promoting stand heterogeneity as well as retention of snags, large tree groups, decadent/cavitary 

trees, down woody debris, and understory trees/shrubs, it is unlikely that the cumulative effects of 

the vegetation management projects, considered with all past, present, ongoing, and reasonably 

foreseeable activities on the BLRD would have an effect on the North population of Pacific 

fishers within the Southern Sierra.

Additional Vegetation Management Projects within the SSFCA

High Sierra Ranger District, Sierra NF: The effects of implementing the Kings River 

Experimental Watersheds (KREW) Project on fisher were evaluated in the 2008 Kings River 

Project Biological Evaluation/Assessment for the Pacific Fisher (USDA Forest Service 2008b). 

The effects of the Dinkey North project on fisher were evaluated concurrently with the Dinkey 

South Project. The KREW Project – Providence unit is just northeast of the boundary of the 

Dinkey South Project area and is projected to result in no more than a 6% loss of fisher habitat 

within its boundaries immediately after project implementation. The KREW Project – Bull unit is 

approximately 6 miles southeast of the Dinkey South Project area and is projected to result in less 

than a 1% loss in suitable fisher habitat within its boundaries immediately after that project is

implemented. The Dinkey North Project borders the Dinkey South Project area to the north and is 

projected to result in a 1% loss in suitable fisher habitat within its boundaries immediately after 

project implementation. All of these projects are predicted to ultimately result in an increase of 

the quality and amount of fisher habitat within project boundaries over the long term.

Stanislaus and Sequoia National Forests: Projects on the Stanislaus National Forest are not 

expected to result in a change in CWHR size class and cover type, though there would be a 15% 

reduction in canopy. The predicted habitat value for fisher would remain at 4M on these projects. 

Projects on the Sequoia National Forest are also not expected to result in a change in CWHR size 

class and cover type though would result in a loss of habitat. The current projections are that there 

would be a 10 to 20% reduction in suitable fisher habitat for these projects combined. Currently 

there is approximately 2,344 acres of suitable fisher habitat identified within in these project 

areas, so the reductions would be between 234 and 469 acres.

While present and reasonably foreseeable vegetation treatments occurring or proposed on the 

Sierra, Stanislaus, and Sequoia National Forests would result in temporary reductions to fisher 
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habitat suitability, these effects are relatively small, with changes calculated to occur across 

approximately 3% of the SSFCA. 

Suitable fisher habitat on the SNF has increased slightly from 422,000 acres about ten years ago 

to 449,000 acres in recent years (USDA Forest Service 2006b). Rick Truex, a USDA Forest 

Service fisher scientist believes fishers may have increased their spatial distribution on the SNF

since the mid-1990s, and that the annual occupancy rate within SNF seems to be consistent, 

though the spatial pattern of detections appears more variable among years than on the Sequoia 

National Forest (Truex pers. comm.). The combination of a stable or slightly increasing amount 

of suitable fisher habitat on the SNF over the last ten years and perhaps an increasing spatial 

distribution of fishers make it reasonable to conclude the cumulative effects of vegetation 

management activities on the SNF have not reduced overall habitat suitability for fishers on the 

Forest. 

Additionally, recent scientific information presented in 2011 at The Western Section of the 

Wildlife Society meeting indicates that the fisher population on the Sierra National Forest is 

stable to increasing. Values of lambda (λ) greater than 1 indicate that a population is increasing, 

while λ values less than 1 indicate that a population is decreasing. Calculated values for λ were 

presented for fisher populations within the SNAMP study area (λ 1.04) on the Bass Lake Ranger 

District, and the Kings River Fisher Project area (λ 1.2) on the High Sierra Ranger District 

(Sweitzer et al. 2011). Based on this data, fisher populations on both districts of the Sierra 

National forest are increasing, although the population growth rate is slightly lower within the 

SNAMP study area as compared to the Kings River area. This is likely due to the bisection of the 

SNAMP study area by Highway 41, a major travel corridor through Sierra National Forest and 

Yosemite National Park. Over 21% of the SNAMP recorded fisher mortalities are road kill events 

on Highway 41 (3 on SNF and 5 in YNP). The Kings River fisher study has only recorded 1 road 

related fisher fatality out of 27 total mortalities (4%). A Wildlife Vehicle Collision (WVC) 

working group has been formed as a subcommittee of the Southern Sierra Nevada Fisher 

Working Group (SSNFWG) and is tasked with finding a solution to the Highway 41 issue. 

Currently, the SNAMP fisher team is monitoring 45 individual fishers across the Bass Lake 

Ranger District, the highest number of individuals the project has had at any time since the study 

began in 2007 (Rick Sweitzer, personal communication, March 2012).

The information listed above is in alignment with the findings from the (USFWS). Their annual 

review of native species that are candidates for listing as endangered or threatened (Federal 

Register: Vol. 72: 69034-69105), reemphasized that the three remaining areas containing fisher 

populations, including the southern Sierra Nevada, “appear to be stable or not rapidly declining 

based on recent survey and monitoring efforts”. This follows with data presented by Jody Tucker 

at the Western Section TWS fisher symposium in 2012, which displayed results from the 

Southern Sierra Nevada Carnivore Monitoring Program indicating the occupancy status of the 

southern Sierra Nevada fisher population from 2002-2009 was stable. (Tucker, 2012; Zielinski et 

al, In Review)

In addition, the California Department of Fish and Game (CDFG) in their Evaluation of Petition: 

Request of the Center for Biological Diversity to list the Pacific fisher (CDFG 2008) found that 

the information provided, and was evaluated by the CDFG did not indicate an immediate or 

substantial change in either population or distribution of fishers since the selected benchmark 

analysis period beginning with the assessment provided by Grinnell et al. (1937). Based on this 

information, the CDFG finds that the fisher has sustained itself since the Grinnell period, with no 

evidence of recent, immediate, or significant change in population or distribution, despite a 

decline in late successional forest. Available information suggests this may be the case for a 

number of reasons. Recent studies of fisher habitat use, occurrence, and movement patterns 
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indicate fishers also use managed forest habitats of mixed tree age structure and canopy closure, 

which have essential attributes such as snag/large tree attributes remaining for resting/denning. 

Fishers are no longer subject to the significant mortality factors of trapping and poisoning of prey 

that were common in past decades. Forest management in California has been trending toward 

more retention of late successional stands and this change in management activity likely has been, 

and would be, beneficial to species such as the fisher in the future.

Based on the above analysis of potential impacts within the project area and in consideration of 

other past, present, ongoing and reasonably foreseeable actions from within the range of the 

Southern Sierra fisher population and timing of the implementation of such projects, it was 

determined that implementing either the proposed action (alternative 2) or alternative 3 of the 

project would not contribute to significant cumulative effects to Pacific fisher or their habitat. 

This determination is supported by recent findings published by both the USFWS and the State of 

California with regard to fisher population viability and habitat sustainability.

It is my determination that Alternative 1 (the no action alternative) for the Greys Mountain 

Ecological Restoration project would not affect the Pacific fisher as a result of vegetation 

treatments, as none would occur under alternative 1. However, by taking no action to reduce fuel 

levels, the threat of large scale stand replacing fires would remain unabated, and if such an event 

occurs, there could be significant detrimental impacts to this species.

It is my determination that alternatives 2-3 (the action alternatives) of the Greys Mountain 

Ecological Restoration project may affect individuals, but is not likely to result in a trend toward 

Federal listing or loss of viability for the Pacific fisher. Suitable fisher habitat occurs in and near 

the project area, and the proposed actions would not result in significant reductions of that habitat 

(CWHR 2.1 habitat) at the project level, unit level, female home range level, or at the regional 

level for the Southern Sierra Fisher Conservation Area. Sufficient levels of large live trees 

≥20”dbh, and large snags ≥16”dbh that provide potential den and rest sites, would be maintained, 

even under the most aggressive action alternative. This project does not propose to remove any 

oaks, and measures would be implemented to protect black oaks. Understory vegetation would be 

retained in clumps throughout treatment units to maintain heterogeneity of the stand and habitat. 

A few fishers may be disturbed by project activities, although this only would be for the shortterm duration of those actions. Most importantly, management actions, throughout all suitable 

fisher habitat would not occur during the fisher breeding season because a LOP (March 15 – June 

15) would be implemented. The project would not impede movement or dispersal to other 

currently connected suitable habitat areas because habitat connectivity would be maintained 

within and adjoining the project area. 

Silvicultural prescriptions would maintain canopy cover of at least 50%, with a preference for at 

least 60%, immediately post treatment, and these prescriptions focus on removing surface and 

ladder fuels, and thinning from below. There would be very few changes to habitat types as a 

result of this management. Large trees (30”dbh and above), and all snags, would be retained 

during mechanized treatments, except where they pose an immediate safety hazard. The project 

would not impede movement or dispersal to other currently connected suitable habitat areas 

because habitat connectivity would be maintained within and adjoining the project area. 

All action alternatives also may result in long-term positive effects to the fisher by: 1) reducing 

the potential for uncharacteristically severe, stand eliminating wildfires; and 2) promoting the 

growth and re-growth of understory vegetation, which provides forage for prey species, as well as 

hiding and thermal cover. The horizontal and vertical diversity of forest vegetation structure and 

species also may be improved in some sites as a result of partially opening the forest overstory, 

particularly with Alternative 2 and 3. This in-turn would bring greater biodiversity into the 
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stands, promoting greater prey species abundance and diversity, including promoting 

establishment and improved growing conditions of black oaks, which are important components 

of fisher habitat. All of these factors combined outweigh the short-term negative effects of 

treatments (due to immediate partial loss of forest biomass and disturbance), especially 

considering that a more severe fire regime is predicted for the future, and without fuels reduction, 

large scale, stand replacing wildfires would most likely cause serious and significant impacts to 

the population.

California Spotted Owl

The California spotted owl has a continuous distribution throughout the Sierra Nevada with a 

network of 234 managed HRCAs (600 acres each) on the Sierra National Forest. Given the scope 

and scale of the project relative to the size of the Sierra National Forest and the Sierra Nevada; 

the area considered in determining the cumulative effects of past, present, and reasonably 

foreseeable activities on the California spotted owl would focus on the SNF. A determination of 

viability for the California spotted owl would be made based on the following analysis.

Since about the mid 1960s, past activities have included clearcutting and salvage logging (1960s 

to 1972), sanitation and salvage harvests (1972 through 1978), clearcutting, shelterwood cutting, 

and salvage harvests (1978 through 1992), and commercial thinning from below and salvage in 

recent times. The only fires to burn substantial amounts of timber were the Rock Fire in 1981, the 

Big Creek Fire in 1995 and the North Fork Fire in 2001, with each fire burning about 3000 acres 

of forest. Clearcuts or burned areas that took place prior to 1972 are typically successful 

plantations today, exhibiting size class 3 and density class M stands. Other, more recent 

disturbances, while they may be reforested have probably not yet reached size class 3.

In its 12-month finding in which it decided to not list the California spotted owl as Threatened or 

Endangered, the USFWS concluded that the scale, magnitude, or intensity of effects on the 

California Spotted Owl resulting from fire, fuels treatments, timber harvest, and other activities 

did not rise above the threshold necessitating protection of the species under the Endangered 

Species Act (ESA) (USDI, 2006). The USFWS reached this conclusion after considering the 

impacts of the Forest Service’s implementation of the SNF LRMP as amended by the SNFPA 

ROD (USDA 2004b). The USFWS’ (USDI, 2006) conclusion is supported by:

 “Data which indicate that California spotted owl populations in the Sierra Nevada are 

stable and comprise 81% of the species’ known territories

 The anticipation that current and planned fuels-reduction activities throughout the 

range of the species would have a long-term benefit by reducing the risk of stand 

replacing wildfire; these activities embrace those described by the SNF LRMP as 

amended by the SNFPA ROD. 

 Protection measures are being implemented for the California Spotted Owl on private 

lands, including the largest private landholders within the range of the species”

More recent results from the ongoing demography studies indicate potential declines in the 

Lassen study area (Keane et al. 2010), which lies over 200 miles north of the Sierra National 

Forest, and the El Dorado study area, which lies over 100 miles north of the Sierra National 

Forest (Gutierrez et al. 2011). 

The estimated mean lambda for the Lassen Demographic Study between 1990-2010 was 0.979 

(SE = 0.0097), with 95% confidence limits ranging from 0.959-0.999 (Scherer et al 2010). There 

was no evidence of linear, quadratic or pseudo-threshold trends in lambda, rather the means 
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model was strongly supported by the data. These results suggest a decline in the CSO population 

within the Lassen study area over the 20-year study period. Annual lambda estimates from the 

best model ranged between 0.87-1.13. Estimates of realized population change based on the time 

series of lambda estimates generated from our modeling suggests that there have been declines in 

the number of territory holding CSOs within the study area (Keane et al. 2010).

It is unknown at this time what factors may be causing a decline in the Lassen California Spotted 

Owl population, although forest treatments and high severity wildfire may both be contributing 

factors. Although the study results suggest a slight decline in the Lassen study area CSO 

population, it is important to note that adult CSO survivorship is still a lambda near 1 within the 

95% confidence interval. A lambda (λ) of 1 indicates a stable population. 

Gutiérrez et al presented their most recent findings in March 2011 regarding CSO populations on 

the El Dorado National Forest: 

The random-effects means model suggested that the average λ over the study period was not 

significantly different than one, the value for a stable population (λt = 0.989, SE = 0.016). 

Estimates of realized population change (which show the proportion of the initial population size 

remaining each year) also suggested that the number of territorial owls in 2009 was similar to that 

at the beginning of the study. (Gutierrez et al. 2011). The finite rate of population change that we 

estimated using mark-recapture data from the Eldorado Density Study Area indicated that the 

population size has been stable since the beginning of the study, although we have observed a 

gradual decline in the realized population change over the last 10 years (Figure 5). This suggests 

that continued monitoring will be needed to assess whether a long-term population decline is 

underway. (Gutiérrez et al. 2011).

Recent results from the demography study sites on and adjacent to the Sierra National Forest 

indicate locally stable California spotted owl populations (Munton et al. 2011). Estimated mean λt 

for the Sierra (SIE) site is 0.989, with 95% confidence intervals ranging from 1.007-0.971 (Table 

11, Munton et al. 2011). This average λ is not significantly different than one, which is the value 

for a stable population. Values for mean λt at the conifer study site in Sequoia National Park 

(SKC) were above 1.0 (Munton et al. 2011) which indicates an increasing population.

At a forest-wide scale, there currently are 234 designated HRCAs/PACs which encompass 

146,760 acres. Approximately 468,861 acres of suitable habitat currently exist on the Forest. 

Considering the proposed treatment activities of the project, along with other ongoing actions, 

and reasonably foreseeable activities, less than one percent of suitable habitat on the Sierra 

National Forest would be affected. Because the alternatives put forth in this project would

increase forest stand structure and heterogeneity, and retain high canopy cover, along with the 

project’s goal of increasing large diameter trees would result in long-term increases in California 

spotted owl suitable habitat over time; along with the relatively stable geographic distribution and 

population levels of spotted owls in the local area, the cumulative effects of vegetation 

management activities in the Greys Mountain and Sugar Pine treatment units taken together with 

all other past, present, and reasonably foreseeable activities on the Forest would not result in a 

loss of viability for the California spotted owl.

It is my determination that Alternative 1 (the no action alternative) for the Greys Mountain 

Ecological Restoration Project would not affect the California spotted owl. This is due to the fact 

that no vegetation treatments would occur under Alternative 1. However, by taking no action to 

reduce fuel levels, the threat of large scale stand replacing fires would remain unabated, and if 

such an event occurs, there could be significant detrimental impacts to California spotted owl 

habitat in and near the project area.
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It is my determination that Alternatives 2-3 (the action alternatives) of the Greys Mountain 

Ecological Restoration Project may affect individuals, but is not likely to result in a trend toward 

Federal listing or loss of viability for the California spotted owl. Spotted owls are known to 

occur in and near the project area, and a few owls may be disturbed by project activities, although 

this would only be for the short-term duration of those actions, and no management activities 

would occur during their breeding period (March 1-August 15), within 1⁄4 mile of spotted owl 

activity centers or nest site centers. The project also may reduce some prey species over the 

short-term, however, other prey species would be available to sustain the owls within their home 

ranges, and prey species are expected to recover and possibly increase over the long-term as a 

result of increased understory growth and re-growth. 

Silvicultural prescriptions within California spotted owl PACs would maintain >60% canopy 

closure where available and within spotted owl HRCAs would aim to maintain >50% canopy 

closure where available. Silvicultural prescriptions outside of Spotted Owl PAC/HRCAs would

maintain canopy cover of at least 50%, with a preference for at least 60%, immediately post 

treatment, and these prescriptions focus on removing surface and ladder fuels, and thinning from 

below. There would be very few changes to habitat types as a result of this management. Large 

trees (30”dbh and above), and all snags, would be retained during mechanized treatments, except 

where they pose an immediate safety hazard. The project would not impede movement or 

dispersal to other currently connected suitable habitat areas because habitat connectivity would be 

maintained within and adjoining the project area through OFLs and non-treated areas. 

All action alternatives also may result in long-term positive effects to the California spotted owl 

by: 1) reducing the potential for uncharacteristically severe, stand eliminating wildfires; and 2) 

promoting the growth and re-growth of understory vegetation, which provides forage for prey 

species, as well as hiding and thermal cover. The horizontal and vertical diversity of forest 

vegetation structure and species also may be improved in some sites as a result of partially 

opening the forest overstory, particularly with Alternative 2. This in-turn would bring greater 

biodiversity into the stands, promoting greater prey species abundance and diversity, including 

promoting establishment and improved growing conditions of black oaks, which are important 

components of California spotted owl habitat. All of these factors combined outweigh the shortterm negative effects of treatments (due to immediate partial loss of forest biomass and 

disturbance), especially considering that a more severe fire regime is predicted for the future, and 

without fuels reduction, large scale, stand replacing wildfires would most likely cause serious and 

significant impacts to the population.

 Great Gray Owl

Because the alternatives put forth in this project would not have a measurable effect to CWHR

nesting and foraging habitat for great gray owl, and both action alternatives are projected to result 

in long-term increases in great gray owl suitable nesting habitat over time due to the project’s 

goal of increasing large diameter trees and removing ladder fuels, the cumulative effects of 

vegetation management activities in the project treatment units taken together with past, present, 

and reasonably foreseeable activities on the Forest would not result in a loss of viability for the 

great gray owl. Therefore cumulative effects to the great gray owl through the implementation of 

Alternatives 2 or 3 of the project are expected to be so minimal as to be nearly undetectable.

It is my determination that Alternative 1 (the no action alternative) for the Greys Mountain 

Ecological Restoration Project would not affect the Great gray owl. This is due to the fact that no 

vegetation treatments would occur under Alternative 1. However, by taking no action to reduce 
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fuel levels, the threat of large scale stand replacing fires would remain unabated, and if such an 

event occurs, there could be significant detrimental impacts to this species.

It is my determination that Alternatives 2-3 (all of the action alternatives) for the Greys Mountain 

Ecological Restoration Project may affect individuals, but is not likely to result in a trend toward 

Federal listing or loss of viability for the great gray owl. Great grey owls have not been found in 

the project area and only marginal great gray owl foraging habitat occurs within the project 

boundary and adjacent areas. One great grey owl PAC is located north of the project boundary, 

therefore, there is a potential that one or a few individuals may be disturbed by project activity. 

However, no measurable reductions to great grey owl habitat are expected, and potential 

disturbances would be limited to the period of management activity. A LOP from March 1 

through August 15 would protect any nest sites that are discovered within 1⁄4 mile of vegetation 

management activities. Large trees (30”dbh and above), and all snags, would be retained during 

mechanized treatments, except where they pose an immediate safety hazard. The project would

not impede movement or dispersal to other currently connected suitable habitat areas because 

habitat connectivity would be maintained within and adjoining the project area through OFLs and 

non-treated areas.

Northern Goshawk 

The northern goshawk has a continuous distribution throughout the Sierra Nevada with a network 

of 57 managed territories on the SNF. Habitat for the northern goshawk has increased over the 

past decade from 382,000 acres in 1995 to 405,000 acres in 2005. Currently there are 405,000 

acres of suitable northern goshawk habitat in the 4,000 to 8,000’ elevation range on the SNF, with 

less than 1% of the suitable habitat occurring in the project boundary. Given the scope and scale 

of the project relative to the size of the Sierra Nevada and the goshawk’s overall North American 

distribution, the area considered in determining the cumulative effects of past, present, and 

reasonably foreseeable activities on the northern goshawk would focus on the SNF. A 

determination of viability for the northern goshawk was made based on the following analysis.

All goshawk nest sites within the project area would be protected by an LOP. Outside of the 

LOP, portions of the three goshawk PACs would be thinned to the degree allowed under the 

SNFPA ROD (USDA 2004b). The PAC would not be reduced to less than 60% canopy cover, 

where available; therefore, would not be diminished to less than nesting habitat. All snags would

be retained during project implementation except in those cases where they pose a hazard.

BEs for many of the past projects in the SNF were reviewed to help inform the present analysis. 

Review of these documents revealed the following basic information about effects to northern 

goshawks from these activities:

 26 total project BEs were reviewed, dating back to 1993 on the SNF.

 Determinations reached were:

o No effect – four BEs

o May affect individual goshawks, but not likely to lead to a trend toward 

federal listing or loss of viability – 20 BEs

o May affect individual goshawks, and likely to lead to a trend toward federal 

listing or loss of viability – 0 BEs

o Northern goshawk was not addressed in the document we reviewed due to 

lack of habitat or other reasons – two BEs

 Types of Projects: Fuels reduction, harvest, hazard tree removal, thinning, and 

underburning were the proposed activities that were most often represented in the 

sample of BEs in which the northern goshawk was analyzed.
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 Relative to “May Affect” projects, the described impacts to northern goshawks most 

often fell in the following categories:

o Noise disturbances

o Loss of foraging area if underburn gets out of control

o Loss of plucking trees

o Habitat quality reduction

As with other species, the SNFPA FEIS (USDA-FS 2001) provided our analysis of northern 

goshawks with useful historical and habitat information. Evidence suggests the number of 

goshawk breeding territories (ranging from 12 reported in the SNFPA (USDA-FS 2001) to the 57 

such territories known to exist today) has increased since some of the earliest data was reported in 

Grinnell and Miller (1944 – as cited in USDA-FS (2001)). This is evidenced by the fact that 

there has been no apparent change in the geographic distribution of northern goshawks in the 

Sierra Nevada since then. Thus, goshawk numbers in the SNF remain fairly stable. Reasons for 

this, as put forth by the SNFPA (USDA-FS 2001), include (1) vegetation management practices, 

(2) the fact that the SNF is near the southernmost edge of the goshawk’s range, and (3) survey 

efforts for goshawks may be lower on the SNF.

The major risk factors identified by the SNFPA (USDA 2004) for goshawks are the effects of 

uncharacteristically severe, stand replacing wildfires on the amount and distribution of quality 

habitat. Implementation of Alternative 2 would result in 121 acres of CWHR 4D converted to 

4M. This density type change is spread across the treatment units and comprises just over 1.5% of 

the total goshawk habitat present in the project boundary. Implementation of Alternative 3 would 

result in 53 acres of CWHR 4D converting to 4M, comprising less than 0.7% if the total goshawk 

habitat present within the project boundary. This habitat is expected to recover with 10-15 years 

to higher quality habitat.

Because the alternatives put forth in this project would result in long-term increases in northern 

goshawk suitable habitat over time, along with the relatively stable geographic distribution and 

population levels of goshawks in the area, and the project’s goal of increasing large diameter 

trees, the cumulative effects of vegetation management activities in the Greys Mountain treatment 

areas taken together with past, present, and reasonably foreseeable activities on the Forest would

not result in a loss of viability for the northern goshawk.

It is my determination that the Alternative 1 (the no action alternative) for the Greys Mountain 

Ecological Restoration Project would not affect the Northern goshawk. This is due to the fact that 

no vegetation treatments would occur under Alternative 1. However, by taking no action to 

reduce fuel levels, the threat of large scale stand replacing fires would remain unabated, and if 

such an event occurs, there could be significant detrimental impacts to this species.

It is my determination that Alternatives 2-3 (the action alternatives) for the Greys Mountain 

Ecological Restoration Project may affect individuals, but is not likely to result in a trend toward 

Federal listing or loss of viability for the Northern goshawk. Northern goshawks are known to 

utilize areas within the project for nesting and foraging, and individual goshawks may 

temporarily be disturbed by project activities. Northern goshawk habitat also occurs in the 

project area, although the proposed treatments would not result in measurable reductions of that 

habitat. This habitat would remain suitable as nesting and foraging habitat, and is expected to 

increase in habitat quality within 5-15 years after project action. An LOP would protect all 

known nest sites within the project area. 
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Sierra National Forest – 127 Chapter 3

Pallid Bat 

BEs for many of the past projects in the SNF were reviewed to help inform the present analysis. 

Our review of these documents revealed the following basic information about effects to pallid 

bats from these activities:

 26 total project BEs were reviewed, dating back to 1993 on the SNF. The 

species was not listed as Forest Service Sensitive until the updated list from June 

1998. 

 Determinations reached were:

 No effect – four BEs

 May affect individual bats, but not likely to lead to a trend toward federal 

listing or loss of viability – ten BEs

 May affect individual bats, and likely to lead to a trend toward federal 

listing or loss of viability – 0 BEs

 Pallid bat was not addressed in the document we reviewed due to lack of 

habitat or other reasons – 12 BEs

 Types of Projects: Fuels reduction, hazard tree removal, thinning, and 

underburning were the proposed activities that were most often represented in the 

sample of BEs in which the pallid bat was analyzed.

 Relative to “May Affect” projects, the described impacts to pallid bats most often 

fell in the following categories:

 Loss of roosting trees/snags

 Displacement because of smoke from underburning

 Noise disturbance

Pallid bats occur most frequently below 6,000 feet and are especially sensitive to the removal of 

hardwoods (USDA-FS 2001). Except for 4D and 5D, CWHR rates all size classes and densities in 

blue oak woodlands as high for pallid bat, in terms of meeting its foraging needs. Montane 

hardwood conifer and montane hardwood habitats are rated low for pallid bat by CWHR 

(California Department of Fish and Game, 2005). Currently, there are 32,600 acres of blue oak 

woodlands and 251,000 acres of montane hardwoods and montane hardwood conifers below 

8,000 ft on the SNF in CWHR size classes 2 and higher. The protection, maintenance, and 

enhancement of such westside foothill oaks and montane oaks are expected to benefit pallid bats 

by ensuring the continued availability of roosting sites. Indeed, all of the alternatives proposed in 

the SNFPA FEIS were determined to lead to an increase in oak species (USDA-FS 2001).

Cumulative effects discussed in the SNFPA FEIS stated that there have been no recent changes in 

the range or distribution of the pallid bat (USDA-FS 2001). For these reasons, and given the longterm objective for increasing the number of large trees across the landscape, the intention of 

reducing fuels to reduce the potential for large stand replacing wildfire, and the foregoing 

discussion of effects, the cumulative effects of vegetation management activities in the project 

treatment areas taken together with past, present, and reasonably foreseeable activities on the 

Forest would not result in a loss of viability for the pallid bat.

It is my determination that Alternative 1 (the no action alternative) for the Greys Mountain 

Ecological Restoration Project would not affect the Pallid bat. This is due to the fact that no 

vegetation treatments would occur under Alternative 1. However, by taking no action to reduce 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 128 Chapter 3

fuel levels, the threat of large scale stand replacing fires would remain unabated, and if such an 

event occurs, there could be significant detrimental impacts to this species.

It is my determination that Alternatives 2-3 (the action alternatives) of the Greys Mountain 

Ecological Restoration Project may affect individuals, but is not likely to result in a trend toward 

Federal listing or loss of viability for the Pallid bat. The project area has pallid bat habitat, and 

the bats themselves may occur there, so there is a risk that some individuals may be disturbed by 

project activities. This project does not propose to remove any snags unless they constitute a 

danger tree as identified in the Engineering Design Critera. Proposed activities also may result in 

the loss of roost or maternal trees, however, the management prescriptions would not result in 

significant changes in that habitat type, therefore, there would not be a measurable degradation of 

overall habitat suitability within or near the project area. 

Western Red Bat 

There are no expected direct or indirect negative effects to the western red bat from the proposed 

project; therefore, there are no expected cumulative effects from the project.

It is my determination that the Alternative 1 (the no action alternative) for the Greys Mountain 

Ecological Restoration Project would not affect the Western red bat. This is due to the fact that no 

vegetation treatments would occur under Alternative 1 No Action.

It is my determination that Alternatives 2-3 (the action alternatives) of the Greys Mountain 

Ecological Restoration Project would not affect the Western red bat. This is due to the fact that 

no suitable roosting, hibernating, or maternal habitat would be impacted by any project activity.

American Marten 

The area considered in determining the cumulative effects of past, present, and reasonably 

foreseeable activities on marten encompasses the Bass Lake Ranger District. This is an 

appropriate scale for cumulative effects for a wide-ranging species (such as the marten) that has 

also been selected as a Management Indicator Species for the Sierra NF. Based on the following 

analysis, a determination of viability for the marten would be made.

BE for many of the past projects in the Sierra NF were reviewed to help inform the present 

analysis. Our review of these documents revealed the following basic information about effects to 

marten from these activities:

• 26 total project Biological Evaluations (BEs) were reviewed, dating back to 1993 on the 

Sierra NF.

• Determinations reached were:

o No effect – seven BEs

o May affect individual marten, but not likely to lead to a trend toward federal 

listing or loss of viability – 15 BEs

o May affect individual marten, and likely to lead to a trend toward federal listing 

or loss of viability – 0 BEs

o Marten were not addressed in the document we reviewed due to lack of habitat 

or other reasons – four BEs

• Types of Projects: Fuels reduction, harvest, hazard tree removal, and thinning were the 

proposed activities that were most often represented in the sample of BEs in which the 

marten was analyzed.

• Relative to “May Affect” projects, the described impacts to marten most often fell in the 

following categories:
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 129 Chapter 3

o Temporary disturbances

o Foraging area may be burned if underburning gets out of control

o Removed hazard trees could serve as resting or denning sites

o Habitat altered or removed

o Reduction of habitat quality (e.g., reduction in canopy cover)

o Habitat would be entered

o Noise disturbance

No large vegetation management projects have occurred above 7,000’ft over the past decade as 

most recent projects are centered around the WUI areas of the district which generally occur 

below 6,000’ft in elevation. Additionally, most marten habitat on the forest occurs in Wilderness 

areas where few vegetation management activities occur. 

Because the alternatives put forth in this project would result in long-term increases in marten 

suitable habitat over time and the project’s goal of increasing large diameter trees, the cumulative 

effects of vegetation management activities in the Greys Mountain treatment units taken together 

with past, present, and reasonably foreseeable activities on the Forest would not result in a loss of 

viability for the American marten.

It is my determination that Alternative 1 (the no action alternative) for the Greys Mountain 

Ecological Restoration Project would not affect the American marten as a result of vegetation 

treatments, as none would occur under Alternative 1. However, by taking no action to reduce 

fuel levels, the threat of large scale stand replacing fires would remain unabated, and if such an 

event occurs, there could be significant detrimental impacts to this species.

It is my determination that Alternatives 2-3 (the action alternatives) of the Greys Mountain 

Ecological Restoration Project may affect individuals, but is not likely to result in a trend toward 

Federal listing or loss of viability for the American marten. Suitable marten habitat occurs in and 

near the eastern edge of the project area and the proposed actions would not result in significant 

reductions of their habitat at the project or unit level. Sufficient levels of large trees >20”dbh, 

that provide potential den and rest sites, would be maintained, even under the most aggressive 

action alternative. This project does not propose to remove any oaks, and measures would be 

implemented to protect black oaks. A few marten may be disturbed by project activities, 

although this only would be for the short-term duration of those actions. There would be a 100-

acre buffer applied to any marten den sites discovered within the project area which would

minimize potential project-related disturbances to breeding marten. 

Silvicultural prescriptions would maintain canopy cover of at least 50%, with a preference for at 

least 60%, immediately post treatment, and these prescriptions focus on removing surface and 

ladder fuels, and thinning from below. There would be very few changes to habitat types as a 

result of this management. Large trees (30”dbh and above), and all snags, would be retained 

during mechanized treatments, except where they pose an immediate safety hazard. The project 

would not impede movement or dispersal to other currently connected suitable habitat areas 

because habitat connectivity would be maintained within and adjoining the project area. 

All action alternatives also may result in long-term positive effects to the marten by: 1) reducing 

the potential for uncharacteristically severe, stand eliminating wildfires; and 2) promoting the 

growth and re-growth of understory vegetation, which provides forage for prey species, as well as 

hiding and thermal cover. The horizontal and vertical diversity of forest vegetation structure and 

species also may be improved in some sites as a result of partially opening the forest overstory, 

particularly with Alternative 2. This in-turn would bring greater biodiversity into the stands, 

promoting greater prey species abundance and diversity. All of these factors combined outweigh 

the short-term negative effects of treatments (due to immediate partial loss of forest biomass and 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 130 Chapter 3

disturbance), especially considering that a more severe fire regime is predicted for the future, and 

without fuels reduction, large scale, stand replacing wildfires would most likely cause serious and 

significant impacts to the population.
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Terrestrial Wildlife Management Indicator 

Species____________________________________

The direct, indirect and cumulative effects to the Terrestrial Wildlife Management Indicator 

Species are summarized from the Terrestrial Wildlife Management Indicator 

Species (MIS) report for the Grey’s Mountain Ecological Restoration Project (Otto, 2012)

The purpose of this report is to evaluate and disclose the impacts of the project on the habitat of 

terrestrial Management Indicator Species (MIS) identified in the SNF LRMP (USDA 1991) as 

amended by the Sierra Nevada Forests Management Indicator Species Amendment (SNF MIS 

Amendment) Record of Decision (ROD) (USDA Forest Service 2007a). This report documents 

the effects of the proposed action and alternatives on the habitat of selected project-level MIS. 

MIS are animal species identified in the SNF MIS Amendment ROD signed December 14, 2007, 

which was developed under the 1982 NFS Land and Resource Management Planning Rule (1982 

Planning Rule) (36 CFR 219). The current rule applicable to project decisions is the 2004 

Interpretive Rule, which states “Projects implementing land management plans...must be 

developed considering the best available science in accordance with §219.36(a)...and must be 

consistent with the provisions of the governing plan.” (Appendix B to §219.35). Guidance 

regarding MIS set forth in the Sierra NF LRMP as amended by the 2007 SNF MIS Amendment 

ROD directs Forest Service resource managers to (1) at project scale, analyze the effects of 

proposed projects on the habitat of each MIS affected by such projects, and (2) at the bioregional 

scale, monitor populations and/or habitat trends of MIS, as identified in the Sierra NF LRMP as 

amended.

Affected Environment

MIS Habitat Status and Trend 

All habitat monitoring data are collected and/or compiled at the bioregional scale, consistent with 

the LRMP as amended by the 2007 SNF MIS Amendment ROD (USDA Forest Service 2007a).

Habitats are the vegetation types (for example, early seral coniferous forest) or ecosystem 

components (for example, snags in green forest) required by an MIS for breeding, cover, and/or 

feeding. MIS for the Sierra Nevada National Forests represent ten major habitats and two

ecosystem components (USDA Forest Service 2007a). These habitats are defined using the 

CWHR System (CDFG 2005). The CWHR System provides the most widely used habitat 

relationship models for California’s terrestrial vertebrate species (ibid). Included in Appendix A 

at the end of this document are tables explaining the acronyms used for available habitat stages in 

the CWHR system. It is also described in detail in the 2010 SNF Bioregional MIS Report (USDA 

Forest Service 2010a). 

Habitat status is the current amount of habitat on the Sierra Nevada Forests. Habitat trend is the 

direction of change in the amount or quality of habitat over time. The methodology for assessing 

habitat status and trend is described in detail in the 2010 SNF Bioregional MIS Report (USDA 

Forest Service 2010a). 

MIS Population Status and Trend

All population monitoring data are collected and/or compiled at the bioregional scale, consistent 

with the LRMP as amended by the 2007 SNF MIS Amendment ROD (USDA Forest Service 
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Sierra National Forest – 132 Chapter 3

2007a). The information is presented in detail in the 2010 SNF Bioregional MIS Report (USDA 

Forest Service 2010a).

Population monitoring strategies for MIS of the Sierra NF are identified in the 2007 Sierra 

Nevada Forests Management Indicator Species (SNF MIS) Amendment ROD (USDA Forest 

Service 2007a). Population status is the current condition of the MIS related to the population 

monitoring data required in the 2007 SNF MIS Amendment ROD for that MIS. Population trend 

is the direction of change in that population measure over time.

There are a myriad of approaches for monitoring populations of MIS, from simply detecting 

presence to detailed tracking of population structure (USDA Forest Service 2001, Appendix E, 

page E-19). A distribution population monitoring approach is identified for all of the terrestrial 

MIS in the 2007 SNF MIS Amendment, except for the greater sage-grouse (USDA Forest Service 

2007a). Distribution population monitoring consists of collecting presence data for the MIS 

across a number of sample locations over time. Presence data are collected using a number of 

direct and indirect methods, such as surveys (population surveys), bird point counts, tracking 

number of hunter kills, counts of species sign (such as deer pellets), and so forth. The specifics 

regarding how these presence data are assessed to track changes in distribution over time vary by 

species and the type of presence data collected, as described in the 2010 SNF Bioregional MIS 

Report (USDA Forest Service 2010a). 

Methodology for Analysis 

Project-level effects on MIS habitat are analyzed and disclosed as part of environmental analysis 

under the NEPA. This involves examining the impacts of the proposed project alternatives on 

MIS habitat by discussing how direct, indirect, and cumulative effects would change the habitat 

in the analysis area. 

These project-level impacts to habitat are then related to broader scale (bioregional) population 

and/or habitat trends. The appropriate approach for relating project-level impacts to broader scale 

trends depends on the type of monitoring identified for MIS in the LRMP as amended by the SNF 

MIS Amendment ROD. Hence, where the Sierra NF LRMP as amended by the SNF MIS 

Amendment ROD identifies distribution population monitoring for an MIS, the project-level 

habitat effects analysis for that MIS is informed by available distribution population monitoring 

data, which are gathered at the bioregional scale. The bioregional scale monitoring identified in 

the Sierra NF LRMP, as amended, for MIS analyzed for the Greys Mountain Project is 

summarized in Section 3 of the Terrestrial MIS report.

Adequately analyzing project effects to MIS generally involves the following steps:

 Identifying which habitat and associated MIS would be either directly or indirectly 

affected by the project alternatives; these MIS are potentially affected by the project.

 Summarizing the bioregional-level monitoring identified in the LRMP, as amended, for 

this subset of MIS.

 Analyzing project-level effects on MIS habitat for this subset of MIS. 

 Discussing bioregional scale habitat and/or population trends for this subset of MIS. 

 Relating project-level impacts on MIS habitat to habitat and/or population trends at the 

bioregional scale for this subset of MIS.

These steps are described in detail in the Pacific Southwest Region draft document “MIS

Analysis and Documentation in Project-Level NEPA, R5 Environmental Coordination” (May 25, 

2006). This MIS section documents application of the above steps to select project-level MIS and 

analyze project effects on MIS habitat for the project.
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Mitigation and Monitoring 

Special project design measures for the project were developed in concert with the BLRD 

interdisciplinary team, PSW research scientists, and concerned public participation groups. These 

design measures would be implemented under any of the two action alternatives. Within this 

project area special considerations have been given to maintaining higher levels of biodiversity 

through actions such as delineating OFLs surrounding perennial streams (see Terrestrial Wildlife 

BE/BA, USDA-FS 2011a for a description of OFLs). Higher levels of biodiversity have also been 

planned for by marking retention groups of large diameter trees. Between 500 to750 of such tree 

groups were identified in the project area. Ideally, when available on the landscape these groups 

also contain “defect” trees: those that have cavity and platform creating defects such as mistletoe, 

rot, forked tops, broken limbs, and broken tops. No trees greater than 20” dbh would be cut 

within these groups. These large tree groups would have a residual basal area of 240 ft2 or more 

for mixed conifer and 210 ft2 or more for pine and in many instances may reach 300 to 400 ft2 per 

acre. 

Another project design measure which would maintain biodiversity is the identification of 

retention areas around large oaks within treatment units. Two to three large oaks per acre were 

identified and marked with paint. These oaks would retain a zone of no activity around them 

measuring 35 feet, or dripline circumference around the oak (whichever is greater). The 

delineation of OFLs, retention of large tree groups, and oak no treatment zones would ensure a 

heterogeneous post treatment landscape resulting in the continued accessibility of both hiding 

cover and prey availability within these areas of biodiversity (USDA-FS 2011a).

The project is designed to improve habitat conditions through the acceleration of latesuccessional habitat characteristics, while still maintaining current functional habitat. Specific 

project design criteria include: canopy cover would be maintained at 50 to 60% or greater where 

available; ground disturbance would be limited to those guidelines with the LRMP as amended; 

vegetation species diversity and composition would be maintained; management activities would

be limited in designated riparian management areas; and retention of snags and downed logs 

would be retained at levels defined in the Design Criteria Common to All Action Alternatives. 

All riparian management areas within the project have been identified and buffers established. In 

addition, no operations would occur during the wet weather season. (USDA-FS 2011a)

Category 1 MIS

Species that would not be discussed further in this document include Category 1 and Category 2 

MIS. Category 1 defines MIS whose habitat does not occur in or adjacent to the project area. For 

the project, Category 1 MIS include the greater sage-grouse and the black-backed woodpecker. 

No sagebrush (SGB) or burned forest habitat is currently present in or adjacent to the project area.

Black-backed woodpecker

Although no burned habitat is currently present within the project area, there may be indirect 

effects to black-blacked woodpecker habitat through the implementation of the project. This is 

due to the fact that part of the purpose and need for the project is to reduce the potential for large 

scale, uncharacteristically severe wildfires to occur on the landscape, and the black-backed 

woodpecker relies on the presence of snags created by moderate and high severity fires. During 

the past decade from 2000 through 2010, the Sierra National Forest has experienced a total of 53 

wildfires totaling 28,419 acres, with an average fire size of 536 acres. 65% of the total acres 

burned during this period were categorized as moderate and high severity burned areas, which 

create the habitat types preferred by the black-backed woodpecker (USDA FS 2010a).
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 134 Chapter 3

The implementation of projects designed to reduce fuel loading and fire severity does not 

preclude the occurrence of wildfire across the landscape, it merely seeks to lessen the extent and 

severity of such fires when they occur. Since treatments for the Greys Mountain Project are 

limited to a maximum of 3,420 acres out of the 9,580 acres within the project boundary (36% of 

the total area), there remains potential for low and moderate severity fire to occur throughout the 

entire project area, and the potential for high severity fire to occur within the untreated portion of 

the project boundary (64% of the total area). 

It is reasonable to conclude that wildfires of all severity types would continue to occur across the 

Bass Lake Ranger District and the Sierra National Forest, even after the implementation of the 

project. Therefore, habitat for the black-backed woodpecker would likely continue to increase on 

the Bass Lake district and across the Sierra NF. Furthermore, current data at the range wide, 

California, and Sierra Nevada scales indicate that the distribution of black-backed woodpecker 

populations in the Sierra Nevada is stable (USDA FS 2010a).

Category 2 MIS

Category 2 defines MIS whose habitat is in or adjacent to the project area, but whose habitat 

would not be directly or indirectly affected by the project. For the project, Category 2 MIS 

include: mule deer, yellow warbler, and sooty grouse. Though habitat for these species occurs 

within or adjacent to the project area, that habitat would not be directly or indirectly affected by 

the project. The primary reasons for this appraisal are the project design features which limit the 

activities reducing canopy closure. These design features, as well as applicable Forest Service 

S&Gs protecting species habitats, are discussed further in the following sections of this document 

for each Category 2 MIS.

Mule Deer

Mule deer were selected as the MIS for oak-associated hardwood and hardwood/conifer forest in 

the Sierra Nevada. CWHR habitat for mule deer includes montane hardwood (MHW) and 

montane hardwood-conifer (MHC) all tree density and size classes. CWHR analysis identified a 

total of 298 acres of montane hardwood and montane hardwood conifer habitat within the project

treatment units. There are no projected changes to montane hardwood habitat throughout the 

project area since no oaks are proposed for removal by this project. Forest stands surrounding 

oaks have varying prescriptions based upon the size and dbh of the oaks present. Many older oaks 

>20” dbh would retain a zone of “No Treatment” surrounding them for a distance of 35 feet, or 

dripline of the oak (whichever is greater). This prescription is designed to maintain habitat 

heterogeneity and hiding cover for fisher and their prey surrounding the larger, decadent oaks 

within the project area. For younger oaks and oak saplings, more trees may be removed around 

the southern exposure of these young oaks to allow for more sunlight and encourage diameter 

growth and vigor of the oaks. Oaks respond well to disturbance, and are among the first species to 

sprout in openings created by prescribed fire or thinning activities. It is expected that the number 

and vigor of oaks within the Greys Mountain Project would increase following project 

implementation. 

Since none of the proposed alternatives for the project would alter the existing 298 acres of 

habitat identified for the mule deer, there would be no direct or indirect effects to habitat for this 

MIS, making it a category 2 species for this analysis. Mule deer will not be discussed further in 

this document.
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Sierra National Forest – 135 Chapter 3

Yellow Warbler

Yellow warblers are found in riparian deciduous habitats in summer (cottonwoods, willows, 

alders, and other small trees and shrubs typical of low, open-canopy riparian woodland) (CDFG 

2005). Montane riparian (MRI) and valley foothill riparian (VRI) are the two CWHR types used 

in this analysis to define the habitat. CWHR analysis identified did not identify any acres of MRI 

habitat type within the project area. However, it is reasonable to assume that some montane 

riparian habitat exists along the 21 miles of perennial streams within and adjacent to the project 

area but was simply not captured by the remote sensing lab when digitizing the 2009 vegetation 

data. 

All applicable S&Gs from the Sierra National Forest LRMP (USDA-Forest Service 1992), and 

associated amendments (USDA-Forest Service 2001, 2004), and other applicable laws and 

regulations would be applied to this project. Sierra National Forest’s LRMP forest-wide S&Gs

that were not superseded by the 2001 or 2004 amendments (USDA-Forest Service 2001; USDAForest Service 2004) applicable to project for aquatic species, habitats, and riparian health can be 

found in the project aquatics and hydrology reports (USDA Forest Service 2011e, USDA Forest 

Service 2004f). With adherence to the S&Gs for aquatic and riparian health, the project would not 

cause a direct or indirect affect to yellow warbler habitat, making it a category 2 species for this 

analysis. Yellow warbler will not be discussed further in this document.

Sooty (Blue) Grouse

The sooty grouse was selected as the MIS for late seral open canopy coniferous forest in the 

Sierra Nevada. CWHR habitat for the sooty grouse includes ponderosa pine (PPN), Sierran mixed 

conifer (SMC), white fir (WFR), red fir (RFR), and eastside pine (EPN), tree size 5, canopy 

closures S and P. CWHR analysis identified only 12 acres of habitat meeting this criteria in the 

project area: SMC5P (12 acres). Although 3 acres of SMC5P occur within treatment units, there 

would be no changes to the habitat type; all 12 acres would remain at current CWHR strata. Since 

none of the proposed Alternatives for the project would alter the existing 12 acres of habitat 

identified for the sooty grouse, there would be no direct or indirect effects to habitat for this MIS, 

making it a category 2 species for this analysis. Sooty grouse will not be discussed further in this 

document.

Category 3 MIS

The MIS whose habitat would be either directly or indirectly affected by the project, identified as 

category 3 are carried forward in this analysis, which evaluates the direct, indirect, and 

cumulative effects of the proposed action and alternatives on the habitat of these MIS. The MIS 

selected for project-level MIS analysis for the Greys Mountain Project are: fox sparrow, mountain 

quail, California spotted owl, American marten, northern flying squirrel, and hairy woodpecker. 

The following section documents the analysis for the Category 3 MIS species: fox sparrow, 

mountain quail, California spotted owl, American marten, northern flying squirrel, and hairy 

woodpecker. The analysis of the effects of the project on the terrestrial MIS habitat for the 

selected project-level MIS is conducted at the project scale. The analysis used the CWHR model 

(Mayer and Laudenslayer 1988)) data to determine vegetative type within the entire project

boundary. Existing acres of vegetation type (base vegetation layer) were determined using the 

Sierra National Forest Corporate GIS vegetation feature class of 2009 Existing Vegetation. 

Detailed information on the MIS is documented in the 2010 SNF Bioregional MIS Report 

(USDA Forest Service 2010a), which is hereby incorporated by reference. 
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Sierra National Forest – 136 Chapter 3

Cumulative effects at the bioregional scale are tracked via the SNF MIS Bioregional monitoring, 

and detailed in the 2010 SNF Bioregional MIS Report (USDA Forest Service 2010a). 

Table 18. Action Alternatives Summary of changes to CWHR Forest Type within the 

Boundaries of the Greys Mountain Project

Alternative 2 Alternative 3

CWHR Habitat 

Type Pre-treatment

CWHR Habitat 

Type Post-treatment

Number of Acres of 

Density Change

Number of Acres of 

Density Change

PPN4D PPN4M 5 acres 2 acres

PPN5D PPN5M 3 acres 2 acres

MHC4D MHC4M 1 acre 1 acre

SMC4D SMC4M 111 acres 47 acres

SMC4D SMC4P 1 acre 1 acre

SMC5D SMC5M 2 acres 2 acres

Total Acres CWHR Habitat Density Change 123 acres 55 acres

MIS Project-level Effects Analysis 

Shrubland (West-Slope Chaparral) Habitat (Fox Sparrow)

Current Condition of the Habitat Factor(s) in the Project Area: There are a total of 368 acres 

of shrub-land (chaparral) habitat within the project boundary. 253 acres are classified as montane 

chaparral (MCP) and the remaining 115 acres are classified as mixed chaparral (MCH). Of the 

368 acres of chaparral within the project boundary 149 acres (40%) occur within proposed 

treatment units. Please refer to Table 18 (Greys Mountain Project CWHR Data Table, Project 

Area, Present Compared to Alternative 2 Proposal) for a full breakdown of all CWHR habitat 

types within the Project boundary pre- and post-treatment.

Alternative 1 – No Action

Alternative 1 is the no action alternative. Under the no action alternative, current management 

plans would continue to guide management of the project area. This includes all ongoing 

activities with existing decisions or permits that would not be changed if this alternative were 

selected including: underburning, plantation maintenance, cattle grazing, recreation, and 

recreation residences. The No Action Alternative would not implement the Greys Mountain 

Project.

Direct and Indirect Effects to Habitat. 

There are no direct effects to shrubland habitat under this alternative. There is a potential for 

indirect effects under the No Action Alternative as the continued immediate threat of wildfire 

would remain unabated. In failing to make an attempt at density management of the stands, the 

eventual changes through drought stress and subsequent insect and disease mortality acceleration 

would exacerbate the threat of stand replacing fire. Additionally, the high probability of a drying 

climate change throughout the Western United States would have the potential to further 

compound these effects. (USDA Forest Service 2011a, 2011c, 2011d). 

Cumulative Effects to Habitat in the Analysis Area. 

Cumulative Effects Conclusion: There would be no direct or indirect effects; therefore there are 

no cumulative effects for the no action alternative of the project.
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Sierra National Forest – 137 Chapter 3

Alternative 2 – Proposed Action

Direct and Indirect Effects to Habitat. 

Under Alternative 2, direct effects to 149 acres of shrubland habitat are proposed through 

mastication and prescribed burning treatments. These 149 acres would be treated to maintain the 

growth and vigor of existing trees, or to create conditions suitable for the establishment of planted 

trees. The change in seral stage of 149 acres of chaparral out of 368 acres within the project 

boundary is a treatment of 40% of the total chaparral available within the project boundary. There 

are an additional 219 acres of shrubland habitat identified within the project boundary that are not 

proposed for treatment under the proposed action alternatives and would continue to provide 

suitable habitat for fox sparrow during implementation of mastication and burning activities. 

Cumulative Effects to Habitat in the Analysis Area. 

A table of current and future projects within the analysis area for the project can be found in the 

Table 9. 

Cumulative Effects Conclusion: 

This project proposes to treat 40% of the existing shrubland within the project boundary. Further

activities taking place within the cumulative effects boundary that may alter shrubland habitat 

include road brushing and plantation maintenance. These activities may alter a very small 

percentage of the available shrubland habitat through removal of senescent chaparral bordering 

roads and inside plantations, resulting in natural regeneration of early seral stage chaparral 

habitat.

Alternative 3 

Direct, Indirect, and Cumulative Effects to Habitat and Conclusion. 

The proposed treatments for the shrubland habitat within Alternative 3 are the same as for 

Alternative 2; therefore the direct, indirect, and cumulative effects for Alternative 3 would be the 

same as those discussed under the proposed action.

Summary of Fox Sparrow Status and Trend at the Bioregional Scale

The Sierra NF LRMP (as amended by the SNF MIS Amendment) requires bioregional-scale 

habitat and distribution population monitoring for the fox sparrow; hence, the shrubland effects 

analysis for the project must be informed by both habitat and distribution population monitoring 

data. The sections below summarize the habitat and distribution population status and trend data 

for the fox sparrow. This information is drawn from the detailed information on habitat and 

population trends in the 2010 Sierra Nevada Forests Bioregional MIS Report (USDA Forest 

Service 2010a), which is hereby incorporated by reference.

Habitat Status and Trend. There are currently 1,009,681 acres of west-slope chaparral 

shrubland habitat on National Forest System lands in the Sierra Nevada. Over the last two 

decades, the trend is slightly increasing (changing from 8% to 9% of the acres on National Forest 

System lands). 

Population Status and Trend. Monitoring of the fox sparrow across the ten National Forests 

in the Sierra Nevada has been conducted since 2009 in partnership with Point Reyes Bird 

Observatory (PRBO) Conservation Science, as part of a monitoring effort that also includes 

mountain quail, hairy woodpecker, and yellow warbler (USDA Forest Service 2010a, 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 138 Chapter 3

http://data.prbo.org/partners/usfs/snmis/). Fox sparrows were detected on 36.9% of 1659 point 

counts in 2009 and 44.3% of 2266 point counts in 2010, with detections on all 10 national forests 

in both years. The average abundance (number of individuals recorded on passive point count 

surveys) was 0.563 in 2009 and 0.701 in 2010. These data indicate that fox sparrows continue to 

be distributed across the 10 Sierra Nevada National Forests. In addition, the fox sparrows 

continue to be monitored and surveyed in the Sierra Nevada at various sample locations by avian 

point count, spot mapping, mist-net, and breeding bird survey protocols. These are summarized in 

the 2008 Bioregional Monitoring Report (USDA Forest Service 2008). Current data at the range 

wide, California, and Sierra Nevada scales indicate that, although there may be localized declines 

in the population trend, the distribution of fox sparrow populations in the Sierra Nevada is stable.

Relationship of Project-Level Habitat Impacts to Bioregional-Scale Fox Sparrow 

Trend. The 368 acres of shrubland habitat that exists within the project boundary account for 

less than 0.04% of the 922,000 acres that exists at the bioregional scale, and only 149 of these 

acres are proposed for some form of treatment. Therefore, cumulative impacts within the project 

boundary would not alter the existing bioregional trends in this habitat, nor would they lead to a 

change in the distribution of fox sparrows across the Sierra Nevada bioregion.

Mid Seral Coniferous Forest Habitat (Mountain quail)

Current Condition of the Habitat Factor(s) in the Project Area: There are currently 

6,052 acres of mid seral coniferous forest habitat within the project boundary. Of these, 2,563 

acres (42%) are within proposed treatment units. Refer to Table 2 (Greys Mountain Project Camp 

CWHR Data Table, Project Area, Present Compared to Alternative 2 Proposal) of this report for a 

full breakdown of all CWHR habitat types within the project boundary pre- and post-treatment.

Alternative 1 – No Action

Direct and Indirect Effects to Habitat. 

There would be no direct effects to mid seral coniferous habitat under this alternative. There is a 

potential for indirect effects under the No Action Alternative as the continued immediate threat of 

wildfire would remain unabated. In failing to make an attempt at density management of the 

stands, the eventual changes through drought stress and subsequent insect and disease mortality 

acceleration would exacerbate the threat of stand replacing fire. Additionally, the high probability

of a drying climate change throughout the Western United States would have the potential to 

further compound these effects. (USDA Forest Service 2011, 2011c, 2011d). 

Cumulative Effects to Habitat in the Analysis Area and Conclusion.

There are no direct or indirect effects of the no action alternative 1, therefore there are no 

cumulative effects for Alternative 1.

Alternative 2 – Proposed Action

Direct and Indirect Effects to Habitat. 

Under Alternative 2, there are projected changes in CWHR composition of mid seral coniferous 

habitat these changes are projected to occur on 124 acres spread across the treatment units. Seven

acres of PPN4D would be converted to PPN4M and 115 acres of SMC4D would be converted to 

SMC4M through proposed mechanical thinning treatments. The remaining 2,515 acres of mid 

seral coniferous habitat within the treatment units would not experience a change in CWHR 

habitat type, size, or density under the Alternative 2 proposal. Due to the thinning prescriptions 

proposed, additional seral stage changes beyond those described would not change. Stands would 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 139 Chapter 3

merely reflect less density. It is expected that those stands treated would experience better health, 

vigor, and growth and would be less susceptible to wildfires.

Cumulative Effects to Habitat in the Analysis Area and Conclusion. 

Many of the ongoing management activities within the cumulative effects boundary would not 

contribute to significant cumulative impacts upon mid seral coniferous forest habitat. Of the 

cumulative effects actions elevated within the analysis area, private land residential development, 

roadside hazard tree removal, on-going plantation maintenance, and past and future timber sale 

activity have the greatest potential to alter mid seral coniferous habitat. Additional effects through 

Alternative 2 proposed canopy cover changes of 0.5% of the total habitat in the cumulative 

effects boundary are insignificant, especially when one considers the vast amount of available 

mid seral coniferous habitat present within the cumulative effects boundary.

Alternative 3

Direct, Indirect, and Cumulative Effects to Habitat and Conclusion.

Under Alternative 3, there are projected changes in CWHR composition of mid seral coniferous 

habitat. These changes are projected to occur on 48 acres spread across the treatment units. one

acre of PPN4D would be converted to PPN4M and 47 acres of SMC4D would be converted to 

SMC4M through proposed mechanical thinning treatments. The remaining 2,441 acres of mid 

seral coniferous habitat within the treatment units would not experience a change in CWHR 

habitat type, size, or density under the Alternative 2 proposal. Due to the thinning prescriptions 

proposed, additional seral stage changes beyond those described would not change. Stands would 

merely reflect less density. It is expected that those stands treated would be less susceptible to 

wildfires, but since no density management would occur the stands would not experience the 

health, vigor, and growth of the larger trees that would occur under Alternative 2.

Indirect effects can be expected by failing to make an attempt at density management of the 

stands, the eventual changes through drought stress and subsequent insect and disease mortality 

acceleration would exacerbate the threat of stand replacing fire. Additionally, the high probability 

of a drying climate change throughout the Western United States would have the potential to 

further compound these effects. (USDA Forest Service 2011, 2011c, 2011d). 

Summary of Mountain Quail Status and Trend at the Bioregional Scale

The Sierra NF LRMP (as amended by the SNF MIS Amendment) requires bioregional-scale 

habitat and distribution population monitoring for the mountain quail; hence, the early and mid 

seral coniferous forest effects analysis for the project must be informed by both habitat and 

distribution population monitoring data. The sections below summarize the habitat and 

distribution population status and trend data for the mountain quail. This information is drawn 

from the detailed information on habitat and population trends in the 2010 SNF Bioregional MIS 

Report (USDA Forest Service 2010a), which is hereby incorporated by reference.

Habitat Status and Trend. 

There are currently 2,776,022 acres of mid seral coniferous forest (ponderosa pine, Sierran mixed 

conifer, white fir, and red fir) habitat on National Forest System lands in the Sierra Nevada. Over 

the last two decades, the trend for mid seral habitat is increasing (changing from 21% to 25% of 

the acres on National Forest System lands). 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 140 Chapter 3

Population Status and Trend. 

Monitoring of the mountain quail across the ten National Forests in the Sierra Nevada has been 

conducted since 2009 in partnership with PRBO Conservation Science, as part of a monitoring 

effort that also includes fox sparrow, hairy woodpecker, and yellow warbler (USDA Forest 

Service 2010a, http://data.prbo.org/partners/usfs/snmis/). Mountain quail were detected on 40.3% 

of 1659 point counts (and 48.6% of 424 playback points) in 2009 and 47.4% of 2266 point counts 

(and 55.3% of 492 playback points) in 2010, with detections on all ten national forests in both 

years. The average abundance (number of individuals recorded on passive point count surveys) 

was 0.103 in 2009 and 0.081 in 2010. These data indicate that mountain quail continue to be 

distributed across the 10 Sierra Nevada National Forests. In addition, mountain quail continue to 

be monitored and surveyed in the Sierra Nevada at various sample locations by hunter survey, 

modeling, and breeding bird survey protocols. These are summarized in the 2008 Bioregional 

Monitoring Report (USDA Forest Service 2008). Current data at the rangewide, California, and 

Sierra Nevada scales indicate that the distribution of mountain quail populations in the Sierra 

Nevada is stable. 

Relationship of Project-Level Habitat Impacts to Bioregional-Scale 

Mountain Quail Trend. 

The 6,052 acres of mid seral coniferous habitat that exists within the project boundary accounts 

for less than 0.2% of the 2,776,022 acres that exists at the bioregional scale. The change in 

canopy closure of 124 acres out of 2,766,000 acres of mid seral coniferous habitat in the Sierra 

Nevada bioregion would not alter the existing trend in the habitat, nor would it lead to a change in 

the distribution of mountain quail across the Sierra Nevada bioregion.

Late Seral Closed Canopy Coniferous Forest Habitat (California spotted 

owl, American marten, and northern flying squirrel) 

Habitat/Species Relationship.

California spotted owl. The California spotted owl was selected as an MIS for late seral 

closed canopy coniferous forest (ponderosa pine, Sierran mixed conifer, white fir, and red fir) 

habitat in the Sierra Nevada. This habitat is comprised primarily of medium/large trees (equal to 

or greater than 24 inches dbh) with canopy closures above 40% within ponderosa pine, Sierran 

mixed conifer, white fir, and red fir coniferous forests, and multi-layered trees within ponderosa 

pine and Sierran mixed conifer forests. The California spotted owl is strongly associated with 

forests that have a complex multi-layered structure, large-diameter trees, and high canopy closure 

(CDFG 2005, USFWS 2006). It uses dense, multi-layered canopy cover for roost seclusion; roost 

selection appears to be related closely to thermoregulatory needs, and the species appears to be 

intolerant of high temperatures (CDFG 2005). Mature, multi-layered forest stands are required 

for breeding (Ibid). The mixed-conifer forest type is the predominant type used by spotted owls 

in the Sierra Nevada: about 80 percent of known sites are found in mixed-conifer forest, with 10 

percent in red fir forest (USDA Forest Service 2001).

American marten. The American marten was selected as an MIS for late seral closed canopy 

coniferous forest (ponderosa pine, Sierran mixed conifer, white fir, and red fir) habitat in the 

Sierra Nevada. This habitat is comprised primarily of medium/large trees (equal to or greater 

than 24 inches dbh) with canopy closures above 40% within ponderosa pine, Sierran mixed 

conifer, white fir, and red fir coniferous forests, and multi-layered trees within ponderosa pine 

and Sierran mixed conifer forests. Martens prefer coniferous forest habitat with large diameter 

trees and snags, large down logs, moderate-to-high canopy closure, and an interspersion of 

riparian areas and meadows. Important habitat attributes are: vegetative diversity, with 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 141 Chapter 3

predominately mature forest; snags; dispersal cover; and large woody debris (Allen 1982). Key 

components for westside and eastside marten habitat can be found in the Sierra Nevada Forest 

Plan Amendment FEIS (USDA Forest Service 2001), Volume 3, Chapter 3, part 4.4, pages 20-21. 

Northern flying squirrel. The northern flying squirrel was selected as an MIS for late seral 

closed canopy coniferous forest (ponderosa pine, Sierran mixed conifer, white fir, and red fir) 

habitat in the Sierra Nevada. This habitat is comprised primarily of medium/large trees (equal to 

or greater than 24 inches dbh) with canopy closures above 40% within ponderosa pine, Sierran 

mixed conifer, white fir, and red fir coniferous forests, and multi-layered trees within ponderosa 

pine and Sierran mixed conifer forests. The northern flying squirrel occurs primarily in mature, 

dense conifer habitats intermixed with various riparian habitats, using cavities in mature trees, 

snags, or logs for cover (CDFG 2005).

Project-level Effects Analysis – Late Seral Closed Canopy Coniferous 

Forest Habitat. 

Habitat Factor(s) for the Analysis: (1) Acres of late seral closed canopy coniferous forest 

(ponderosa pine, Sierran mixed conifer, white fir, and red fir) habitat [CWHR ponderosa pine 

(PPN), Sierran mixed conifer (SMC), white fir (WFR), red fir (RFR), tree size 5 (canopy closures 

M and D), and tree size 6]. (2) Acres with changes in canopy closure (D to M). (3) Acres with 

changes in large down logs per acre or large snags per acre.

Current Condition of the Habitat Factor(s) in the Project Area: There are a total of 

1,009 acres of late seral closed canopy coniferous forest habitat within the project boundary. 292 

acres are PPN5D, 5 acres of PPN5M, 392 acres of SMC5D and 320 acres of SMC5M. This 

habitat type accounts for 11% of the total acreage within the project boundary area.

Alternative 1 (No Action)

Direct and Indirect Effects to Habitat. 

There would be no direct effects to late seral, closed canopy coniferous habitat under this 

alternative. There is a potential for indirect effects under the no action alternative as the continued 

immediate threat of wildfire would remain unabated. In failing to make an attempt at density 

management of the stands, the eventual changes through drought stress and subsequent insect and 

disease mortality acceleration would exacerbate the threat of stand replacing fire. Additionally, 

the high probability of a drying climate change throughout the Western United States would have 

the potential to further compound these effects. (USDA Forest Service 2011, 2011c, 2011d). 

Cumulative Effects to Habitat in the Analysis Area and Conclusion. 

There are no direct or indirect effects of the no action alternative 1, therefore there are no 

cumulative effects for Alternative 1 of the Greys Mountain Project.

Alternative 2 (Proposed Action)

Direct and Indirect Effects to Habitat. 

There are a total of 1,009 acres of late-seral closed canopy coniferous forest within the project 

boundary of the Greys Mountain Project. Of these, 366 acres (36%) occur within treatment units. 

Under Alternative 2, minimal changes to late-seral habitats are projected to occur within the 

fuelbreak treatment areas of the project. 3 acres of PPN5D are projected to be converted to 

PPN5M, and another 2 acres are projected to be converted from SMC5D to SMC5M. Total 

changes to late-seral habitat are expected for only 5 acres, or 0.5% of the available habitat within 

the project boundary. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 142 Chapter 3

Alternative 3

Direct and Indirect Effects to Habitat. 

Changes to late-seral closed canopy forest habitat under Alternative 3 are similar to those 

described for Alternative 2.

Cumulative Effects to Habitat in the Analysis Area and Conclusion. 

Many of the ongoing management activities within the cumulative effects boundary would not 

contribute to significant cumulative impacts upon late seral closed canopy coniferous forest 

habitat. Of the cumulative effects actions elevated within the analysis area, private land 

residential development, roadside hazard tree removal, and past and future timber sale activity 

have the greatest potential to alter late seral stage coniferous habitat. Additional effects through 

Alternative 2 and 3 proposed canopy cover changes of 0.5% of the total habitat in the cumulative 

effects boundary are insignificant, especially when one considers the significant amount of 

available late seral coniferous habitat present within the cumulative effects boundary. Cumulative 

effects are not anticipated to alter the existing trend in the habitat at the project level.

Summary of Status and Trend at the Bioregional Scale

California spotted owl, American marten, and Northern flying squirrel. The Sierra

NF LRMP (as amended by the SNF MIS Amendment) requires bioregional-scale habitat and 

distribution population monitoring for the California spotted owl, American marten, and northern 

flying squirrel; hence, the late seral closed canopy coniferous forest (ponderosa pine, Sierran 

mixed conifer, white fir, and red fir) habitat effects analysis for the project must be informed by 

both habitat and distribution population monitoring data. The sections below summarize the 

habitat and distribution population status and trend data. This information is drawn from the 

detailed information on habitat and population trends in the 2010 SNF Bioregional MIS Report 

(USDA Forest Service 2010a), which is hereby incorporated by reference.

Habitat Status and Trend. There are currently 1,006,923 acres of late seral closed canopy 

coniferous forest (ponderosa pine, Sierran mixed conifer, white fir, and red fir) habitat on 

National Forest System lands in the Sierra Nevada. Over the last two decades, the trend is 

slightly increasing (changing from 7% to 9% of the acres on National Forest System lands); since 

the early 2000s, the trend has been stable at 9%.

Population Status and Trend - California spotted owl. California spotted owl has been 

monitored in California and throughout the Sierra Nevada through general surveys, monitoring of 

nests and territorial birds, and demography studies (Verner et al. 1992; Gutierrez et al. 2008, 

2009, 2010; USDA Forest Service 2001, 2004, 2006; USFWS 2006; Sierra Nevada Research 

Center 2007, 2008, 2009, 2010). Current data at the range wide, California, and Sierra Nevada 

scales indicate that, although there may be localized declines in population trend [e.g., localized 

decreases in “lambda” (estimated annual rate of population change)], the distribution of 

California spotted owl populations in the Sierra Nevada is stable.

Population Status and Trend – American marten. American marten has been monitored 

throughout the Sierra Nevada as part of general surveys and studies since 1996 (e.g., Zielinski et 

al. 2005, Moriarty 2009). Since 2002, the American marten has been monitored on the Sierra 

Nevada forests as part of the SNFPA monitoring plan (USDA Forest Service 2005, 2006, 2007, 

2009, 2010b). Current data at the range wide, California, and Sierra Nevada scales indicate that, 

although marten appear to be distributed throughout their historic range, their distribution has 

become fragmented in the southern Cascades and northern Sierra Nevada, particularly in Plumas 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 143 Chapter 3

County. The distribution appears to be continuous across high-elevation forests from Placer 

County south through the southern end of the Sierra Nevada, although detection rates have 

decreased in at least some localized areas (e.g., Sagehen Basin area of Nevada County). 

Population Status and Trend – northern flying squirrel. The northern flying squirrel 

has been monitored in the Sierra Nevada at various sample locations by live-trapping, eartagging, camera surveys, snap-trapping, and radio telemetry: 2002-present on the Plumas and 

Lassen National Forests (Sierra Nevada Research Center 2007, 2008, 2009, 2010), and 1958-

2004 throughout the Sierra Nevada in various monitoring efforts and studies (see USDA Forest 

Service 2008, Table NOFLS-IV-1). These data indicate that northern flying squirrels continue to 

be present at these sample sites, and current data at the range wide, California, and Sierra Nevada 

scales indicate that the distribution of northern flying squirrel populations in the Sierra Nevada is 

stable. 

Relationship of Project-Level Habitat Impacts to Bioregional-Scale Trends. 

California spotted owl/American marten/Northern flying squirrel. The change in 

canopy closure of 5 acres out of 1,006,923 acres of late seral closed canopy coniferous forest 

habitat available throughout the Sierra Nevada forests would not alter the existing trend in the 

habitat, nor would it lead to a change in the distribution of California spotted owl across the 

Sierra Nevada bioregion. This projected change represents less than 0.0005% of the available 

habitat within the 10 Sierra Nevada forests.

Snags in Green Forest Ecosystem Component (Hairy woodpecker) 

Habitat/Species Relationship.

The hairy woodpecker was selected as the MIS for the ecosystem component of snags in green 

forests. Medium (dbh between 15 to 30 inches) and large (diameter breast height greater than 30 

inches) snags are most important. The hairy woodpecker uses stands of large, mature trees and 

snags of sparse to intermediate density; cover is also provided by tree cavities (CDFG 2005). 

Mature timber and dead snags or trees of moderate to large size are apparently more important 

than tree species (Siegel and DeSante 1999). 

Project-level Effects Analysis – Snags in Green Forest Ecosystem 

Component 

Current Condition of the Habitat Factor(s) in the Project Area: 

Prior to 2004, the forest implemented S&Gs from the Sierra NF LRMP (1992) which called for 

maintaining an average of 1.5 snags per acre in sizes 15-24” dbh and an average of 0.5 snags per 

acre in sizes 25” dbh or greater. All countable snags had to be 20’ or greater height (S&G #64, p. 

4-16). Additionally, a sufficient number of live trees had to be left in appropriate sizes to serve as 

replacement snags. The SNFPA (2004), modified the SNF LRMP with the followings guidelines: 

(1) in westside mixed conifer and ponderosa pine types, Forests should maintain four of the 

largest snags per acre, (2) in red fir forest type, they should maintain six of the largest snags per 

acre, (3) in eastside pine and mixed conifer forest types, they should maintain three of the largest 

snags per acre, and (4) in westside hardwood ecosystems, they should maintain four of the largest 

snags (hardwood or conifer) per acre, or if standing live hardwood trees lack dead branches, they 

should maintain six of the largest snags per acre (S&G #11, p. 51).

Current conditions within the project boundary meet and in some areas exceed the snag and down 

woody material retention guidelines laid forth in the 2004 SNFPA. The following standards and 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 144 Chapter 3

guidelines for Snags and Down Woody Material apply to this project (SNFPA FSEIS ROD Pg. 

51-52):

Down Woody Material: “Determine down woody material retention levels on an individual 

project basis, based on desired conditions. Emphasize retention of wood in the largest size 

classes and in decay classes 1, 2, and 3. Consider the effects of follow-up prescribed fire in 

achieving desired down woody material retention levels.” Typically 10-20 tons of down woody 

material per acre is acceptable from a fuel loading standpoint, and would retain sufficient material 

to provide for post-treatment habitat for down woody utilizing species, based on extrapolation of 

pre-European stand conditions. 

Snag Retention: “Design projects to implement and sustain a generally continuous supply of 

snags and live decadent trees suitable for cavity nesting wildlife across a landscape. Retain some 

mid- and large-diameter live trees that are currently in decline, have substantial wood defect, or 

that have desirable characteristics (teakettle branches, large diameter broken top, large cavities in 

the bole) to serve as future replacement snags and to provide nesting structure. When 

determining snag retention levels and locations, consider land allocation, desired condition, 

landscape position, potential prescribed burning and fire suppression line locations, and site 

conditions (such as riparian areas and ridge tops), avoiding uniformity across large areas.

The general guidelines for large-snag retention are as follows:

Westside mixed conifer and ponderosa pine types – four of the largest snags per acre.

Use snags larger than 15 inches dbh to meet this guideline. Snags should be clumped and 

distributed irregularly across the treatment units. Consider leaving fewer snags strategically 

located in treatment areas within the WUI. When some snags are expected to be lost due to 

hazard removal or the effects of prescribed fire, consider these potential losses during project 

planning to achieve desired snag retention levels.”

No snags are proposed to be removed in the project unless they meet the definition of a 

danger tree and are felled for safety (US Forest Service 2011). 

Additional design criteria common to all action alternatives includes:

1. Maintain highest canopy cover possible to meet the prescription within stands, aim for 50-

60% immediately post-harvest.

2. Thinning would not remove any trees larger than 30”dbh. 

3. Retain groups of larger trees (greater than 30”) at the rate of approximately one group per 

2.5-3.5 acres. Ideally these groups would contain “defect” trees, those that have cavity 

and platform creating defects (mistletoe, rot, fork topped, broken limbs and tops) for den 

and rest sites.

4. Retain largest snags and logs. Do not remove snags unless it is safety concern (project does 

not propose to remove snags). Retain largest logs to maximum allowed by fuel loading 

standards.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 145 Chapter 3

Alternative 1 (No Action)

Direct and Indirect Effects to Habitat. There would be no direct effects to snags in 

green forest habitat under this alternative. There is a potential for indirect effects under the no 

action alternative as the continued immediate threat of wildfire would remain unabated. In failing 

to make an attempt at density management of the stands, the eventual changes through drought 

stress and subsequent insect and disease mortality acceleration would exacerbate the threat of 

stand replacing fire. Such a wildfire would convert current snags in green forest habitat to snags 

in burned forest habitat. Additionally, the high probability of a drying climate change throughout 

the Western United States would have the potential to further compound these effects (USDA 

Forest Service 2011, 2011c, 2011d). 

Cumulative Effects to Habitat in the Analysis Area and Conclusion. 

There are no direct or indirect effects of the no action alternative for the project, therefore there 

are no cumulative effects for Alternative 1.

Alternative 2 (Proposed Action)

Direct, Indirect, and Cumulative Effects to Habitat and Conclusion. There 

would be minimal direct effects to snags under the Alternative 2 proposed action. Currently, 

across the treatment units, there are an average of 11 standing conifer snags per acre that are ≥10” 

dbh. Of those standing conifer snags, a total of four per acre are ≥16” dbh. No snags are proposed 

for removal by any of the action alternatives in the project, except for in rare cases where they 

constitute a safety concern. Current conditions within the project boundary and cumulative effects 

boundary meet and in some areas exceed the snag and down woody material retention guidelines 

laid forth in the 2004 SNFPA. It is reasonable to assume that a few stage 4 through 7 snags may 

be lost in prescribed fire treatment areas, however this treatment is also likely to produce stage 2 

and 3 snags. It is not expected that removal of snags that pose a safety concern along roadways or 

in treatment units would alter the available snag levels below the current standards set forth in the 

2004 SNFPA ROD. 

Alternative 3 

Direct, Indirect, and Cumulative Effects to Habitat and Conclusion. 

The proposed treatments for forest snags within Alternative 3 are the same as for Alternative 2, 

therefore the direct, indirect, and cumulative effects for Alternative 3 would be the same as those 

discussed under the proposed action.

Summary of Hairy Woodpecker Status and Trend at the Bioregional Scale

The Sierra NF LRMP (as amended by the SNF MIS Amendment) requires bioregional-scale 

habitat and distribution population monitoring for the hairy woodpecker; hence, the snag effects 

analysis for the project must be informed by both habitat and distribution population monitoring 

data. The sections below summarize the habitat and distribution population status and trend data 

for the hairy woodpecker. This information is drawn from the detailed information on habitat and 

distribution population trends in the 2010 SNF Bioregional MIS Report (USDA Forest Service 

2010a), which is hereby incorporated by reference.

Ecosystem Component Status and Trend. The current average number of medium-sized and 

large-sized snags (> 15" dbh, all decay classes) per acre across major coniferous and hardwood 

forest types (westside mixed conifer, ponderosa pine, white fir, productive hardwoods, red fir, 

eastside pine) in the Sierra Nevada ranges from 1.5 per acre in eastside pine to 9.1 per acre in 
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Sierra National Forest – 146 Chapter 3

white fir. In 2008, snags in these types ranged from 1.4 per acre in eastside pine to 8.3 per acre in 

white fir (USDA Forest Service 2008). 

Data from the early-to-mid 2000s were compared with the current data to calculate the trend in 

total snags per acre by Regional forest type for the 10 Sierra Nevada national forests and indicate 

that, during this period, snags per acre increased within westside mixed conifer (+0.76), white fir 

(+2.66), red fir (+1.25), and productive hardwoods (+0.35) and decreased within ponderosa pine 

(-0.16) and eastside pine (-0.14).

Detailed information by forest type, snag size and snag decay class can be found in the 2010 SNF 

Bioregional MIS Report (USDA Forest Service 2010a).

Population Status and Trend. Monitoring of the hairy woodpecker across the ten National 

Forests in the Sierra Nevada has been conducted since 2009 in partnership with PRBO 

Conservation Science, as part of a monitoring effort that also includes mountain quail, fox 

sparrow, and yellow warbler (USDA Forest Service 2010a, 

http://data.prbo.org/partners/usfs/snmis/). Hairy woodpeckers were detected on 15.1% of 1659 

point counts (and 25.2% of 424 playback points) in 2009 and 16.7% of 2266 point counts (and 

25.6% of 492 playback points) in 2010, with detections on all 10 national forests in both years. 

The average abundance (number of individuals recorded on passive point count surveys) was 

0.116 in 2009 and 0.107 in 2010. These data indicate that the hairy woodpecker continues to be 

distributed across the 10 Sierra Nevada National Forests. In addition, the hairy woodpeckers 

continue to be monitored and surveyed in the Sierra Nevada at various sample locations by avian 

point count and breeding bird survey protocols. These are summarized in the 2008 Bioregional 

Monitoring Report (USDA Forest Service 2008). Current data at the range wide, California, and 

Sierra Nevada scales indicate that the distribution of hairy woodpecker populations in the Sierra 

Nevada is stable. 

Relationship of Project-Level Habitat Impacts to Bioregional-Scale Hairy Woodpecker 

Trend. The 7,061 acres of mid and late seral forest habitat that provides the green forest snag 

component within the project boundary account for less than 0.2% of the 3,835,000 acres of mid 

and late seral coniferous forest habitat within the Sierra Nevada bioregion. Therefore, none of the 

alternatives would alter the bioregional trend in the snag component of the coniferous forest 

habitat, nor would they lead to a change in the distribution of the hairy woodpecker across the 

Sierra Nevada bioregion.

Summary and Conclusions

There are no direct effects to any MIS habitat within the Greys Mountain Project area for 

Alternative 1: No Action. However, there may be indirect effects to MIS habitat if an 

uncharacteristically severe wildfire was to occur, and no action had been taken to lessen some of 

the fuel loading within the project area.

If Alternative 2 were selected, there would be alterations to canopy closure on 121 acres of MIS 

habitat (approximately 4% of the treatment area) including shrubland, mid seral coniferous forest, 

and late seral closed canopy coniferous forest. These predicted changes are spread across the 

treatment units, and would not alter the existing trend in any of the habitats at the project-level, 

nor would it lead to a change in the distribution of the fox sparrow, mountain quail, California 

spotted owl, american marten, northern flying squirrel, or hairy woodpecker across the Sierra 

Nevada bioregion.

If Alternative 3 were selected, there would be alterations to canopy closure on 53 acres of MIS 

habitat (approximately 2% of the treatment area) including shrubland, mid seral coniferous forest, 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 147 Chapter 3

and late seral closed canopy coniferous forest. These predicted changes are spread across the 

treatment units, and would not alter the existing trend in any of the habitats at the project-level, 

nor would it lead to a change in the distribution of the fox sparrow, mountain quail, California 

spotted owl, american marten, northern flying squirrel, or hairy woodpecker across the Sierra 

Nevada bioregion.
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Aquatic Wildlife and Management Indicator 

Species____________________________________

The direct, indirect and cumulative effects to the Aquatic Wildlife Management Indicator 

Species are summarized from the Aquatic Wildlife Management Indicator 

Species (MIS) report for the Grey’s Mountain Ecological Restoration Project (Strand P., 2012)

The Affected Environment

This section describes existing condition based on data collected within the aquatic analysis area.

Existing Condition 

The following tables summarize information within the analysis area subwatersheds. Table 19

presents stream channel survey information. Of stream channels evaluated within the analysis 

area, approximately 10 miles were channel types considered moderately to highly sensitive to 

disturbance. Of these 10 miles, approximately 1.2 miles were evaluated as being in Poor 

condition. The Project Hydrology Report (Stone 2011) indicates there is evidence that past 

activities have caused watershed degradation, but overall the channels and subdrainages in the 

project area appear to be recovering and reaching a state of equilibrium. The current condition for 

most of the stream reaches is good or fair for channel stability using modified Pfankuch (Rosgen 

1996), which has been corroborated with Stream Condition Inventory data. There are, however, 

several areas (subwatersheds 503.0056 and 504.0061) within the proposed project boundary that 

are unstable and sensitive to disturbance. Subdrainage 503.0056 has a sub-basin where evidence 

of excess sediment in the stream channel was observed during interdisciplinary field review. 

Table 19. Summary of subwatershed conditions. *From project hydrologist review (Stone 

2011).

Subwatershed Acres

Rosgen 

Channel 

Typing 

(mi)

Rosgen Sensitivity (mi)

Poor 

Stabilit

y (mi)

Channel 

Sensitivity

*

Pfankuch 

stability 

(Rosgen 

modified)*

Low 

(mi)

Moderat

e (mi)

High 

(mi)

503.0056 1211 Extreme Poor - - - -

503.0057 1246 - - - - - - -

503.3002 2472 - - - 0.34 - - -

503.3051 1484 - - 0.34 0.24 0.5 - -

504.0011 1972 - - 0.74 - - - -

504.0012 3033 Low Good - 2.59 - 3.56 -

504.0013 1369 Low Fair 6.15 - - - -

504.0014 1078 Very High Good - - - - -

504.0015 455 Extreme Good - - - - -

504.0059 1866 Very low/ 

Moderate - - 11.1 1.88 2.07 0.26

504.0060 2737 Very low Fair/Good 15.05 - - - -

504.0061 1262 Moderate Poor - - - - -

504.3001 1496 - - - 1.62 1 0.5 -
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504.4051 1534 Very High Good 3.12 - - - 0.93

Table 20 displays miles of perennial streams, miles occupied by resident trout, 2009 mean 

summer (7/15-9/15) water temperature, and maximum daily mean water temperature from the 

larger perennial streams. Streams in the analysis area meet the Desired Condition for water 

temperature identified in the Willow Creek Landscape Analysis (USDA-Forest Service 1995) and 

are within the expected summer temperature range (< 21o C) for the zoogeographic province 

described by Moyle (2002), which should be appropriate for native aquatic/riparian species.

Table 20. Perennial streams (mi); resident trout occupancy (mi), mean summer water 

temperature (period 7/15-9/15), and maximum daily temperature (greatest mean daily 

period 7/15/9/15).

Subwatershed Acres Stream Drainage

Per. 

Stream 

(mi)

Fish 

Occupied 

(mi)

Mean 

Summer 

Temp 

(C)

Max 

Daily 

Mean(C)

503.0056 1211 Unnamed trib. to Nelder 

Creek 1.8 0.0 - -

503.0057 1246 Redwood Creek 0.5 0.0 - -

503.3002 2472 California Creek 3.2 2.5 - -

503.3051 1484 Nelder Creek 2.9 2.8 14.8 17.1

504.0011 1972 Slide Creek 2.2 0.0 - -

504.0012 3033 Chilkoot Creek 5.6 5.3 14.2 16.3

504.0013 1369 Unnamed trib. to North 

Fork Willow Creek 2.3 1.6 - -

504.0014 1078 Soquel Creek 2.1 0.8 12.2 13.3

504.0015 455 Unnamed trib. to North 

Fork Willow Creek 0.5 0.0 - -

504.0059 1866 North Fork Willow Creek 3.9 3.9 17.3 19.7

504.0060 2737 North Fork Willow Creek 5.1 4.9 16.6 18.4

504.0061 1262 North Fork Willow Creek 4.8 3.6 12 13.9

504.3001 1496 Pines Creek 2.0 0.9 14.9 15.8

504.4051 1534 Unnamed trib. to North 

Fork Willow Creek 0.7 0.0 12.6 14.5

Species Accounts and Status

The following provides summarized information on aquatic/riparian threatened, endangered, 

candidate, and Forest Service sensitive (FSS) species that are either known to occur or have 

potential habitat within the analysis area, along with the system used to quantify and evaluate 

potential habitat (CWHR). Complete descriptions and analysis are available in the project 

aquatic/riparian species biological assessment/ evaluation (Strand 2011). Species lists are based 

on the May 12, 2011 online database of federally threatened, endangered, proposed, and 

candidate species for the Sierra National Forest from the U.S. Department of the Interior (USDA) 
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Sierra National Forest – 150 Chapter 3

Fish and Wildlife Service (USFWS; http://sacramento.fws.gov/es/spp_list.htm). The U.S. 

Department of Agriculture (USDA) Forest Service’s sensitive species list is based on the Pacific 

Southwest Region’s list of June 10, 1998, as amended on March 6, 2001 and May 7, 2003. These 

lists are the most current versions for the Sierra National Forest.

Further analysis is presented to determine the effects from the Greys Mountain Project on the 

following threatened (T), endangered (E), proposed (P), candidate (C), and/or Forest Service 

Sensitive (FSS) aquatic species, which have potential habitat within or adjacent to the aquatic 

analysis area: 

FYLF (FSS), Rana boylii

Western pond turtle (FSS), Clemmys marmorata (Subspecies marmorata and pallida)

Mountain yellow-legged frog (C/FSS), Rana muscosa (=mountain yellow-legged frog, Rana 

sierrae)

Yosemite toad (C/FSS), Bufo canorus

Habitat Suitability

The CWHR (CDFG 2008) was used to evaluate species habitat quantity and quality. The CWHR 

System contains life history, habitat relationships, and management information for amphibians 

and reptiles occurring in California. Suitable habitats for the species are described within the 

CWHR and suitability ratings for Reproduction, Cover, and Feeding are provided. Ratings are 

provided for habitat values as High, Medium, Low, or Unsuitable as described in the following:

High: Habitat suitability rating where habitat is optimal for species occurrence; habitat can 

support relatively high population densities at high frequencies. Suitability index value = 1.00. 

Medium: Habitat suitability rating where habitat is suitable for species occurrence; habitat can 

support relatively moderate population densities at moderate frequencies. Suitability index value 

= 0.66.

Low: Habitat suitability rating where habitat is marginal for species occurrence; habitat can 

support relatively low population densities at low frequencies. Suitability index value = 0.33.

Unsuitable: Habitat stage is unsuitable for species occurrence, and the species where habitat is 

rated unsuitable is not expected to reliably occur in the habitat. Suitability index value = 0.00.

Foothill Yellow-Legged Frog

Distribution: Historically, FYLFs occurred between sea level and 6,000 feet in most Pacific 

drainages west of the Sierra-Cascade crest from the Santiam River, Marion County, Oregon, to 

the San Gabriel Drainage, Los Angeles County, California (Hayes and Jennings 1988). 

Life History: Breeding occurs in shallow, slow flowing water (with at least some pebble and 

cobble substrate) between March and June after high flows have receded. Breeding generally 

occurs in perennial streams defined by some shading (> 20%), water temperatures not exceeding 

20°C for egg-laying and larval development, shallow riffles (< 0.21 m), and cobble or larger 

substrates (CDFG 2008). Eggs hatch in 5 to 30 days and tadpoles transform in about 15 weeks, 

from July to September. 

During breeding season and in the summer, FYLF are rarely encountered far from permanent 

water. During the winter, FYLF have been observed in abandoned rodent burrows and under logs 

as far as 100 meters (328 feet) from a stream (Zeiner et al. 1988). FYLF usually reach sexual 

maturity between one to two years, although some individuals may reproduce as early as six 

months after metamorphosis. Diet consists of a wide variety of invertebrates.
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Status: Jennings (1996) indicates that FYLF no longer occur within 45% of historic habitat in 

California, and has disappeared from 66% of its historic habitat within the Sierra Nevada 

mountain range. The Pacific Southwest Region of the Forest Service designated the FYLF as a 

sensitive species in 1998. 

Occurrence in the Analysis Area: There is currently one known population of FYLF on the Sierra 

National Forest (Jose Basin – San Joaquin drainage), approximately 15 miles from the closest 

portion of the analysis area. Neither the CNNDB nor the Museum of Vertebrate Zoology 

((MVZ); Berkeley, California) indicate FYLF specimens from the analysis area, and USFS 

surveys have not detected them. 

Potential Habitat: The CWHR (CDFG 2008) notes that highly suitable habitats for this species are 

riverine and valley/foothill riparian with mostly submerged and flooded gravels, cobble, boulders, 

and bedrock. Potential suitable habitat for the FYLF was identified from GIS using perennial 

(stream order 4 and greater) streams below 5,000 feet in elevation with a 165-foot dispersal area 

on each side of the stream. The essential elements for the species are indicated to be algae, 

invertebrates, lithic (rocky substrate), and water. Within the analysis area there are approximately 

19 miles of potential habitat providing approximately 745 acres of habitat. Potential habitat 

occurs within subwatersheds 503.0056; 504.0011; 504.0012; 504.013; 504.0059; 504.0060; and 

504.3001.

The CWHR habitat values for the acres of potential habitat for breeding, cover, and feeding 

indicates that most (80%) the habitat in the analysis area is of Low or No quality for FYLF.

Western pond turtle

Distribution: The westside central Sierra Nevada mountain range is an area of overlap between 

two pond turtle subspecies, Actinemys marmorata (northwestern pond turtle) and Actinemys 

marmorata pallida (southwestern pond turtle). These pond turtles, collectively known as western 

pond turtles (WPT), are found from sea level to 4,690 feet in elevation. Historically, WPT 

occurred along the west slope of Cascade/Sierra Nevada mountain ranges from the Columbia 

River to northern Baja California. 

Life History: Across the Sierra National Forest it appears mating occurs in late April to early 

May (Holland 1991). Nesting extends from late April through August (Holland ibid) depending 

on the latitude, with a peak from late May to early July. Females may travel along a waterway as 

far as 1.2 miles (2 km) to distant nesting areas if suitable nesting habitat is not available locally 

(Rathbun et al. 1993). Nesting is favored at unshaded south facing slopes, with clay/silty soils. 

Clutch size examined by Holland (1991) ranged from 1-13 eggs. Eggs hatched between 80-126 

days. Young WPT are believed to over-winter in the nest. Hatchlings out of the nest occupy 

shallow water habitats where they feed on nekton. 

WPT forage early in the morning and then bask on logs or rocks intermittently. During the 

summer, turtles may forage in the late afternoon or early evening. WPT are believed to be 

relatively long lived with recaptures of marked specimens exceeding 40 years.

Status: In 1992 the USFWS was petitioned to list WPT under the ESA (USDSI-USFWS 1992). 

Following review, the USFWS declined to list the species. The Pacific Southwest Region of the 

Forest Service designated the western pond turtle as a sensitive species in 1993. Bury and 

Germano (2008) note that WPT abundance appears to be declining in the northern and southern 

portions of the species range, but not in the core of the range from central California to southern 

Oregon

Occurrence in the Analysis Area: Surveys for WPT have been conducted between 1995 and 2011. 

WPT have not been detected within the aquatic analysis area, nor are there any records of the 

species in the CNDDB or the MVZ databases for this area. 
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Potential Habitat across the Sierra National Forest: For the purposes of this analysis, potential 

habitat within the analysis area was evaluated as perennial (stream order 4 and greater) streams 

and lakes and ponds below 5000 feet elevation. Terrestrial habitat used for breeding or a 

movement corridor of 325 feet to either side of the channels and around lakes/ponds defines 

potential habitat (CDFG 2008). Within the analysis area there are approximately 19 miles of 

potentially suitable stream habitat. Potential habitat within the analysis area has been projected 

using GIS based on CWHR criteria. There approximately 1,430 acres of potential habitat within 

the analysis area. Water and Slow Water are identified as essential elements of habitat. The 

potential habitat occurs within subwatersheds 503.0056; 504.0011; 504.0012; 504.013; 504.0059; 

504.0060; and 504.3001.

The CWHR habitat values for the acres of potential WPT habitat for breeding, cover, and feeding 

indicate most of the habitat (89%) in the analysis area is generally of Low or No quality for WPT.

Sierra Nevada yellow-legged frog (mountain yellow-legged frog)

Distribution: The Sierra Nevada MYLF occurs at high elevation (4,500-12,000 ft) only in the 

Sierra Nevada Mountains of California (CDFG 2005). DNA sequencing by Vredenburg et al. 

(2007) suggest two species within the historic range of MYLF. R. muscosa (Sierra Madre yellowlegged frog) would apply to populations south of the divide between the Middle and South Forks 

of the Kings River. Populations to the north (including the analysis area) would be considered R. 

sierrae (Sierra Nevada yellow-legged frog). The FSS species list and the USFWS continue to 

refer to the species as MYLF and this evaluation includes that nomenclature. 

Life History: The MYLF is diurnal and is seldom far from water. The species prefers well 

illuminated lakes and tarns, sloping banks of meadow streams, riverbanks, and isolated pools. At 

high elevations, breeding occurs between May and August as soon as the meadows and lakes are 

free of snow and ice (CDFG 2008). In lower elevations breeding occurs between March and June 

once high water in streams subsides. Following mating, the female deposits their 30-400 eggs in 

clusters submerged along stream banks or on vegetation and tadpoles develop after 2-3 weeks. 

Tadpoles maintain a relatively high body temperature by selecting warmer microhabitats 

(margins of water bodies) where they may congregate in the hundreds feeding on algae. Tadpoles 

may require up to three years before metamorphosis. Following metamorphosis, it can take up to 

four years for juveniles to reach sexual maturity. MYLF may move several hundred meters 

between breeding, feeding, and overwintering habitats (Pope and Matthews 2001). They tend to 

follow lake shores and streams, but will move short distances across dry land (Matthews and 

Pope 1999). Since the adults and tadpoles overwinter underwater, at high elevations they are 

restricted to relatively deep lakes (over five feet deep) which do not freeze solid in winter. Overwintering of tadpoles in an aquatic habitat makes them more susceptible to fish predation and 

diseases. 

Status: Vredenburg et al. (2007) report that MYLF no longer occur at more than 92% of its 

historic sites, in the Sierra Nevada. The USDI-USFWS (2003) found that listing was warranted as 

threatened or endangered for this species. However the listing was precluded at the time based on 

other higher priority issues. It is designated as a candidate species and is currently managed as 

sensitive by the USFS. 

Species Occurrence in the Analysis Area: On the Sierra National Forest there are 40 known 

locations currently occupied by MYLF. The species is known to occur at two sites within the 

aquatic analysis area. Habitat adjacent to both sites was surveyed to identify the extent of species 

occupancy and the species was not detected within or adjacent to any proposed treatment area. 

There are no records of the species occurring within the aquatic analysis area located in either the 

CNDDB or the MVZ databases.
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Potential Habitat: Habitat for MYLF was evaluated as the perennial streams and lakes at or above 

5,000 feet in elevation. Potential habitat was determined by GIS within the analysis area. There is 

approximately 19 miles of perennial stream habitat, and 55 acres of pond and lake habitat. An 

estimated acreage of suitable habitat was derived from the total miles of stream with a 165-foot 

habitat on each bank (CDFG 2008) and the total acres of lake/pond habitat with a 165-foot 

dispersal area. There are approximately 810 acres of potential suitable habitat for this species 

within the aquatic analysis area. 

The CWHR habitat values for the acres of potential MYLF habitat for Breeding, Cover, and 

Feeding indicate most the habitat in the analysis area (81%) is of Low quality for MYLF.

Yosemite toad 

Distribution: The original range of the YT extends from Ebbetts Pass in Alpine County to south 

of Kaiser Pass and Evolution Lake in Fresno County (CDFG 2008) above 6000 feet elevation. 

However, populations have been found as far south as Spanish Mountain on the Sierra National. 

Life History: YT breed in shallow pools and small, slow moving, shallow streams usually in 

meadows. Movement to and from breeding sites could be extensive, including travel over 

snowfields from over-winter hibernation sites in forested areas (CDFG 2008). Males arrive at 

breeding pools several days before females. Breeding takes place from mid-May to mid-August. 

Males appear to outnumber females at breeding sites, and females may only breed once in three 

years. Eggs are laid in single or double strands, typically in pools or streams not more than three 

inches deep with a loose silt substrate. A single female lays an estimated 1,500 to 2,000 eggs. 

Individual males only stay at breeding ponds for a week or two, and females leave shortly after 

breeding. Eggs hatch in about 10-12 days, and tadpoles metamorphose seven to nine weeks after 

the eggs are laid (USDI-USFWS 2002a). 

After breeding both sexes were thought to remain in meadow areas to feed for two to three 

months before hibernating (Kagarise Sherman and Morton 1984), although recent studies indicate 

adults may move several hundred meters from meadows to upland foraging sites (Martin 2008; 

Liang 2010). Seasonal variation in home range size is considerable. Mullally (1953) estimated 

home ranges of some toads to be about 20 ft, but suggested that individuals may travel long 

distances away from water (CDFG 2008). Martin (2008) estimated home range at approximately 

8,460 m2 (2.1 ac), while Liang (2010) estimated mean home range of 27,430 m2 (6.8 ac), and 

noted female home range was more than 1-1/2 times larger than males. YTs seek cover during 

non-breeding seasons (approximately August to March) in abandoned rodent burrows or by 

moving into adjacent forested areas (CDFG 2008). 

YTs enter hibernation in late September or early October, and emerge in the spring. The toads 

utilize rodent burrows, crevices under rocks, or the base of willows for hibernation (Martin 2008). 

Males emerge from hibernation for breeding as soon as snow melts from meadows. Females first 

breed at 4-6 years and males at 3-5 years of age (USDI-USFWS 2002a).

Status: Current estimates indicate disappearance of YT from 47 to 69 percent from historical 

locations (USDI-USFWS 2002a). Remaining populations seem more scattered than they were 

historically and frequently appear to consist of small numbers of breeding adults. The USFWS 

(2002a) determined that listing was warranted as threatened or endangered for this species. 

However, the listing was precluded at the time based on other higher priority issues. The species 

is managed as sensitive by the USFS.

Occurrence in the Analysis Area: This species was inventoried for occurrence across the Sierra 

National Forest between 2002 and 2004. Potential breeding habitat in the aquatic analysis area 

was surveyed again in 2011. No breeding meadows or individual YT were identified within the 

aquatic analysis area during surveys. Three occupied meadows are located outside of the aquatic 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 154 Chapter 3

analysis area, but may have foraging habitat within the analysis area based on CWHR criteria 

using 900-meter as dispersal for the species. The CNDDB identifies a record of the species at 

Chilkoot Lake from 1946, but several surveys of the site in the last 10 years have not detected 

current occupancy at this site.

Potential Habitat: Suitable breeding habitat for this analysis was considered all meadows above 

6000 feet elevation. There are approximately 55 acres of meadow habitat above 6000 feet 

elevation within the aquatic analysis area. The CWHR model evaluates wet meadows as 

providing high quality habitat for YT Reproduction, Cover, and Feeding. YT habitat was 

evaluated as 900-meters surrounding meadows above 6000 feet elevation, which indicates 

approx. 4770 acres. 

The CWHR habitat values for the acres of occupied YT habitat for Breeding, Cover, and Feeding 

indicates that most the habitat in the analysis area is of Medium quality (71%). 

Aquatic Management Indicator Species

Benthic macro invertebrates and Pacific tree frog are aquatic/wet meadow associate Management 

Indicator Species (MIS) for the Sierra National Forest, and analyzed in a separate report (Strand 

2011a). Benthic Macro invertebrates (BMI) have been demonstrated to be very useful as 

indicators of water quality and aquatic habitat condition. They are sensitive to changes in water 

chemistry, temperature, and physical habitat. BMI are an important component of the food web, 

providing a food source for birds, mammals, amphibians, reptiles, and fish. The 37 miles of 

perennial streams represent potential habitat for BMI. The Pacific tree frog was selected as an 

MIS for wet meadow habitat in the Sierra Nevada. This broadly distributed species requires 

standing water for breeding; tadpoles require standing water for periods long enough to compete 

aquatic development, which can be as long as 3 or more months at high elevations in the Sierra 

Nevada (CDFG 2008). There are approximately132 acres of CWHR wet meadow habitat within 

the aquatic analysis area.

Habitat Summary Table

Table 21 summarizes potential habitat within the project aquatic analysis area for each the 

special interest herpetofauna. The CWHR essential habitat elements for the species are:

FYLF: algae, invertebrates, lithic, water

WPT: water, slow water

MYLF: algae, invertebrates (aquatic and terrestrial), water

YT: algae, invertebrates, water, slow water
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 155 Chapter 3

Table 21. Summary of potential habitat within project area subwatersheds (acres based on 

GIS).

Desired Condition

Desired conditions for the project area were described in the Willow Creek Landscape Analysis 

(USDA - Forest Service 1995). The watershed analysis established desired conditions for canopy 

cover and water temperature. Potential effects on water would also be analyzed since it was a 

common essential habitat element identified for each of the species under the CWHR. Water was 

identified as a CWHR essential element for all the special interest amphibians and reptiles and 

will be analyzed as Flow.

Riparian canopy cover is the degree to which tree canopies obscure the sky or block the sun. 

Stream shading would vary by the width of the stream channel, which is generally a function of 

stream order. Lower order channels may have nearly overlapping canopies while large rivers may 

have limited shading from riparian vegetation. Stream shading is important in maintaining stream 

temperature with the effect varying by the height of adjacent vegetation, proximity to the stream, 

topography, angle of the sun, and aspect. The desired condition identified in the Willow Creek 

Landscape Analysis (USDA-Forest Service 1995) is that riparian canopy cover be maintained at 

current levels.

Water temperature has multiple effects on aquatic/riparian species and their behavior. Thermal 

effects relate to directing behavior (trigger migration or spawning); controlling factors (time of 

incubation and emergence); lethal (lead to breakdown of homeostatic system and increased 

susceptibility to disease); and growth (metabolic regulation; affected by food supply). Elevation, 

aspect, stream width, channel roughness coefficient, riparian shading, solar radiation, air 

temperature, cloud cover, and stream discharge levels can affect water temperature. Of these 

elements, direct effects on riparian shading and indirect effects on stream discharge level could 

have the most effect on stream temperature (Beschta et al. 1987; Moore et al. 2005). The desired 

condition identified in the Willow Creek Landscape Analysis (USDA-Forest Service 1995) is that 

water temperatures to be less than 70o F (21o C).

Flow is synonymous with stream discharge. Flow is affected by climate, geology, elevation, 

aspect, vegetative cover, road patterns, and topography. Changes to stream flow patterns, such as 

alteration of the timing, duration, and magnitude of runoff, could affect both life history of 

aquatic/riparian species, along with habitat availability and suitability. Alteration could be 

expressed as a change in flow pattern, in bank and channel instabilities, widening of the stream 

channel, and undermining of bank trees resulting in increased levels of sediment. Widening of the 

Species Potential 

Habitat (ac)

CWHR 

Medium/Good (ac)

Foothill yellow-legged frog 745 147

Western pond turtle 1429 157

Sierra Nevada yellow-legged frog 811 151

Yosemite toad 4769 3419

Benthic macro invertebrates

(Riverine and lacustrine)

37 mi 37 mi

Pacific tree frog (wet meadow) 132 132
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 156 Chapter 3

stream channel would decrease the level of canopy cover over the stream. A desired condition for 

flow has not established as part of a Landscape Analysis, but timing and magnitude of flows 

should be consistent with life history needs for aquatic/riparian species.

Environmental Consequences

This section analyzes the effects (environmental consequences) from the proposed action and 

alternatives on the aquatic/riparian management indicator, threatened, endangered, proposed, 

candidate and sensitive species and their habitats. Effects of the action refers to the direct, 

indirect, and cumulative effects of an action on the species or critical habitat, together with the 

effects of other activities that are interrelated or interdependent with that action, that would be 

added to the environmental baseline. The environmental baseline includes the past and present 

impacts of all Federal, State, or private actions and other human activities in the action area, the

anticipated impacts of all proposed Federal projects in the action area that have already 

undergone formal or early section 7 consultation, and the impact of State or private actions which 

are contemporaneous with the consultation in process. 

Aquatic species live in a wide variety of wetland habitats, from subalpine meadows to highgradient streams. In general, the riparian condition, especially vegetation, is important for all 

aquatic organisms to complete their life cycles. These organisms benefit from the shade provided 

by riparian vegetation. In addition, most rely on both terrestrial and aquatic insects for food. 

Within the project area, all Class I stream channels (perennial steams; order 4 and higher) provide 

potential habitat for aquatic/riparian species. For herpetofauna, meadow edges, seeps and damp 

headwater areas as well as the riparian conservation areas surrounding streams also provide 

potential habitat.

Complete descriptions of project alternatives are available in Chapter 2 of this DEIS. The

combined treatments proposed for the action alternatives involve tree thinning; prescribed fire, 

including underburning, mastication, mechanical piling and pile burning; vegetative clearing for 

the stock drive; vegetative clearing at prehistoric and historic sites, removal of conifer 

encroaching meadows, stabilization of stream segments within meadows, restoration of a userdefined off highway vehicle route, road reconstruction and maintenance; along with temporary 

roads and skid trails. All these activities individually and together would have risks and both 

short-term and long-term effects on aquatic/riparian species. Numerous effects on aquatic habitat 

and species have been attributed to actions proposed under the project. The following general 

summarization of potential effects does not indicate they are currently occurring or anticipated 

within the analysis areas. 

Proposed management actions have the potential to directly alter stream shading (solar radiation); 

and indirectly or cumulatively alter water temperature; water quantity; water quality; sediment, 

nutrient, and litter inputs; woody debris; and channel structure. All of these elements can affect 

aquatic habitat and nutritional resources of aquatic organisms (Gregory et al. 1987; Dwire et al. 

2006). Pilliod et al. (2003) identify that amphibians may be directly affected by fire (mortality), 

and indirectly affected through alteration of habitat. Habitat alteration could include decreased 

cover, increased temperature, increased nutrients, sedimentation, alteration in woody debris, 

channel scour, or hydro period alteration.

Various life stages of resident herpetofauna utilize macro invertebrates as a food source and they 

represent a CWHR essential element. Macro invertebrates are recognized for their importance in 

the aquatic/riparian systems. Erman (1996) notes that springs, seeps, peat lands and small 

first/second order streams could contain rare or endemic invertebrates. Thus, if the project alters 

stream temperature, canopy cover, hydrologic regime, sediment inputs, seeps/springs/headwater 

areas, and nutrient cycling (LWD or litter inputs), it could affect aquatic/riparian species 

indirectly through affects to the invertebrate community. Project effects on BMI are evaluated as 

an aquatic MIS (Strand 2011a).
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 157 Chapter 3

Stream flow may increase as basal area (and evapotranspiration) declines, and peak flows can be 

indirectly affected by vegetation removal (Kattelmann 1996). Troendle (2001) indicated 

increased water yields following timber harvest, although treatments were primarily clearcuts 

rather than thinnings that are being proposed under the project. Alteration of the hydrologic 

regime (timing, duration or magnitude of flows) from the combined effects of silviculture and 

underburning could affect success of amphibians that breed in the spring. Should such an 

alteration occur, it could also result in channel down cutting, bank instabilities and degradation of 

aquatic habitat through additional accumulations of sediment in pool habitat and filling of 

interstitial spaces. In snow-dominated areas, nearly all of the change in flows would occur during 

spring runoff, and spring runoff may occur slightly sooner if reductions in canopy allow faster 

melting of the snowpack

Fire, both prescribed and wild, has potential to affect aquatic/riparian systems. Potential affects 

from prescribed fire have been identified as streambank stability, aquatic food webs, stream 

temperature, and large wood dynamics (Dwire et al. 2006; Bêche et al. 2005). High intensity fires 

can severely disrupt aquatic ecosystems, and that these affects can be prolonged. Specific 

influences may include decreased channel stability; greater and more variable stream discharge; 

altered woody debris delivery and storage; increased nutrient availability; higher sediment 

delivery and transport; and increased solar radiation and altered water temperature regime (Bisson 

et al. 2003; Dunham et al. 2003). 

Incomplete and Unavailable Information

There is limited information on fire history within the riparian areas in the west, but it is expected 

to vary from those experienced in upland areas (Dwire and Kauffman 2003; Bisson et al. 2003). 

Riparian areas differ from upland areas in topography, microclimate, geomorphology, and 

vegetation. Further they are characterized as having cooler air temperatures, lower daily 

maximum air temperatures, and higher relative humidity. These characteristics may contribute to 

higher moisture content of live and dead fuels, and riparian soils, which presumably lowers the 

intensity, severity and frequency of fire (Dwire and Kauffman 2003). The ecological diversity of 

riparian corridors is maintained by natural disturbance regimes including fire and fire-related 

flooding, debris flows, and landslides. Many species have adapted life histories that are shaped 

by, and may depend on disturbance events (Dunham et al. 2003; Bisson et al. 2003; Rieman et al. 

2005). Nakamura et al. (2007) note some success with reducing crown fire after thinning and 

burning for the Cone and Megram Fires. They also note that some fires are so large (McNally or 

Cedar Fires) that they would continue to burn through or around treatment areas. Analysis 

following the Angora Fire (USDA-Forest Service 2007), identified fire spread was facilitated in 

part by corridors provided in the no-treatment Streamside Environmental Zones.

Spatial and Temporal Context for Effects Analysis

The aquatic analysis area consists of 14 HUC8 subwatersheds that contain the proposed project. 

effects to CWHR habitat are considered under this assessment of consequences, as well as effects 

to aquatic indicators. Direct effects are caused by action and occur at the same time and place. 

Indirect effects are those that are caused by the action and are later in time, but still are 

reasonably certain to occur. Interrelated actions are those that are part of a larger action and 

depend on the larger action for their justification. Interdependent actions are those that have no 

independent utility apart from the action under consideration. Cumulative effects result from 

incremental impacts of the action when added to other past, present and reasonably foreseeable 

future actions
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 158 Chapter 3

Past, Present, and Foreseeable Activities Relevant to Cumulative Effects 

Analysis

A list of past, present, and reasonably foreseeable actions considered under this affects analysis is 

provided in Chapter 3 of this DEIS.

Alternative 1 – No Action

Alternative 1 is the no action alternative. Under the no action alternative, current 

approved management plans would continue to guide management of the aquatic analysis 

area. This includes all ongoing activities with existing decisions or permits that would not 

be changed if this alternative were selected including: roads and trails; plantation 

maintenance, cattle grazing, and recreation. The no action alternative, would not 

implement the project No project associated treatments would be implemented in any 

subwatershed as displayed in. Projected acres potentially affected habitat for 

herpetofauna is also displayed in Table 22
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 159 Chapter 3

Table 22. Activities proposed under Alternative 1

Subdrainage

503.0056503.0057503.3002503.3051504.0011504.0012504.0013504.0014504.0015504.0059504.0060504.0061504.3001504.4051

Tractor (ac) 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Rx Fire (ac) 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Mastication (ac) 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Hand Thin (ac) 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Subdrainage (ac) 1211 1246 2472 1484 1972 3033 1369 1078 455 1866 2737 1262 1496 1534

%Subdrainage 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Foothill yellow-legged 

frog 70 19 60 112 89 35 42 0 0 154 86 0 79 0

Ac. Treated 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Western pond turtle 138 38 114 221 178 56 75 0 0 304 151 0 156 0

Ac. Treated 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Mountain yellowlegged frog 0 0 65 4 0 264 48 81 18 0 113 188 0 30

Ac. Treated 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Yosemite toad 0 0 467 0 0 2146 584 170 50 0 0 179 0 1173

Ac. Treated 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Riverine/Lacustrine 

(mi) 1.8 0.5 3.2 2.9 2.2 5.6 2.3 2.1 0.5 3.9 5.1 4.8 2 0.7

Adjacent to treatment 

unit (mi) 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Wet Meadow (ac) 0 0 10 8 0 12 9 55 4 0 0 26 0 8

Treatments within 100 ft 

wet meadow (ac) 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 160 Chapter 3

Direct Effects 

There would be no direct effects on threatened, endangered, sensitive aquatic species or MIS 

habitat as a result of the implementation of Alternative 1. No fuels ladder reduction or 

underburning would occur under this alternative. No direct, indirect, or cumulative affects to 

riparian canopy cover would be anticipated from Alternative 1. Water temperature would meet 

the desired condition, while canopy cover would be expected to remain at current levels.

Indirect Effects 

There would be no anticipated indirect effects to special interest herpetofauna or MIS habitat as a 

result of the implementation of Alternative 1. Water temperature data collected from the project 

area in 2009 indicates it currently meets the desired condition. However, Pilliod et al. (2003)

suggest that no action may have consequences for amphibians due to overgrown forests changing 

the quality of amphibian habitat and increasing susceptibility for a high severity fire. Roads 

maintained by the U.S. Forest Service would remain in poor condition and contribute sediment to 

aquatic systems.

Cumulative Effects 

Past, present, and reasonably foreseeable actions are detailed in Table 9. Known activities 

occurring spatially and temporally within the within the analysis area are recreational use 

(campgrounds and off-highway vehicle routes), roads and trails; vegetation and fuels projects, 

cattle grazing, and fires. 

Recreation: There are approximately 35 miles of inventoried OHV routes within the aquatic 

analysis area, some which cross habitat for FSS herpetofauna. Slow moving species (such as 

reptiles and amphibians) are more susceptible to vehicle mortality because their life histories 

often involve migration between wetland and upland habitats (Trombulak and Frissell 2000). 

Bury et al. (1977) reported declines in individuals, diversity, density and biomass related to areas 

of off highway motor vehicle use. Alterations to terrestrial habitat may include, but are not 

limited to: reductions in riparian vegetation cover, introductions of non-native plant species and 

impacts to meadow hydrology. Alterations to aquatic habitat may include, but are not limited to: 

increased sedimentation, altered hydrology, and geomorphology. The Sierra National Forest has 

completed a Travel Management Plan (USDA – Forest Service 2010) that would eliminate crosscountry travel by OHVs, designate routes approved for OHV use, and establish a season of use. 

Approved routes require improvements to protect resources. This analysis considers the 21 miles 

of approved routes within the analysis area, under the Record of Decision for the Travel 

Management Plan. Approximately 1 mile of approved routes traverses potential habitat for all 

four species, representing less than 1 acre of direct overlap. Approximately 14 miles would be 

expected to continue to have effects within the short-term (10-year period).

Within the project analysis area there are three developed campgrounds, and several overflow 

camping areas. These facilities total approximately 30 acres. Some of the campgrounds and 

overflow areas are located adjacent to water, thus are within habitat for amphibians 

(approximately 23 acres MYLF habitat). Recreation activities include use of motor vehicles and 

dispersed camping. These activities have the potential to affect aquatic/riparian habitat through 

changes in hydrologic regime; site compaction; sediment contribution; loss of vegetation; or 

direct mortality (Bury et al. 1977). Amphibians and reptile species adjacent to campgrounds may 

be subject to handling; collection; consumption; or translocation (Maxwell and Hokit 1999). 

Increased mortality rates may result from pets accompanying recreationists, along with mortality 

associated with use areas from pets or predators (ravens, skunks, raccoons, coyotes or foxes) that 

may occur at greater frequency at these sites due to refuse. Ashton et al. (1997) note that areas of 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 161 Chapter 3

human influence can drive out larger predators. Thus, the numbers of small predators (such as 

ravens) may be supported at artificially high numbers near areas of increased human activities. 

Rainbow trout are stocked by the California Department of Fish and Game at several sites along 

Big Creek. The Sierra National Forest is consulted on CDFG stocking sites, which is 

discontinued on sites known to be occupied by aquatic/riparian TES amphibians.

Vegetation and Fuels Projects: Approximately 570 acres within the aquatic analysis area were 

masticated in 2010 under the Greys Mountain Plantation and Wild Stand Mastication Project to 

thin, release, and remove fuel ladders in densely vegetated stands. Stands were precommercially 

thinned within 20-40 year old plantations, with some segments of non-plantation included. 

Mastication occurred within approximately 2 acres of MYLF, and 120 acres of YT habitat. Use of 

heavy machinery can result in compaction and potentially stream channel disturbance. 

Mastication typically traverses a layer of treated vegetation that reduces potential effects related 

from compaction. Application of SMZs and implementation of BMPs reduces the risk of 

compaction, or project-associated erosion being transported to stream channels. 

Roads: The existing NFTS (approximately 100 miles in the aquatic analysis area) could result in 

mortality to aquatic/riparian species in a variety of ways including collisions and introduction of 

non-native species, and parasites or disease vectors. Forest system roads intercept approximately 

40 miles of habitat, representing four acres of FYLF; 11 acres of WPT; nine acres of MYLF; and 

52 acres of YT habitat. Slow moving species (such as reptiles and amphibians) are more 

susceptible to road mortality because their life histories often involve migration between wetland 

and upland habitats (Trombulak and Frissell 2000). Linear features, such as roads, represent both 

physical barriers as well as sites of direct morality. Collisions with vehicles have been 

documented in numerous different aquatic and riparian dependant species and they may even be 

particularly vulnerable to it (Trombulak and Frissell ibid). 

Cattle grazing: The aquatic analysis area includes portions of the Soquel, Central Camp, and 

Beasore allotments. There are approximately 1,520 acres of Primary Use Areas within the 

analysis area, which represents available forage. Primary Use Areas were defined as meadows 

(approx. 245 acres) buffered by 250 feet. The grazed meadows represent potential habitat for 

FYLF (two ac); WPT (six ac.); MYLF (42 ac.); and YT (53 acres). The stock drive to move cattle 

between lower elevation allotments to higher elevation areas traverses approximately 7.7 miles 

through the project area. There is approximately 0.3 miles of the stock drive passing through

potential habitat for MYLF. Periodic work of the stock drive to reduce vegetation on the edges of 

the stock drive is not anticipated to affect habitat.

Numerous effects on aquatic habitat and species have been attributed to “prolonged use” of 

riparian areas by cattle. Mention of these effects does not indicate that they are currently 

occurring or anticipated. Literature suggests potential effects from cattle grazing relating to 

channel function, water quantity, hydrologic alteration, and water quality. All of these factors 

could result in negative effects to habitat for herpetofauna. Some of the effects described in 

literature are noted as resulting from “heavy” or “overgrazing”. 

Cattle grazing is administered under U.S. Forest Service permits, which include compliance with 

standards and guidelines from the Sierra National Forest Land and Resources Management Plan 

(USDA – Forest Service 1992; 2001; 2004). The three allotments have completed NEPA analysis 

within the past five years. It is expected that cattle grazing is locally resulting in exposed 

streambanks and erosion. The project hydrology report (Stone 2011) describes current stream 

bank stability as generally in being in fair or better condition.

Climate Change: Climate change has been suggested as a contributing agent in the decline of 

amphibians (Pounds and Crump 1994; Stewart 1995; Pounds et al. 1999). The Species Survival 

Commission (2008) notes that over 50% of the amphibians may be potentially susceptible to 

climate change. Reaser and Blaustein (in Lannoo 2005) summarize that site specific review of 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 162 Chapter 3

amphibian declines indicate possible global changes, and that regional warming, increasing 

ultraviolet radiation, and diseases are a potential result of global change. California anticipates 

warmer temperatures, accompanied by altered patterns of precipitation and runoff related to 

climate change (DWR 2007). Annual runoff in the San Joaquin River basin has declined by 19% 

over the past 100 years, and projected precipitation alterations could reduce the snowpack by 

25% by the year 2050. 

It is expected that air temperatures and precipitation patterns may change within the aquatic 

analysis area over time. The project is within an elevational zone characterized as having 

warm/hot summers (varies by elevation) and cool winters. Most precipitation above 5500 feet 

falls in the form of snow from fall through spring. Change is expected to be reflected through an 

increase in daily maximum, minimums, and mean air temperatures, along with altered rainfall 

patterns. Meyer and Safford (2010) examined fire trends presented in Miller et al. (2009), and 

incorporated long-term weather stations within or adjacent to the Sierra National Forest to 

illustrate that mean annual temperature at Huntington Lake has increased by 1.8o F, with a mean 

minimum (nighttime) increase of 4o F since 1915. Utilizing information projected by Meyer and 

Safford, mean annual temperature increases by 0.3 o F; mean annual minimum temperature 

increases by 0.4 o F; and mean annual maximum temperature increases by 0.19 o F over the 10-

year period at Huntington Lake (7000 feet). 

Thompson (2005) summarizes that direct solar radiation has the greatest influence on water 

temperature, thus managing to maintain or improve shade is important to reduce heat flux. 

Precipitation changes would be expected to reflect a great deal of variability. Information from 

Meyer and Safford (ibid) project an increase in annual precipitation of 2.1 inches at Huntington 

Lake over the 10-year period, but the projections at Grant Grove in Kings Canyon National Park 

project no change. The North Fork Willow Creek drainage in the project area is influenced by 

snowmelt runoff. Spring runoff is occurring earlier in the year and fraction of runoff occurring in 

the spring is decreasing. With less snowfall expected to result from elevated air temperatures 

associated with climate change, it is likely that less water would be available during the late 

summer and that the water would be warmer than current conditions. An increasing snow level 

would reduce the amount of shallow pools during the springs which provide breeding habitat for 

YT. A similar effect to shallow lakes would reduce the suitability of habitat for MYLF, which 

could result in localized extirpations in a species with a high degree of site fidelity. 

Lind (2008) notes that amphibian and reptile populations respond to changes and variability in air 

or water temperature, precipitation, and the hydro-period of their environments. Over the shortterm (annually), these factors can influence reproductive success rates and survival to 

metamorphosis. Over the long term, the frequency and duration of extreme temperature and 

precipitation events can influence the persistence of populations and structure of metapopulations on the landscape. The net effect of less water and higher temperatures would be a 

reduction in the quantity and quality of aquatic/riparian habitat. Herpetofauna would likely be 

concentrated at sites where water is available, increasing their susceptibility to predators at these 

sites. The changing conditions of habitat would provide conditions more favorable for invasion 

by species currently occurring at lower elevational sites, and possibly an increase in non-native 

species. 

Alteration of the fire return interval: The USDI-USFWS (2002a) identified that “Fire suppression, 

and changes in fire frequency and hydrology, has probably contributed to the decline of YT

through habitat loss caused by conifer encroachment on meadows. Under natural conditions, 

conifers are excluded from meadows by fire and soils too saturated for their survival. But as 

conifers begin to encroach on a meadow, if they are not occasionally set back by fire, they 

transpire water out of the meadow, reducing the saturation of the soils, and facilitating further 

conifer encroachment. Therefore, some vegetation treatment may be needed to maintain or restore 

YT habitat.”
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 163 Chapter 3

The Greys Mountain Project is being proposed to reduce or modify the intensity and spread of 

wildland fires across the landscape and near communities, in this case Greys Mountain. 

Nakamura et al. (2007) noted some success with reducing crown fire after thinning and burning 

for the Cone and Megram Fires. They also note that some fires are so large (McNally or Cedar 

Fires) that would continue to burn through or around treatment areas. 

In the event of a wildfire there could be varied response depending on size and severity. A large, 

high severity fire could disrupt flow regime and alter stream channel dynamics. Soil water 

storage; base flow; streamflow regime; peak flow; water quality (sediment, temperature, pH, ash 

slurry); and chemical characteristics can be affected by wildfire (Neary et al. 2005). If a wildfire 

followed by a large precipitation event occurred, accelerated erosion and increased sedimentation 

would occur and sediment would be transported to the stream system via overland flow from 

burnt slopes and roads. Accumulations of sediment could reduce habitat for BMI. Vieira et al. 

(2004) also reported that a 100-year flood following the Dome wildfire (New Mexico) resulted in 

an almost total loss in density and taxon richness. 

Meyer and Safford’s (2010) review of fire literature indicates increases on fire frequency, size, 

total area burned and severity in the Sierra Nevada over the past 20-30 years. Since 2002 (year of 

Vegetation Typing), there has been not been any fire within the analysis area. There has been no 

overlap within potential habitat within the analysis area for any aquatic/riparian sensitive species 

since 1920. 

CWE Analysis: The CWE analysis in the Greys Mountain Hydrology Report notes that all of the 

subdrainages are considered sensitive to moderately sensitive to disturbance (i.e., 4 - 5% Lower 

TOC %). The baseline or existing condition of most of the subdrainages is below the Lower TOC 

%, but subdrainages 503.0056 and 503.3051 are over their Lower TOC %. The Project Hydrology 

Report also identifies that “Maintenance level 2 (“native surface”) roads throughout the project 

area are in moderate to poor condition and are hydrologically connected to the watersheds in 

which they are constructed. Many of these roads lack adequate drainage and have partially to 

completely blocked culverts that would require replacement.” No changes to Flow would be 

anticipated from Alternative 1.

Table 23 indicates that greatest potential effects to species habitat in the analysis area results from 

roads, cattle grazing and mastication. As noted under occurrences in the species accounts, there 

are no known sites occupied by FYLF, WPT, or YT within the aquatic analysis area. There would 

be no anticipated cumulative effects to these species as a result of the implementation of 

Alternative 1. Lacustrine/riverine and wet meadow habitats would be expected to remain stable. 

There are two known locations of MYLF within the analysis area. Project design criteria 

developed during NEPA analysis of the grazing allotments have been implemented to reduce 

potential conflicts between MYLF and effects from cattle grazing.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 164 Chapter 3

Table 23. Acres of habitat cumulatively affected under Alternative 1. (*lacustrine/riverine 

miles converted to acres assuming 9 ft wide stream)

Alternative 2 – Proposed Action

Table 24 below summarizes gross acres from proposed activities (net treatment acres 

would be less due to Controlled Areas; portions of treatment units lacking access or not 

requiring treatment).

Species

Potentia

l 

habitat 

(ac)

Grazing 

Meado

ws (ac)

Rec/OH

V 

Effected 

(ac)

Bass 

Lake 

Mast

. (ac)

Fire 

(ac)

Road

s

(ac)

Greys 

Moun

tain 

(ac)

Cum. 

Effect 

(ac)

% 

Habitat 

Affected

Foothill yellowlegged frog 745 2 0 0 0 4 0 6 1%

Western pond 

turtle 1429 6 0 0 0 11 0 17 1%

Mountain yellowlegged frog 811 42 23 2 0 9 0 76 9%

Yosemite toad 4769 53 0 121 0 53 0 227 5%

Lacustrine/riverine

* 40.5 4 1 0 0 0 0 5 12%

Wet meadow 132 132 0 0 0 2 0 132 100%
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 165 Chapter 3

Table 24 Gross acres from proposed activities by subwatershed

Subdrainage

503.0056503.0057503.3002503.3051504.0011504.0012504.0013504.0014504.0015504.0059504.0060504.0061504.3001504.4051

Totals

Thin or 

precommercial thin 

(ac)

160 0 11 19 120 235 187 88 248 73 982 301 50 74 2548

Rx Fire (ac) 190 0 0 0 0 13 84 0 0 0 233 0 0 0 520

Mastication (ac) 55 14 0 0 82 20 18 0 0 0 126 0 0 3 318

Hand Thin (ac) 24 0 13 15 0 0 10 0 0 40 19 0 4 0 125

Subdrainage (ac) 1211 1246 2472 1484 1972 3033 1369 1078 455 1866 2737 1262 1496 1534 23215

%Subdrainage 35% 1% 1% 2% 10% 9% 22% 8% 55% 6% 50% 24% 4% 5% 15%

Foothill yellowlegged frog (ac) 70 19 60 112 89 35 42 0 0 154 86 0 79 0 745

Ac. Treated 1 0 0 0 0 8 3 0 0 1 10 0 0 0 23

Western pond 

turtle (ac) 138 38 114 221 178 56 75 0 0 304 151 0 156 0 1429

Ac. Treated 11 0 0 0 0 27 10 0 0 5 21 0 0 0 74

Mountain yellowlegged frog (ac) 0 0 65 4 0 264 48 81 18 0 113 188 0 30 811

Ac. Treated 0 0 0 0 0 3 0 5 1 0 16 13 0 0 38

Yosemite toad 0 0 467 0 0 2146 584 170 50 0 0 179 0 1173 4769

Ac. Treated 0 0 0 0 0 25 28 0 10 0 0 31 0 77 170

Riverine/Lacustrine 

(mi) 1.8 0.5 3.2 2.9 2.2 5.6 2.3 2.1 0.5 3.9 5.1 4.8 2 0.7 37.3

Mi. adjacent 0.0 0.0 0.0 0.0 0.0 1.3 0.3 0.1 0.0 0.1 2.0 0.3 0.0 0.0 4.2

Wet meadow 0 0 10 8 0 12 9 55 4 0 0 26 0 8 132

Treatments within 

wet meadow SMZ 

(ac)

0 0 0 0 0 0 0 2.8 3.6 0 0 6.1 0 0 12.5
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 166 Chapter 3

Table 25. Alternative 2 activities (acreages approximations generated by GIS). Riverine/Lacustrine and wet meadow habitats have Class I SMZ 

buffers (100 feet) with no direct affects anticipated. Affected miles or acres reflect treatments in the outer 50 feet

Subdrainage

503.0056503.0057503.3002503.3051504.0011504.0012504.0013504.0014504.0015504.0059504.0060504.0061504.3001504.4051

Totals

Thin or precommercial 

thin (ac) 160 0 11 19 120 235 187 88 248 73 982 301 50 74 2548

Rx Fire (ac) 190 0 0 0 0 13 84 0 0 0 233 0 0 0 520

Mastication (ac) 55 14 0 0 82 20 18 0 0 0 126 0 0 3 318

Hand Thin (ac) 24 0 13 15 0 0 10 0 0 40 19 0 4 0 125

Subdrainage (ac) 1211 1246 2472 1484 1972 3033 1369 1078 455 1866 2737 1262 1496 1534 23215

%Subdrainage 35% 1% 1% 2% 10% 9% 22% 8% 55% 6% 50% 24% 4% 5% 15%

Foothill yellow-legged 

frog (ac) 70 19 60 112 89 35 42 0 0 154 86 0 79 0 745

Ac. Treated 1 0 0 0 0 8 3 0 0 1 10 0 0 0 23

Western pond turtle (ac) 138 38 114 221 178 56 75 0 0 304 151 0 156 0 1429

Ac. Treated 11 0 0 0 0 27 10 0 0 5 21 0 0 0 74

Mountain yellow-legged 

frog (ac) 0 0 65 4 0 264 48 81 18 0 113 188 0 30 811

Ac. Treated 0 0 0 0 0 3 0 5 1 0 16 13 0 0 38

Yosemite toad 0 0 467 0 0 2146 584 170 50 0 0 179 0 1173 4769

Ac. Treated 0 0 0 0 0 25 28 0 10 0 0 31 0 77 170

Riverine/Lacustrine (mi) 1.8 0.5 3.2 2.9 2.2 5.6 2.3 2.1 0.5 3.9 5.1 4.8 2 0.7 37.3

Mi. adjacent 0.0 0.0 0.0 0.0 0.0 1.3 0.3 0.1 0.0 0.1 2.0 0.3 0.0 0.0 4.2

Wet meadow 0 0 10 8 0 12 9 55 4 0 0 26 0 8 132

Treatments within wet 

meadow SMZ (ac) 0 0 0 0 0 0 0 2.8 3.6 0 0 6.1 0 0 12.5
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 167 Chapter 3

Design Features and Mitigation Measures 

It is expected that the project design features described below would provide protection to both 

MIS habitat types and for aquatic/riparian special interest species.

Table 26 displays habitat potentially directly affected by the proposed action. There are 

approximately13 acres of proposed treatment adjacent (within 100 feet), but not within wet 

meadows. Similarly, there are approximately 4 miles of proposed treatments within Class I SMZs 

along perennial stream channels.

Table 26. Overlap of Proposed Treatment Areas and Potential Habitat for species. Thinned 

includes hand thin. (*lacustrine/riverine miles converted to acres assuming approximately 9 

ft wide stream)

Foothill yellow-legged frog: There are approximately 745 acres of potential FYLF habitat within 

the aquatic analysis area. Alternative 2 would affect approximately 23 acres of potential habitat. 

Most of the effected acres would be subject to thinning (13 acres) and prescribed fire (10 acres). 

FYLF was not detected during surveys in the analysis area and the project area is not within 

dispersal distance of any known population. 

Western pond turtle: There are approximately 1,430 acres of potential WPT habitat within the 

aquatic analysis area. Alternative 2 would affect approximately 74 acres of potential habitat. Most 

of the effected acres would be subject to thinning (52 acres) and prescribed fire (21 acres). WPT 

was not detected during surveys in the analysis area and the project area is not within dispersal 

distance of any known population. 

Mountain yellow-legged frog: There are approximately 810 acres of MYLF potential habitat 

within the aquatic analysis area. Alternative 2 would affect approximately 40 acres of potential 

habitat. MYLF was detected at two sites within the analysis area, but not within any treatment 

area. Most of the effected acres would be subject to thinning (23 acres) and prescribed fire (12 

acres). The species breeds in streams and ponds, both of which are protected with project design 

measures. 

Yosemite toad: There are approximately 4,769 acres of potential YT habitat within the aquatic 

analysis area. Alternative 2 would affect approximately 170 acres of potential habitat. Most of the 

effected acres would be subject to thinning (152 acres) and prescribed fire after thinning. YT was 

Species

Potential 

Habitat 

(ac)

Habitat 

thinned 

(ac)

Habitat 

masticated 

(ac)

Habitat 

underburned 

(ac)

Total ac. 

Habitat 

Treated

Foothill yellow-legged 

frog 755 13 0 10 23

Western pond turtle 1429 52 1 21 74

Mountain yellow-legged 

frog 811 23 3 12 38

Yosemite toad 4769 151 19 0 171

Lacustrine/riverine* 40.5 0 0 0 0

Wet Meadow 132 0 0 0 0
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 168 Chapter 3

not detected during surveys in the analysis area and the project area is not within dispersal 

distance of any known population. 

Direct Effects 

There is overlap between timing of proposed activities and potential effects on FYLF , WPT, 

MYLF and YT. Project design measures would be expected to protect breeding and rearing sites 

from direct effects, thus subadult and adult life stages remain potentially directly affected. Hand 

thinning, including felling of encroaching conifers in meadow; hand removal of noxious weeds; 

reforesting understocked areas; vegetation removal at historic and prehistoric resource sites; and 

grazing stock drives would not be anticipated to result in direct effects. Restoration of an OHV 

route across meadow 503M7 that was not approved as part of the Forest Travel Management Plan 

(USDA- Forest Service 2010) is not within potential habitat for any of the special interest 

herpetofauna and no direct effects would be anticipated by 0.5 miles of trail restoration.

Proposed tractor thinning, tractor piling, or mastication overlaps units M-3, T-9, T-16, T-27, T29, T-30, T-33, T-34, T-35, T-37, and T-38. The potential for direct effects from crushing would 

be expected to be limited under the Proposed Action. Project design measures include the Old 

Forest Linkage corridors for Pacific fisher. These migration corridors extend 150 feet from both 

streambanks along the perennial streams within the project area. There are no proposed 

treatments within the inner 50 feet from each streambank. The outer 50-feet would implement 

hand treatments to remove the understory ladder fuels < 12’’ dbh. No heavy equipment would be 

allowed within 100 feet of the streambank within these corridors. During primary periods of 

project operations (July – Oct) it is expected frogs and turtles would remain near aquatic habitat 

due to presence of water; the microclimate provided; and riparian connectivity, except during 

rainy periods. The possibility of direct effects from crushing would be most likely during rainy 

periods when species may move away from aquatic areas. Operation of heavy equipment ceases 

during periods of prolonged precipitation to prevent compaction. Adult YT leave breeding 

meadows for foraging sites where they spend the majority of the summer, which would make 

them more susceptible to direct effects than other TES herpetofauna evaluated under this analysis.

Introduced fire (both prescribed and pile burning) could directly affect herpetofauna. Some 

species may use slash piles for cover or for estivation. The possibility of direct effects on 

individual animals from burning piles within the Old Forest Linkage Corridors would be reduced 

by implementing the project design measure to light piles on one side to allow an escape from the 

pile. Underburning may also represent a direct effect to herpetofauna. Underburning is proposed 

adjacent to perennial streams in units Rx-1 Rx-2, T-4, T-9, T-16, Rx-24, T-28-30, T-34-35, and 

T-37-38 potentially affecting MYLF, FYLF, and WPT. Prescribed burning would be expected to 

occur during the spring or fall. During spring, amphibians may be moving to breeding sites or 

dispersing after breeding. During the fall, herpetofauna may be moving to overwintering sites or 

estimating within areas to be burned. Allowing fire to creep into the SMZ (as opposed to active 

introduction) would provide opportunity for herpetofauna to move away from areas burning, but 

not eliminate the possibility of mortality.

Direct effects to FYLF, WPT, and YT would not be anticipated from implementing Alternative 2 

due to Project Design Measures; non-detection of listed species during surveys; and nearest 

known occupied sites are not within dispersal distance of project treatment areas. The nearest 

known occupied YT site is more than 1,200 meters from the nearest proposed treatment unit. 

MYLFs were detected in the analysis area (Figure 17), but not within or adjacent to any 

treatment unit. Breeding and rearing sites for the frog would be protected by project design 

measures. The frog is closely associated with water, which is buffered by streamside management 

zones that would be anticipated to protect the frog from direct effects. No project activities would 

take place until after June 15 in adjacent treatment units to protect frog movement to breeding 

sites.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 169 Chapter 3

Figure 17. Occupied mountain yellow-legged frog (brown triangles indicating RAMU) in 

relation to Greys Mountain project treatment units.

Indirect Effects 

Thinning to reduce ladder fuels would occur over approximately 2,550 acres under this 

alternative. Underburning (both post-thinning and unthinned sites) could occur over 

approximately 2500 acres, hand thinning on 125 acres, and mastication on 320 acres. Reduction 

in stand densities could affect canopy cover (indirectly affecting micro-climate and water 

temperatures), macro invertebrate community, and changes to water yield (indirectly affecting 

stream channel stability). Most of the potential indirect effects to herpetofauna would be related 

to habitat alteration. Thinning is proposed within the ponderosa pine and Sierra mixed-conifer 

CWHR types. The primary changes may reduce size groups and reduce density for a 20-30 year 

period. Canopy cover would be maintained at 60% or greater to maintain habitat for Pacific 

fisher. CWHR habitat quality would remain unchanged for all species based on projected stands 

following thinning. Changes to microclimate (such as increased air temperatures, reduced soil 

moisture, and lower relative humidity) within treated areas may not be accounted for at the 

CWHR scale. Meadow restoration (35 acres) in meadows 503M7, 503M8, 504M132, 504M198, 

504M208, 504M209, 504M211, 504M220, 504M292, and 504M293 may result in short-term 

increases in sediment through stream bank exposure during treatment. It is expected that meadow 

treatment sites would recover within several years and overall site stability would increase and 

sediment contribution would decline at these sites. 

Riparian Canopy Cover: Proposed management actions have the potential to directly alter stream 

shading (solar radiation). Pilliod et al. (2003) identify that amphibians may be directly affected by 

fire (mortality), and indirectly affected through alteration of habitat. Naiman et al. (2000) note 

that riparian forests strongly influence stream microclimate; including air, soil, and surface 

temperatures; relative humidity; and solar radiation. Streamside shading affects the amount of 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 170 Chapter 3

solar radiation that filters to the surface of the water, and Matlack (1993) indicates that aspect 

also exerts influence on microclimate. Cushman (2006) identifies the importance in habitat 

connectivity for amphibian dispersal, suggesting juvenile dispersal as a possible limiting factor. 

Water temperature affects various life activities, such as breeding and rearing time, for 

amphibians. If forest harvesting occurred in streamside areas there could be an increase in solar 

radiation to the stream channel, affecting water temperature. Additionally, underburning could 

result in tree mortality and openings within the riparian canopy. 

Aquatic invertebrates serve as food source for various life stages of herpetofauna. Kattelmann 

(1996) notes several studies have demonstrated that communities of aquatic invertebrates 

changed significantly in response to upstream logging, with some of these effects persisting for 

two decades. Much of the food base for stream ecosystems is derived from adjacent terrestrial 

ecosystems with litter fall from deciduous stands exceeding that of coniferous stands. Deciduous 

input (leaves) generally breaks down in less than half the time necessary for the breakdown of 

coniferous input (needles; Gregory et al. 1991). Buffer strips 30 meters (98.4 feet) wide are noted 

as protecting invertebrate communities from logging induced changes (Gregory et al. 1987; EPA 

1991). 

Dwire et al. (2006) suggest that prescribed fire may top-kill some riparian trees and shrubs. A 

study at Blodgett Forest in northern California introduced prescribed fire into the riparian zone 

and found that a 4.4% mortality rate resulted, occurring in trees 11 – 40 centimeters (4.5 - 15.7 

inches) dbh (diameter at breast height; Bêche et al. 2005). Prescribed fire is not proposed for 

introduction into the perennial SMZs for this project, but it would be allowed to creep within the 

SMZ. Pilliod et al. (2003) suggest that prescribed burning could benefit amphibians by reducing 

forest canopy cover and providing breeding habitat, if reduced transpiration increased base flow. 

However, habitat could be negatively affected if sediment was increased as a result of the 

burning.

Perennial stream channels are included under the Old Forest Linkage (Riparian Migration 

Corridor). These corridors extend 150 feet from both streambanks along the perennial streams 

within the project area. There is no proposed removal of commercial conifers within the inner 50 

feet from each stream bank. The outer 50 feet would implement hand treatments to remove the 

understory ladder fuels. No alteration of the existing stream shading is anticipated from the 

proposed action

Water temperature: Elevation, aspect, stream width, channel roughness coefficient, riparian 

shading, solar radiation, air temperature, cloud cover, and stream discharge levels can affect 

water temperature. Of these elements, solar radiation has the most effect on water temperature 

(Beschta 1987; USGS 2002). Shading effects from forest canopies are important during the 

summer months due to high levels of radiation (high sun angles, long days, clear skies) 

accompanied by low stream discharges (Beschta et al. 1987). Solar radiation through forest 

canopies depends on the heights of the crowns and density, along with the foliage (Moore et al. 

2005). If forest harvesting occurred in streamside areas there could be a direct increase solar 

radiation (reduction in canopy cover) to the stream channel. However, in evaluating possible 

project direct effects to canopy cover it was noted that changes in overhead canopy from stands 

adjacent to perennial streams would not be anticipated. There would no commercial harvesting 

under any prescription within the inner 50-feet of the Class I SMZ. In the outer 50-feet of treated 

SMZs there is a possible increase of open space within the understory component of the treated 

stand (trees <= 12” dbh may be hand thinned). This provides limited opportunity for increased 

solar radiation. 

The mean summer (7/15 – 9/15) and maximum daily mean water temperatures during the 2009 

monitoring period were presented in Table 20. Water temperatures met the Desired Condition (< 

21o C). The period monitored represents that of highest air temperatures and lowest stream flow, 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 171 Chapter 3

thus most stressful on aquatic/riparian species. It is anticipated that the majority of the trees 

would be retained and the inner 50-foot No-Treatment zone would intercept solar radiation and 

there would be no change to water temperatures. Wilkerson et al. (2006) found that a 23 m (75 

feet) buffer resulted in no change to water temperature, while a 11 m (36 ft) buffer (>60% canopy 

retention) resulted in an increased weekly maxima of 1.0 -1.4° C. No alterations to current water 

temperatures would be anticipated to result from the Proposed Action. 

Flow: Of the remaining elements that may affect aquatic habitat, only stream discharge level 

could be affected by the proposal. Stream flow may increase as basal area (and 

evapotranspiration) declines, and peak flows can be indirectly affected by vegetation removal 

(Kattelmann 1996). Troendle (2001) indicated increased water yields following timber harvest, 

although treatments were primarily clearcuts rather than thinnings that are being proposed for 

Greys Mountain. Alteration of the hydrologic regime (timing, duration or magnitude of flows) 

from the combined effects of silviculture and underburning could affect success of amphibians 

that breed in the spring. Should such an alteration occur, it could also result in channel down 

cutting, bank instabilities and degradation of aquatic habitat through additional accumulations of 

sediment in pool habitat and filling of interstitial spaces. In snow-dominated areas, nearly all of 

the change in flows would occur during spring runoff, and spring runoff may occur slightly 

sooner if reductions in canopy allow faster melting of the snowpack

Changes to stream discharge would be an indirect effect from the proposal. If more water were 

available as base flow during the late summer, there would be a possible reduction in stream 

temperature and an increase in available habitat. Potential increases in peak flows are related to 

changes in snow accumulation and snow melt. In the Rocky Mountains, any reduction in stand 

density will increase snowpack accumulation. Troendle et al. (2006) state that the potential for 

thinning to have an effect on streamflow due to reduced evapotranspiration depends on the 

amount of precipitation. In wet summers, there may be surplus water contributing to increased 

stream flow, while in dry years it is likely that the residual stand would use all of the available 

water. In snow-dominated areas such as the Greys Mountain analysis area, nearly all of the 

change in flows would occur during spring runoff, and spring runoff may occur slightly sooner if 

reductions in canopy allow faster melting of the snowpack. Proposed meadow restoration would 

protect water table levels in disturbed meadows. Removal of encroaching conifers at these sites 

may locally decrease the amount of evapotranspiration, but it is not clear that Flow would 

increase over the long term.

Late summer, when solar radiation potential is greatest, air temperatures are warmest, and stream 

flows are lowest, is the period when canopy cover is essential in moderating water temperatures. 

Typically only perennial channels flow during this period, thus concerns over water temperature 

focus on these stream channels. Forest thinning projects have the potential to affect water 

quantity through changes in interception of precipitation, changes in snow accumulation and 

snowmelt (important in snow-dominated areas but less so in rain-dominated and ‘warm snow’ 

zones such as the project area), and changes in available soil moisture due to decreased 

evapotranspiration. The Project Hydrology Report notes that any changes in Flow resulting from 

thinning would be unlikely to persist beyond 10 years. 

Cumulative Effects

Past, present, and reasonably foreseeable actions within the project areas are displayed in Chapter 

3 of the DEIS for the Greys Mountain Project. Known activities occurring spatially and 

temporally within the analysis area are recreational use (campgrounds and off-highway vehicle 

use), vegetation and fuels projects, roads, cattle grazing, and fires. 

Alternative 2 has a risk of compacting soil (tractor thinning, mastication, and machine piling of 

slash), which could result in both short and long-term sediment delivery to riparian and aquatic 

habitats. Compaction has the potential to increase erosion through overland flow; alteration to 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 172 Chapter 3

flow regime; and alteration of stream channel equilibrium. Increased sediment could decrease 

available pool habitat and breeding habitat for amphibians. According to Reid (2006), the impacts 

of mechanical treatments on erosion and sediment yield are likely to result from direct soil 

disturbance where these activities affect swales and low-order stream channels. In this project, 

swales and Class V channels have no SMZs – mechanized access is not prohibited and could 

occur. Class IV channels have a 25-foot SMZ where equipment is excluded. BMP 1-19 prescribes 

practices to mitigate the potential effects, including requiring that stream crossings on Class IV 

and V streams be agreed to by the sale administrator. Unscoured swales that are dry during 

operations receive no special protection. Activities that would be accomplished by hand, such as 

felling and leaving trees, noxious weed removal, vegetative clearing at historic and prehistoric 

sites or stock drives, hand piling, and planting, are assumed to have no effect on hydrology or 

water quality. Roads maintenance (50 miles) and reconstruction (20 miles) would reduce 

hydrologic connectivity and reduce sediment from existing sources.

Sediment: The CWE analysis in the Greys Mountain Hydrology report indicates that all of the 

subdrainages are considered sensitive to moderately sensitive to disturbance (i.e., 4 - 5% Lower 

TOC %). The baseline or existing condition of most of the subdrainages is below the Lower TOC 

%. However, subdrainages 503.0056 and 503.3051 are over their Lower TOC %. When adding in 

the proposed action, none exceeded the Upper TOC of 14%. Bringing system roads up to 

maintenance level 3 standards should address most of these watershed degradation issues, but 

additional measures (i.e., rocking) should be used in subdrainage 503.0056 to mitigate the very 

high potential for CWE response. Restoration of 0.5 miles of OHV trail through meadow 503M7 

may further reduce sediment contribution in this subwatershed. Restoration would include ripping 

of the trail to reduce compaction and restore soil porosity.

There are approximately 70 acres of FYLF and 140 acres of WPT habitat within subwatershed 

503.0056. Of this total, approximately 1 acre of FYLF and 11 acres of WPT habitat would be 

treated under Alternative 2. Observations within this subwatershed indicate instability is currently 

occurring resulting in an excess amount of sediment in pools. Implementation of Alternative 2 

may further increase the amount of sediment beyond the ability of the stream system to transport 

resulting in further reduction in aquatic habitat quantity and quality in this drainage.

Most of the Forest Service actions over the past decade, along with those proposed in the next 

decade, relate to cattle grazing, fuels reduction (including mastication), or forest thinning. These 

actions have Best Management Practices (USDA – Forest Service 2000), along with Forest 

standards and guidelines to restrict off-site erosion and activities within Streamside Management 

Zones. Literature has shown BMPs to be effective in minimizing the erosion in treatment areas 

and at preventing sediment from reaching streams. In a study of sediment redistribution after 

harvesting, Wallbrink and Croke (2002) found that sediment derived from skid trails was 

deposited both within the treated area and the stream buffers (23-30 m). BMPs are expected to 

protect stream channels from sediment for treatments areas near streams. Monitoring of BMP on 

Forest Service lands in California has shown that, when implemented, timber management BMP 

are 95-98% effective (USDA- Forest Service 2004a).

Stream Shading: Past, present and foreseeable actions were evaluated under cumulative effects in 

Alternative 1. It is expected that riparian canopy cover would be maintained at current levels as 

described under Indirect Effects.

Flow and Water Temperature: Changes to Flow would be similar to those described under 

Indirect Effects. Changes to timing and magnitude of Flow that might negatively affect 

aquatic/riparian habitat would be restricted to subwatershed 503.0056. Riparian canopy cover 

would be anticipated to remain at current levels based on use of Class I SMZs (minimum 100 ft) 

that include no removal of commercial conifers within the inner 50 ft, thus a cumulative effect to 

water temperature through implementation of Alternative 2 would not be anticipated. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 173 Chapter 3

Summary of Effects 

Table 27 summarizes overlap of potential habitat by other Actions and the Greys Mountain 

project. Under Alternative 2, approximately 0.5 miles of unapproved off-highway vehicle trails 

could be restored to reduce compaction effects from continuing use. Effects from actions not part 

of the Greys Mountain Project were previously disclosed under Alternative 1 and effects from 

those actions would be similar to those discussed under the No Action Alternative. 

Table 27. Acres of habitat cumulatively affected under Alternative 2. (*lacustrine/riverine 

miles converted to acres assuming 9 ft wide stream)

It is not anticipated that the Greys Mountain Project (Alternative 2), in addition to other activities 

in the Project Area subwatersheds, would contribute to cumulative effects to MYLF or YT. While 

approximately 4.2 miles of BMI habitat are within or adjacent to a treatment unit, overall habitat 

would be expected to be maintained through project design measures (SMZs). 

Existing trend in the riverine/lacustrine habitat or aquatic macro invertebrates across the Sierra 

Nevada bioregion would not be expected to be altered under any project alternative. There would 

be no changes anticipated in wet meadow habitat within the Greys Mountain Project Area. Of the 

132 acres indicated to be wet meadow, 2 acres have been altered by roads and an additional 13 

acres are within the outer 50 feet of the SMZ surrounding wet meadows (not part of the wet 

meadow acreage). Wet meadows would be expected to be protected by project design measures. 

The project would not be expected to alter the existing trend in the habitat, nor will it lead to a 

change in the distribution of Pacific tree frogs across the Sierra Nevada bioregion.

Alternative 3 (Lower and Limited Mid-Level Canopy Treatments, All 

Treatment Areas 

In Alternative 3, treatment areas would remain the same as in Alternative 2. Treatments would 

include only those needed to reduce the surface and ladder fuels (within the lower and limited 

mid-level canopy levels) to achieve fire and fuels objectives. Under Alternative 3 there would be 

no additional treatment (i.e. additional thinning in the mid-level canopy) so it would only partially 

address stand density and forest health objectives. This alternative was developed based, in part, 

using the significant issues. A higher degree of canopy cover would remain after treatment and 

stand densities would remain higher than in the proposed action (Alternative 2). In wild stand 

treatment areas, the break-up of crown continuity would not be the main focus, but the ability to 

raise the height of the canopy base (the average height of the bottom layer of branches) where 

fire/fuels objectives are met. This includes the need to remove some material that is considered 

pre-commercial sized (i.e. less than 10 inches dbh). Maintenance and/or reconstruction of forest 

roads that were determined to not meet Forest Service standards will be brought back up to 

Species

Potential 

habitat 

(ac)

Grazing 

Meadows 

(ac)

Rec/OHV 

Effected 

(ac)

Bass 

Lake 

Mast. 

(ac)

Fire 

(ac)

Roads

(ac)

Greys 

Mountain 

(ac)

Cum. 

Effect 

(ac)

% 

Habitat 

Affected

FYLF 745 2 0 0 0 4 23 29 3.9%

Western pond turtle 1429 6 0 0 0 11 74 91 6.4%

Mountain yellowlegged frog 811 42 23 2 0 9 38 114 14.0%

Yosemite toad 4769 53 0 121 0 53 170 397 8.3%

Riverine/ Lacustrine* 40.5 4 1 0 0 0 2 7 17%

Wet Meadow 132 132 0 0 0 2 0 132 100%
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 174 Chapter 3

standard. Meadow restoration treatments Restore hydrologic function by 36 acres of meadow 

stabilization in meadows 503M7, 503M8, 504M132, 504M198, 504M208, 504M209, 504M211, 

504M220, 504M292, and 504M293 would be completed as planned as funds become available. 

Prescribed burning only treatment areas would be completed as planned. Other actions include 

planting or understocked areas, vegetative clearing at historic and prehistoric sites, vegetative 

clearing along stock drives, removal of noxious weeds, restoration along a user-defined offhighway vehicle route (0.5 mile) through meadow 503M7 that was not approved under the Forest 

Travel Management Plan.

This alternative would receive treatment only to achieve fire and fuels objectives and limit 

treatments to mechanical clearing of ladder and surface fuels. As such, all design criteria and 

SNFPA ROD (USDA- Forest Service 2004) standards and guidelines associated with Pacific 

Fisher would be implemented with this alternative. Of the 9700 total acres within the project 

boundary, approximately 3450 acres were analyzed as areas where some form(s) of treatment are 

proposed (so named as treatment areas). The remaining 6250 acres have no treatments proposed 

due to slopes greater than 35 percent, standard and guideline limitations on treatment and/or no 

treatment is needed to meet the purpose and need. Table 8 for Alternative 2 would also represent 

treatments by subwatershed. Table 9 from Alternative 2 also represents overlap of treatments and 

species habitat for Alternative 3.

Design Features and Mitigation Measures

Project design measures would be detailed under Alternative 2.

Direct Effects

As previously noted, there is overlap between timing of proposed activities and potential effects 

on FYLF, WPT, MYLF and YT. Potential direct effects could occur from crushing of individual 

animals by tractor thinning, or mastication, or from burning of animals. Direct effects from hand 

thinning, including felling of encroaching conifers in meadow; hand removal of noxious weeds; 

reforesting understocked areas vegetative clearing at prehistoric and historic sites; ripping of a 

user-defined off-highway vehicle route to reduce compaction; and vegetative clearing along stock 

drives would not be anticipated. Project design measures would be expected to protect breeding 

and rearing sites from direct effects, thus sub adult and adult life stages would remain potentially 

affected similar to Alternative 2.

Introduced fire could directly affect herpetofauna similar to Alternative 2. Allowing fire to creep 

into the SMZ (as opposed to active introduction) would provide opportunity for herpetofauna to 

move away from areas burning, but not eliminate the possibility of mortality. 

Similar to Alternative 2, direct effects from Alternative 3 to FYLF, WPT, and YT would not be 

anticipated due to Project Design Measures; non-detection of listed species during surveys; and 

nearest known occupied sites not being within dispersal distance of project treatment areas. 

MYLFs were detected within the aquatic analysis area (Figure 17), but not within or adjacent to 

any treatment unit. Breeding and rearing sites for the frog would be protected by project design 

measures. The frog is closely associated with water, which is buffered by streamside management 

zones that would be anticipated to protect the frog from direct effects. No project activities would 

take place until after June 15 in adjacent treatment units to protect frog movement to breeding 

sites.

Indirect Effects 

Thinning to reduce ladder fuels, mastication, and underburning would occur on over the same 

acreage analyzed under Alternative 2. Table 27 in Alternative 2 identifies that treatment areas 

represent approximately 23 acres of FYLF, 74 acres of WPT, 38 acres of MYLF; and 170 acres 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 175 Chapter 3

of YT habitat. Alternative 3 has a risk of compacting soil (tractor thinning or mastication), which 

could result in both short and long-term sediment delivery to riparian and aquatic habitats. 

Implementation of Best Management Practices (USDA – Forest Service 2000); streamside 

management zones; road maintenance/reconstruction; and project design criteria are expected to 

reduce the potential for sedimentation and protect aquatic habitat (Project Hydrology Report: 

Stone 2011).

As noted under Alternative 2, reduction in stand densities could potentially affect canopy cover 

(indirectly affecting micro-climate and water temperatures), macro invertebrate community, and 

changes to water yield (indirectly affecting stream channel stability). Most of the indirect effects 

to herpetofauna would be related to habitat alteration. Thinnings are proposed within the Sierra 

mixed-conifer CWHR types. The primary changes may reduce size groups and reduce stand 

density for a 20-30 year period. CWHR habitat quality would remain unchanged for 

aquatic/riparian TES species based on projected stands following thinning. Changes to 

microclimate (such as increased air temperatures, reduced soil moisture, and lower relative 

humidity) within treated areas may not be accounted for at the CWHR scale, but the reduction in 

mid-canopy tree removal under Alternative 3 may represent reduced effects to microclimate 

relative to Alternative 2.

Stream Shading: Similar to Alternative 2, there would be no alteration to current stream shading 

anticipated. 

Water temperature: Similar to Alternative 2, there would be no anticipated alterations to canopy 

cover, thus there would be no effects on water temperature expected from Alternative 3 

anticipated.

Flow: Similar to Alternative 2, the Project Hydrology Report (Stone 2011) notes that any changes 

in flow resulting from thinning resulting from Alternative 2 would be unlikely to persist beyond 

10 years. Any changes to timing and magnitude of Flow would be restricted to subwatershed 

503.0056 where CWE is noted as likely to occur.

Cumulative Effects 

Past, present, and reasonably foreseeable actions within the project area are displayed in Chapter 

of the DEIS for the Greys Mountain Project. For the Greys Mountain aquatic analysis area, other 

known activities are mastication projects, cattle grazing, roads, and recreational use (both 

campgrounds and off highway vehicles). Acres of habitat potentially affected would be similar to 

Table 9 under Alternative 2. Effects to Stream Shading, Water Temperature, Flow, CWE, and 

sediment would be similar to Alternative 2.

Summary of Effects 

Most of the Forest Service actions over the past decade, along with those proposed in the next 

decade, relate to cattle grazing, and fuels reduction or forest thinning. These actions have Best

Management Practices (USDA – Forest Service 2000), along with Forest standards and 

guidelines to restrict off-site erosion and activities within Streamside Management Zones. 

Literature has shown BMPs to be effective in minimizing the erosion in treatment areas and at 

preventing sediment from reaching streams. In a study of sediment redistribution after harvesting, 

Wallbrink and Croke (2002) found that sediment derived from skid trails was deposited both 

within the treated area and the stream buffers (23-30 m). BMPs are generally expected to protect 

stream channels from sediment for treatments areas near streams. Monitoring of BMP on Forest 

Service lands in California has shown that, when implemented, timber 

Similar to Alternative 2, it is not anticipated that the Greys Mountain Project (Alternative 3), in 

addition to other activities in the Project Area subwatersheds, would contribute to cumulative 

effects to MYLF or YT. There is a high potential for cumulative effects to habitat for WPT and 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 176 Chapter 3

FYLF in subwatershed 503.0056 (affecting approximately 1.7 miles of stream or 2 acres of 

aquatic habitat).

Similar to Alternative 2, riverine/lacustrine and wet meadow habitat would be anticipated to 

remain stable across Sierran National Forests.

Other Relevant Mandatory Disclosures

Table 28 and Table 29 display determination of effects on threatened, endangered, and sensitive 

herpetofauna based on known information on species, habitat available, literature review, and 

anticipated effects. Lacustrine/riverine and wet meadow habitats would be anticipated to remain 

stable under any of the Alternatives. 

Table 28. Effects from Greys Mountain Alternative 1 (No Action) on aquatic threatened, 

endangered, candidate, and sensitive species

Species Determination Rational for the Determinations for Proposed Action

Foothill 

Yellow legged 

frog No Effect No anticipated impacts to species or habitat

Western pond 

turtle No Effect No anticipated impacts to species or habitat

Mountain 

yellow-legged 

frog

No effect No anticipated impacts to species or habitat

Yosemite toad No effect No anticipated impacts to species or habitat

Table 29. Effects from Alternatives 2 and 3 on aquatic threatened, endangered, and 

sensitive species.

Species Determination Rationale for the Determinations for Proposed 

Action

Foothill 

Yellow legged 

frog

May affect 

individuals, but is 

not likely to lead 

to federal listing 

or loss of viability 

for the FYLF in 

the Sierra 

National Forest.

• Not detected within the aquatic analysis area 

during surveys

• Nearest known occupied site is 15 miles from any 

treatment area, which is beyond dispersal range of 

species.

• Available habitat is primarily (80%) Unsuitable or 

Poor based on CWHR.

• Proposed treatments occur over approximately 3% 

of potential habitat, and 4% cumulatively with 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 177 Chapter 3

other projects.

• Proposed treatments not anticipated to reduce quality 

of CWHR habitat.

Western 

pond turtle

May affect 

individuals, but is 

not likely to lead 

to federal listing 

or loss of viability 

for the WPT in 

Sierra National 

Forest.

• Not detected within the aquatic analysis area 

during surveys

• Nearest known occupied site is 2.3 miles from any 

treatment area, which is beyond dispersal range of 

species.

• Available habitat is primarily (89%) Unsuitable or 

Poor based on CWHR.

• Proposed treatments occur over approximately 5% 

of potential habitat, and 6% cumulatively with 

other projects.

• Proposed treatments not anticipated to reduce quality 

of CWHR habitat.

Sierra 

Nevada 

yellow-legged 

frog

May affect 

individuals, but is 

not likely to

contribute to the 

need for Federal 

listing or in loss 

of viability for 

Sierra Nevada 

MYLF in the 

Sierra National 

Forest.

• Two occupied sites in the Aquatic Analysis Area.

• No occupied habitat detected within proposed 

treatment units.

• Treatment units adjacent to populations have No 

Treatment buffering that would protect 

breeding/rearing.

• Limited operating period after June 15th would 

reduce potential for frogs moving to breeding sites 

from being affected by project.

• Available habitat is primarily (81%) Unsuitable or 

Poor based on CWHR.

• Proposed treatments occur over approximately 5% 

of potential habitat, and 14% cumulatively with 

other projects.

• Proposed treatments not anticipated to reduce quality 

of CWHR habitat.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 178 Chapter 3

Yosemite 

toad

May affect 

individuals, but is 

not likely to 

contribute to the 

need for Federal 

listing or in loss 

of viability for YT

in the Sierra 

National Forest.

• Species was not detected during Forest-wide surveys 

between 2002-2004, or during 2010/2011project 

surveys.

• No meadows are occupied within aquatic analysis 

area subwatersheds 

• Nearest occupied meadows (> 0.9 miles) from any 

proposed treatment unit are beyond dispersal 

distance of species (0.6 mi).

• Proposed treatments occur over approximately 4% 

of potential habitat, and 8% cumulatively with 

other projects.

• Proposed treatments not anticipated to reduce quality 

of CWHR habitat.

Effects to Aquatic Biota from proposed changes in treatments

The two treatment areas overlap potential habitat for western pond turtle. The habitat overlap 

represents less than 1.25 acres based on GIS review. This acreage was previously considered as 

part of the 74 acres of western pond turtle habitat potentially affected by the Greys Mountain 

Project. The proposed treatment revisions represent an increase in acres burned, and a decrease in 

acres mechanically thinned. Considering the amount of affected habitat involved, that western 

pond turtle was not located adjacent to these two units during surveys, and the less intensive 

management proposed by these two revisions; a change in the determination of effects to western 

pond turtle would not result. There is no habitat for any other threatened, endangered, or sensitive 

aquatic species within the two treatment units, nor is there any habitat for aquatic management 

indicator species.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 179 Chapter 3

Range Management _________________________

The direct, indirect and cumulative effects to the Range Management are summarized from the 

Range Management report for the Grey’s Mountain Ecological Restoration Project (Smith A., 

2012)

Affected Environment 

Existing Condition 

The project area is within the boundaries of two grazing allotments: Central Camp and Soquel 

(Figure 18). Grazing by domestic livestock has occurred in the project area for over 100 years. 

The Forest Service began administration of grazing in 1905 and has continually modified and 

adjusted livestock grazing practices, numbers of animals and season of use up to the present. 

These allotments have been analyzed for compliance with NEPA and the decision was made to 

continue to authorize cattle grazing in these allotments. Therefore, the authorization of cattle 

grazing within the project is not the focus of this analysis. This analysis focuses on the condition 

of montane meadows within the project area and the effects of the restoration on meadow 

ecological status. Meadow restoration is proposed for a sub-set of meadows with the project area 

(Figure 18). Several meadows within the project area are key areas used for monitoring the 

effects of grazing.

Cattle use occurs throughout the project area. The primary use by livestock is in the montane 

meadows where the forage is most abundant and secondary use is in plantations (e.g. browse on 

buckbrush) or the forest where some understory where forage is found. 

Historic overgrazing from past improper grazing management and other anthropogenic activities 

has resulted in impacts to meadows and riparian areas, some that are still evident. Ranching was 

the first industry in California and was expanded upon with the establishment of the Spanish 

missions. During this time cattle were valued for their hides and tallow that were exported back 

to Europe at considerable profit margin leading to very high and unsustainable stocking rates 

beyond the carrying capacity of the land. The Gold Rush of 1849 ushered in a shift toward beef 

production where cattle were used for meat. Summer grazing in the Sierra Nevada began during 

the droughts in the 1860s and 1870s. Sheep grazing was the dominant use of these meadows. 

Overgrazing in the late 1800s and early 1900s resulted in widespread deterioration of meadows. 

Effective control and regulation of the range did not begin until the Forest Reserves were created 

and when grazing permits were required by the Forest Service.

The Central Camp and Soquel allotments are managed under a deferred grazing system. 

Deferment involves delay of grazing in a pasture until the seed maturity of the key forage species, 

which permits the preferred forage plants to gain vigor and reproduce. The allotments are grazed 

primarily by elevation zone within each unit with the lower elevations receiving grazing pressure 

early in the season and then livestock drift or are driven to the mid-high elevations meadows. It 

is not a strict deferment, since there are no drift fences or pasture boundary fences to keep the 

stock from grazing throughout the allotment. The objective in managing these allotments is to 

delay use in the higher elevations and to achieve even distribution throughout the allotment as the 

season progresses. From this perspective, the use is considered a combination between deferred 

grazing and season long grazing, which implies that cattle graze a particular pasture or unit 

throughout the grazing season year after year. The gathering pastures are grazed under a high 

intensity-low frequency grazing system, since large numbers of stock are gathered into the 

pastures for a very short time (one-two nights) before they are driven or trucked off the allotment.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 180 Chapter 3

Livestock may congregate in riparian areas (e.g. meadows, seeps, springs and creeks) because of 

convenience of forage, water, terrain and cover. The preferred plants in these areas may receive 

excessive use as a result; therefore, a considerable amount of herding and trailing of cattle is 

required to keep stock in the lower elevations early in the season. This ensures even use and 

keeps the stock from moving upslope too quickly and from re-grazing areas to avoid over use. 

Proper livestock distribution that results in good animal distribution over the entire grazing area is 

a primary management goal to meet allowable forage utilization standards. Permittees use riding, 

herding and salting to achieve this objective. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 181 Chapter 3

Figure 18. Allotment boundaries and meadows with proposed restoration within the project 

area.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 182 Chapter 3

Meadow Condition

Meadows are wetlands or semi-wetlands that support hydrophytic and mesophytic vegetation 

including grasses, sedges, other grasslikes, such as rushes, and a variety of forb species. The 

meadows within the project area are managed for meadow stability and ecological health while 

providing a forage resource. The meadows identified in the proposed action have ground water 

tables have been lowered due to impacts from a combination of past logging, road building and 

grazing. These meadows have localized areas that are degraded and have compromised 

hydrologic function where portions of associated channel have areas of vertical and lateral 

instability. The resulting change in soil moisture conditions has resulted in conifer encroachment 

beyond the range of natural variability. 

Several key area meadows within the project area have long term range condition and trend 

monitoring plots and long term meadow ecological condition and trend data has been analyzed as 

part of this analysis (Table 30). At these monitoring sites, vegetation, soil and general plot 

location information are collected. Plots are located in mesic sites that are likely in a lower 

ecological condition as opposed to being placed in the most hydric or wetter areas. Therefore the 

plots are established to best determine changes over time in the meadow by being placed in the 

areas likely to show change and transition due to management activities. The plot data shows that 

vegetation is in moderate ecological condition with overall high ecological condition with stable 

and upward trends respectively.

Table 30. Summary of ecological status data collected at two key area meadows within to 

the Greys Mountain Project Area. 

Allotment

Meadow 

Name

(plot 

location)

Meadow 

Type

Vegetation 

Condition 

Class

(ecological 

status)

Overall 

Condition 

Class 

(ecological 

status)

Vegetation 

Trend

Overall 

Trend

Moving 

Towards 

Desired 

Conditions?

Meets 

Desired 

Conditions?

Central 

Camp

Chipmunk 

Meadow

Moist 

Meadow Moderate High Stable Upward Yes Yes

Soquel Poison 

Meadow

Wet 

Meadow Moderate High Stable Upward Yes No

Mountain meadows have been susceptible to conifer encroachment during the past century. This 

may reflect a process of contraction following a disturbance such as wildfire or may reflect a 

change in land use such as the cessation of sheep grazing or a shift in climate. Meadow types 

vary in their susceptibility to encroachment. A transition from open meadow to large, older trees 

represents a stable relationship between the forested areas and meadows. Transition from an 

open meadow to scattered small trees to larger trees to large mature trees suggests instability from 

past effects (Ratliff 1985). Physically degraded meadows would often have lowered ground 

water tables, which in turn can lead to accelerated conifer encroachment outside the range of 

natural variability. A comparison of aerial photos from 1944 and 2008 and field analysis 

indicates varying degrees of conifer encroachment in meadows within the project area. The 

encroaching trees <12” dbh are proposed for removal. 

Fire is a part of the natural environment and there is evidence that fire plays a significant role in 

the evolution and maintenance of meadows of the Sierra Nevada by influencing the forest and 

meadow boundary (Ratliff 1985). Forests burned from lightning and fires set by Native 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 183 Chapter 3

Americans and later by fires set by sheep and cattlemen to improve forage and conditions for 

livestock. Meadows are not likely to burn in years with normal or above normal precipitation, but 

may have burned when herbage was dry and during drought periods. Prescribed burning in 

forested areas (units) is part of the proposal, burning within the meadows is not proposed.

Soquel Allotment

The Soquel Allotment was used by cattlemen prior to the formation of the Sierra National Forest. 

During the early period of livestock use, the allotment was overgrazed by cattle and sheep. Peak 

use occurred during the two world wars following a decline in use in post war years. The first 

available data recording use was in 1908 where the level of use was 375 animal months. Use 

rapidly increased and by 1918 the stocking was at 1,784 animal months. Following 1918, there 

were periodic increases and reductions. There were sharp rises in livestock use in 1926 to 1,556 

animal months and again in 1944 to 2,112 animal months, which is the highest recorded use. 

This prolonged and heavy use resulted in considerable damage to vegetation and soil resources. 

Extensive resource rehabilitation and stocking reduction measures were employed to correct the 

overgrazed conditions. During the period of 1948 through 1953 animal stocking levels were 

reduced to levels commensurate with the estimated capacity of 943 animal unit months. In 1957, 

the allotment capacity at this time was determined to be a 736 animal unit months based on 

boundary changes and allotment condition. Subsequent measurements and monitoring studies 

indicated that further reductions were necessary. Therefore in 1967, the overall allotment capacity 

was reduced to 651 animal unit months. Additional stocking reductions have been put in place 

since the range analysis and NEPA decision from 2007.

Transitory range, or newly opened areas due to logging that support forage growth and 

production, was created through past logging and burning activities at the turn of the century. 

Today, the majority of forage is located in meadows and natural openings. The Soquel Allotment 

is a 44,000 acre allotment used as summer range by Mike and Sherrine Knapp of Lazy K Ranch, 

Chowchilla, CA. Table 31 below shows the number of cattle permitted to graze and the timing of 

use. The allotment is grazed by cow/calf pairs from June 1 through October 15 with 190 cow calf 

pair. The majority of cattle are gathered by mid-September, with straggler cattle sometimes 

remaining into October. A portion of the herd is trucked to the allotment from the base ranch to 

Sivels Meadow early in the season with the remaining cattle being trucked to Soquel Meadow 

where they are kept temporarily in the fenced holding field at this location prior to being 

dispersed throughout the allotment. The grazing system is generally considered a deferred season 

of use with lower elevation meadows used initially followed by higher elevations grazed as 

season progresses. 

A portion of the Beasore Stock Driveway is also located within the Greys Mountain project area 

(Figure 18). The distribution of livestock in the allotment is considered season long grazing with 

deferred use of lower elevations followed by the higher elevations. Forage areas are 

predominantly in moist to wet meadow types with most grazing occurring in meadow areas 

although there is some hillside forage in forested areas and on open sandy slopes. The number of 

livestock and season of use is described in Table 31. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 184 Chapter 3

Table 31. Current Permitted Numbers and Season of Use for Soquel Allotment.

LIVESTOCK PERIOD OF USE Head Months 

(Animal 

Months)

Animal Unit 

Months

NUMBER KIND CLASS FROM TO

100 Cattle cow/calf 6/1 9/15 352 465

75 Cattle cow/calf 7/1 10/1 229 302

15 Cattle cow/calf 7/1 10/15 53 70

Total 634 837

Poison Meadow (504M209)

Poison Meadow (Figure 18) is a key area meadow used for annual forage utilization monitoring. 

A permanent range condition and trend monitoring plot is also located in the meadow. The plot 

in Poison Meadow was analyzed using the vegetation frequency method in 2000, 2005 and most 

recently in 2010. Results from this analysis show the meadow to be in moderate ecological status 

for vegetation condition and high overall ecological condition (takes vegetation, soils, rooting 

depth and depth to water table into account) with a stable trend for vegetation and upward trend 

for ecological condition (Figure 18). There is a WIN site where rock structures were previously 

installed in the toe of the meadow that is no longer functional so reconstruction and repair of 

existing structures is proposed. There is a medium level of conifer encroachment in the northern 

portion of meadow approximately 0.86 acres (11%). Split rail fencing and signage is 

recommended to discourage OHV use along track ML91 of the meadow. This meadow receives 

little if any livestock use so enclosure fencing of the restoration site may not be necessary. 

Physical restoration and/or stabilization efforts would restore/preserve approximately 7.5 acres of 

this meadow.

Texas Flat Meadow (504M293)

Texas Flat Meadow (Figure 18) is a key area meadow used for annual forage utilization 

monitoring. There are two main headcuts with several smaller knick points in the meadow. The 

east end of the meadow has very high conifer encroachment (approximately 1.25 acres). The 

headcuts and knick points in Texas Flat Meadow are proposed to be treated by constructing rock 

step pool structures. Although no OHV use into the meadow was noted during field observations, 

it is recommenced that split rail fencing be placed along FS Road 6S36 to discourage OHV use in 

meadow. There is an infestation of bull thistle in the northern portion of the meadow. Physical 

restoration and/or stabilization efforts would restore/preserve approximately 5 acres of this 

meadow.

Meadow 504M211/504M212 (un-named meadows)

Meadow 504M211 (Figure 18) has two headcuts and rock step pools are proposed to address 

both headcuts The meadow has a negligible amount of encroachment so no conifer removal is 

proposed. The meadow shows 1.34 acres of encroachment from satellite and aerial photo review. 

Physical restoration and/or stabilization efforts would restore/preserve approximately 3 acres of 

meadow 504M211. Meadow 504M212 is located 0.1 miles north of meadow 504M211. There 

are no WIN sites identified in this meadow (thus no physical restoration is planned), but there has 

been 0.75 acres of conifer encroachment identified through satellite and aerial photo review. 

Meserve Meadow (504M132)

Livestock are driven via the Beasore Stock Driveway to the Beasore Allotment (not within the 

project area) from Bass Lake Corral off County Road 274. The fenced portion of Meserve 

Meadow (Figure 18) is adjacent to the stock drive and is used as a livestock holding field used to 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 185 Chapter 3

overnight cattle during the cattle drive. The holding fence right-of-way would be cleared and the 

barbed wire fence would be reconstructed under the maintenance terms of the grazing permit. 

The stock drive would be maintained by cutting out encroaching conifers and clearing stock drive 

tread. This meadow has three log structures and one rock structure. The log structure would be 

replaced under the proposal and the headcut between the bottom two log structures would be 

repaired with a rock step pool structure. Meserve Meadow has very high conifer encroachment 

(0.5 acres) and existing conifers (up to 12” dbh) would be removed, but no other woody 

vegetation is proposed for removal.

Progeny Meadow (503M8)

Progeny Meadow (Figure 18) is a lower elevation meadow that has a mix of annual and 

perennial herbaceous species present, so it is somewhat of a transitional meadow with mesic and 

dry portions of the meadow supporting difference plant species. The primary WIN feature is 

located at the toe of the meadow, which consists of two headcuts. The channel along the west 

side of the meadow has several headcuts and two rock bowl restoration structures where the 

channel meets the meadow. Rock step pool structures are recommended to stop headward 

erosion of the headcuts. Conifer encroachment is high throughout meadow (approximately 3.5 

acres) and the proposal is that these trees be removed. Split rail fencing is proposed along FS 

Road 6S13 to discourage damage to the meadow due to OHV use. An offsite livestock water 

development is recommended to minimize impacts to the associated channel.

Meadow (504M208)

Meadow 504M208 (Figure 18) has a functional rock bowl in the upper part of the meadow, eight

headcuts, and OHV tracks in the meadow south of 6S38. Rock structures (e.g. rock step pools 

and rock rundowns) are proposed to repair all the headcuts in the southern portion of the meadow. 

High conifer encroachment is noted above road (approximately 0.1 acres) with low to medium 

encroachment below road. Split rail fencing is also proposed along FS Road 6S38 to discourage 

OHV use in meadow. Physical restoration and/or stabilization efforts would restore/preserve 

approximately 0.3 acres of this meadow.

Railroad Meadow (504M198)

Railroad Meadow (Figure 18) is a key area meadow used for annual forage utilization 

monitoring. A portion of the meadow is bisected by an old railroad grade bed that is altering 

water flow and the hydrology of this meadow. A breach in the railroad bed is used as a crossing 

by the cattle and is contributing to channel incision and erosion. Conifer encroachment is very 

high in the west end of the meadow near 6S11 (head of meadow) at approximately 2.4 acres 

(~50%). The hydrologist recommends obliterating the railroad bed and removing encroaching 

conifers to improve conditions in this meadow. There is a bull thistle infestation in this meadow 

on the railroad bed. Physical restoration and/or stabilization efforts would restore/preserve 

approximately 3.5 acres of this meadow.

Board Ranch Meadow (503M7)

Board Ranch Meadow (Figure 18) is also a lower elevation transitional meadow with a mix of 

annual and perennial herbaceous species. An OHV track bisects the meadow and is impacting the 

hydrology. Localized OHV and cattle impacts have resulted in chiseling and vertical banks are 

evident at the toe of the meadow along the 6S13 Road and rock work is proposed to repair a 

headcut in this area. Split rail fencing is proposed to discourage access at this location. Conifer 

encroachment is very high in small pockets of the lower southeast and upper northwest ends of 

the meadow (approximately 2.5 acres). Conifer encroachment removal is proposed in the upper 

portion of the meadow and in small pockets of the lower end of the meadow. There is an old 

fenced spring development in the southwestern portion of the meadow (just above the 6S13) that 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 186 Chapter 3

needs repair and maintenance which could be covered under administration of the grazing permit. 

Physical restoration and/or stabilization efforts will restore/preserve approximately 3.0 acres of 

the true meadow area.

Central Camp Allotment

Although early records are sketchy and not too reliable, it is apparent that this allotment is similar 

in past history to many of those in the Sierra. Early records are not available but it is safe to 

assume that the area was probably grazed by sheep, as most of the forest area was, during the 

1870s and 1880s. Sheep use was replaced by cattle use near the turn of the century. Use was 

heavy in the 1920s, decreased during the drought years of the 1930s, increased greatly during the 

war years, decreases slightly from 1948-1952 and remained constant for a period after. Grazing 

use was heavy until reductions were initiated in the 1940s and 1950s. Use was around 598 AUMs 

from 1963-1983. Further reductions occurred in 2008 with the reduction from 166 cow calf pair 

to 101 cow calf pair (468 AUMs) (Table 30). 

The Central Camp Allotment is a 25,893 acre allotment used as summer range by Gary and 

Tawny Pamplin of Clovis, CA. Livestock are trucked to the Graham Meadow Corrals and are 

distributed throughout the allotment to the Gaggs Unit and Francis Junction Units. The higher 

elevations meadows in these Units, such as Morgan Meadow and Upper Francis Junction 

Meadow are used later in the season. Livestock are gathered into Graham Meadow at the end of 

the season and trucked home to Tollhouse, CA. Straggler cattle may be gathered into Upper 

Francis Junction Corral or Chipmunk Corral and trucked off the allotment. Along with riding and 

herding, salting is used to improve or maintain livestock distribution throughout the allotment. 

Salt is to be located more than 1/4 mile from streams, meadows, trails and young plantations. 

Salt blocks are not placed within or near known archaeological sites.

Only the northwestern most portion of the Central Camp allotment is located within the project 

area. Chipmunk Meadow is a key area meadow that is proposed for restoration (Figure 18). The 

distribution of livestock in the allotment is considered season long grazing with a deferred use of 

lower elevations followed by the higher elevations. Forage areas are predominantly in moist to 

wet meadow types. Most grazing occurs in meadow areas although there is some hillside forage 

in forested areas and on open sandy slopes Table 32 describes the current livestock numbers and 

season of use for Central Camp Allotment. 

Table 32. Current Permitted Numbers and Season of Use for the Central Camp Allotment.

LIVESTOCK PERIOD OF USE Head Months 

(Animal 

Months)

Animal Unit 

Months

NUMBER KIND CLASS FROM TO

101 Cattle cow/calf 6/16 9/30 355 468

Total 355 468

Chipmunk Meadow (504M220)

A permanent range condition and trend monitoring plot is located in the key area at Chipmunk 

Meadow. The plot in Chipmunk Meadow was analyzed using the vegetation frequency method 

in 1999, 2002, and 2004. Results from this analysis show the meadow to be in moderate 

ecological status for vegetation condition and high overall ecological condition with a stable 

vegetation trend and upward overall trend (Table 30). Chipmunk Meadow has a headcut at the 

toe of the meadow and several small knick points in the middle and upper sections of the 

meadow. A rock step pool or possibly a log step fall structure would be constructed to repair the 

headcut. This meadow has negligible conifer encroachment. OHV damage has occurred in this 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 187 Chapter 3

meadow in the past and barriers have been placed at entry points to the meadow to discourage 

OHV use which seems to be working. Physical restoration and/or stabilization efforts would

restore/preserve approximately 2.6 acres of this meadow.

Desired Condition 

Applicable S&Gs

These land allocations incorporate S&Gs from the SNF (LRMP) (USDA-FS 1992), including 

amendments; An Environmental Assessment of Utilization Standards for Determining Proper Use 

of Available Forage for Commercial Livestock (USDA- FS 1995), and the Sierra Nevada Forest 

Plan Amendment (SNFPA) (USDA-FS 2001, 2004). The goal of protecting and restoring desired 

conditions is applied through following standards applicable to the proposed grazing management 

within the project area. These S&Gs are part of the action alternatives. Additional S&Gs have 

been incorporated into the alternatives to achieve and/or maintain desired conditions. Table 33

provides utilization standards for each vegetation community

Table 33. Allowable utilization levels by vegetation community

Desired conditions are for rangelands to be in satisfactory condition and all grazing activities 

occurring on the forest would have management strategies which achieve or maintain rangeland 

conditions in satisfactory condition. 

Landscape Vegetation type Standards for 

rangeland in 

satisfactory condition 

or late ecological 

status

Standard for 

rangeland in 

unsatisfactory 

condition or early 

ecological status

Annual grasslands & 

oak woodlands with > 

10 inches annual 

precipitation and ≤15% 

slope (1,000-2,500 feet 

elevation)

grass and grasslike plants 

and forbs

700 lbs/acre Residual 

Dry Matter

1,000 lbs/acre Residual 

Dry Matter

Annual grasslands & 

oak woodlands with > 

10 inches annual 

precipitation and >15% 

slope (>2,500 feet 

elevation)

grass and grasslike plants 

and forbs

1,000 lbs/acre Residual 

Dry Matter

1,200 lbs/acre Residual 

Dry Matter

Meadows/riparian areas 

within annual 

grasslands, oak 

woodlands, montane 

and subalpine meadows

grass and grasslike plants 

and forbs

40 % Use by Weight 30 % Use by Weight

All rangeland types hardwoods: including 

(oak/willow and other 

shrub 

seedlings/regeneration)

Allow browse on no 

more than 20% of 

current annual leader 

growth and advanced 

regeneration

Allow browse on no 

more than 10% of 

current annual leader 

growth and advanced 

regeneration

Annual Grasslands & 

Oak Woodlands

Annual Grasslands & 

Oak Woodlands/Uplands

Minimum of 60 percent 

cover

Minimum of 60 percent 

cover
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 188 Chapter 3

Desired condition is upper moderate or high ecological condition where late successional species 

are well represented on the site (e.g. greater than 40% of the composition). Early successional 

species may be represented but are of low abundance. Sites with higher late seral species and low 

abundance of early successional species allow for satisfactory ecological health, biological 

diversity, and resilience.

Desired conditions for rangelands are summarized in Table 34.

Table 34. Desired conditions for montane meadows and riparian conservation areas.

Desired Future Condition

Rangelands are to be in satisfactory condition and all grazing activities occurring on the Forest 

would have management strategies which achieve or maintain rangelands in satisfactory 

condition. 

Satisfactory rangeland condition is defined in the Forest Plan as having either 1) a livestock 

forage condition rating of good or excellent or; 2) late seral ecological status greater than or equal 

to 60% similarity to potential natural community (PNC) (moderate ecological status), or; 3) a 

resource value rating of greater than or equal to 76% similarity to desired condition, and stable 

soils with continuous vegetative cover and rooting throughout available profile (1995 SNF LRMP 

Amendment: 2.2.4, Page 2-11).

Water quality meets the goals of the Clean Water Act and Safe Drinking Water Act; it is fishable, 

swimmable, and suitable for drinking after normal treatment (2004 SNFPA ROD Page 42).

Habitat supports viable populations of native and desired non-native plant, invertebrate and 

vertebrate riparian and aquatic dependent species. New introductions of invasive species are 

prevented. Where invasive species are adversely affecting the viability of native species, the 

appropriate State and Federal wildlife agencies have reduced impacts to native populations (2004 

SNFPA ROD Page 42).

Ensure that characteristics of special aquatic features are, at a minimum, at Proper Functioning 

Condition, as defined in the appropriate Technical Reports (or their successor publications): (1) 

“Process for Assessing PFC” TR 1737-9 (1993), “PFC for Lotic Areas” USDI TR 1737-15 

(1998) or (2) “PFC for Lentic Riparian-Wetland Areas” USDI TR 1737-11 (1994); (2004 SNFPA 

ROD S&G 117, Page 65). 

Species composition and structural diversity of plant and animal communities in riparian areas, 

wetlands and meadows provide desired habitat conditions and ecological functions (2004 SNFPA 

ROD Page 43). 

The distribution and health of biotic communities in special aquatic habitats (such as springs and 

seeps) perpetuates their unique functions and biological diversity (2004 SNFPA ROD Page 43). 

Soils with favorable infiltration characteristics and diverse vegetative cover absorb and filer 

precipitation and sustain favorable conditions of stream flows (2004 SNFPA ROD Page 43). 

A diversity of age classes of hardwood shrubs is present and regeneration is occurring (2004 

SNFPA ROD Page 43). 

Streams in meadows, lower elevation grasslands and hardwood ecosystems have vegetation and 

channel bank conditions that approach historic potential (2004 SNFPA ROD Page 42).
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 189 Chapter 3

Environmental Consequences 

Methodology 

The Environmental Consequences chapter describes the predicted effects on meadows. This 

analysis focuses on the effects of restoration activities on meadow ecological status.

The boundary for the cumulative effects analysis is the project boundary where it overlaps the 

Soquel and Central Camp allotments. Cattle grazing is an ongoing activity which has occurred in 

the project area for over 100 years but as management has improved; there have been periodic 

and sustained reductions in livestock numbers and authorized grazing seasons resulting in 

improved conditions. Past activities in Soquel Meadow and the Nelder Grove areas adjacent to 

the project area include railroad logging (1889-1892) by the Madera Flume and Trading 

Company. More recent logging activity includes the Cedar Valley Timber Sale adjacent to the 

project area and also recent logging on private land in the Paradise Spring Resort and Soquel 

Meadow areas. Known recent and present activities within the analysis area are recreational and 

cultural uses, vegetation and fuels reduction projects, special uses (e.g. MID and apiaries) and

cattle grazing. The present known recreational activities occurring within the analysis area 

include camping, off-highway vehicle use, horseback riding, and hunting, fishing and cultural 

uses. The project boundary includes roads for motorized use and trails for motorized use and 

non-motorized use (e.g. hiking and horseback riding). Wildfire, although infrequent, includes 

past fire activity occurring between the 1920s and 1960s primarily due to slash burning from 

logging operations.

Alternative 1 – No Action 

Direct, Indirect Effects

Under the No Action Alternative, meadow restoration or conifer encroachment removal would 

not occur. The project meadows would continue to have areas of exposed bank, headcuts and 

knick points that would remain unaddressed and the condition of these degraded areas could 

worsen causing additional instability, erosion and further meadow degradation. Successional 

encroachment or “reforestation” of meadows is a natural process, but in many cases 

anthropogenic stressors (e.g. fire suppression) have greatly accelerated this process beyond the 

range of natural variability. Conifer encroachment would continue expanding towards the 

interior of the meadow and this process would continue to negatively affect meadow ecological 

condition. The area of expanding conifers would reduce water availability for herbaceous 

species, potentially reducing vegetative cover and could accelerate drier conditions within the 

meadow resulting in a shift to a more xeric site. This shift could eventually convert the meadow 

area to a forest environment. Over time meadow condition and trend could move in a direction 

away from desired conditions.

Cumulative Effects 

The effects of not implementing structural vegetation restoration activities, channel stabilization 

and trail restoration on meadow ecological status may result in static deteriorated conditions due 

to past and present activities that have altered meadow conditions. If restoration is not 

implemented then there would be a continuation of degraded conditions in stream channels that 

would adversely affect adjoining meadows from ongoing erosion. This deterioration would result 

in reduced water availability which may cause downward trend and reductions in the relative 

abundance of desired herbaceous species composition in meadows. There would be negligible 

additional effects from past activities and possible and likely localized effects from other ongoing 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 190 Chapter 3

activities in the project area to meadow ecological status (e.g. occasional unauthorized motorized 

use across meadows). 

Alternative 2 – Proposed Action 

Design Features and Mitigation Measures

Design features would be implemented to ensure success of restoration efforts. Excluding the 

restoration areas from cattle grazing with temporary fencing would be done for a period of no less 

than two years in order to allow vegetation to recover and to protect the area(s) from trampling 

damage. To help compensate for the potential loss of available stock water, offsite watering 

systems would be evaluated on a case-by-case basis and be installed in coordination with the 

range manager and permittee. As part of the proposed conifer removal, only trees up to 12” dbh 

would be felled, lopped-and-scattered, bucked in place, or bucked and carried to the meadow 

edge and left as biomass or used in the restoration structures. Existing stock trails would not be 

blocked and the material would be placed to discourage cattle from trailing or creating new trails 

in the meadow. The material would be placed to encourage livestock use of the forest or forested 

edge to travel. Native vegetation (e.g., sod plugs) removed during restoration activities would be 

saved and preserved for later planting to encourage re-vegetation of newly disturbed areas. Areas 

of bare soil in the floodplain would also be planted with native willows to expedite and enhance 

the stabilization process. Willows would be either cultivated or harvested locally from the same 

meadow(s) or meadows in the same watershed and at the same elevation range.

Direct, Indirect Effects

Meadows provide the bulk of forage on grazing allotments. Ecological condition and hydrologic 

function of montane meadows affects water availability and storage which influences water 

quality and quantity, wildlife habitat and forage quality and production. The ecological condition 

and hydrologic function of the meadows and associated riparian channels would improve under 

Alternative 2. Improved ecological condition would be evident by high vegetative cover (>90%), 

species composition that reflects a high relative percentage of late seral species (>40% late seral 

species), improved plant vigor and possible increases in forage production. Vegetation trends 

would remain stable or move upward for sites with stable trends (Poison and Chipmunk 

Meadows) and sites with upward trends would continue on that trend which is desired condition. 

Meadows with moderate ecological status could move toward high ecological status with higher 

abundance of late seral herbaceous species. Direct benefits of the meadow restoration from repair 

of existing and installation of new rock structures to stabilize channels would be increased water 

storage and reduced erosion. The effect of this stabilization would further move sites towards 

desired conditions. The installation of enclosure fencing would avoid or minimize potential 

livestock impacts on the restoration sites while vegetation is re-establishing in these areas. 

Recovery of the degraded channels in the meadows would improve conditions cumulatively in 

the meadow. The effects of continued implementation of grazing S&Gs would also act to 

maintain or improve site conditions over time. 

The most effective strategy for conservation and maintenance of meadow habitats targets conifer 

encroachment removal during the early stages of encroachment. Restoration efforts that target 

forest-meadow edges or small tree islands maximize the potential for improved dispersal of 

meadow species (Thompson 2007). Restoration attempts at later stages of encroachment may be 

hindered by loss of meadow species from the vegetation, absence of soil seed bank for most 

meadow species and changes in soil properties that facilitate further recruitment of tree seedlings. 

Conifer encroachment removal and channel restoration under this alternative would increase the 

area covered by meadow or riparian vegetation. Trees that invade a meadow alter light and soil 

moisture available to herbaceous plants which can lead to undesirable changes in species 

composition and biomass productivity. A decrease in conifer seedling establishment would be 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 191 Chapter 3

expected as the meadow conditions would improve from increased water storage under the 

proposal and may result in saturated soil for a longer period in the growing season which would 

inhibit seedling establishment. Also, trees (12” dbh or less) within the meadow that are 

contributing to the seed source would be removed further delaying conifer seedling 

establishment.

The channel stabilization and conifer removal would improve hydrologic function of the 

meadows and would have a beneficial effect on the watershed. Meadow condition would move 

towards upper moderate or high ecological condition where late successional species are well 

represented on the site, which is the desired condition. Restoration effects in the long term may 

improve resiliency of the meadow and riparian vegetation in relation to climate change. 

Fire in the surrounding watershed probably influenced meadow ecology more often that fires 

directly in meadows resulting in increased water flows and sedimentation (Ratliff 1985). 

Although prescribed fire is not proposed directly in meadows in the project area, it is proposed as 

a follow treatment to mechanically treated units. Prescribed fire is planned and implemented to 

limit burn intensity and severity (e.g. degree of tree mortality) with reduced effects when 

compared to those of wildfire. Fire exclusion has resulted in increased stand density and 

accumulation of downed wood and litter. Treatment by mechanical thinning and prescribed fire 

would help to physically open up the forest floor to allow livestock access and improved 

livestock distribution within the allotments. 

The openings in the canopy combined with the follow-up entry with fire could benefit the 

production of herbaceous species and forage under the forested canopy. This effect may also 

attract livestock out of the meadow areas that are the primary forage areas and may reduce the 

impacts from livestock in meadows. Busse et al (2000) found that the total herbaceous vegetation 

cover and production were unaffected by burning, while species diversity increased slightly in a 

ponderosa pine forest in Central Oregon. The primary response on herbaceous plants was a slight 

increase in diversity and a change in relative abundance of graminoid species. The herbaceous 

plant community was otherwise unresponsive to low severity fire as neither forbs nor graminoid 

cover increased significantly as a result of burning. The primary factors contributing to the poor 

aboveground response of herbaceous plants were that the low severity fire had little effect on tree 

mortality and competition for soil and water nutrients between overstory and herbaceous plants 

was unaltered. Harris and Covington (1983) found that following a fall-prescribed fire in 

ponderosa pine in Arizona understory vegetation appears to have increased nutrient availability, 

stimulating understory production and increasing nutrient concentration thus improving forage 

quality for both livestock and wildlife.

Barrier fencing and signage to discourage unauthorized OHV use in meadows may discourage 

use to help prevent future impacts and allow affected meadows time to heal from past impacts.

Cumulative Effects

The effects of structural vegetation restoration activities, channel stabilization and trail restoration 

on meadow ecological status would result in either maintenance of existing condition or become 

expressed as improvement in desired herbaceous species composition (move toward >40 % 

relative abundance of late seral species), vegetative cover (maintain cover at greater than 90% 

cover), depth to water table and rooting depths. The cumulative effects of the proposed action on 

changes to factors affecting meadow ecological status would not be evident immediately after 

project implementation but may become evident over a longer timeframe that may take several to 

up to 10 years. There would be negligible additional effects from past activities and possible and 

likely localized effects from other ongoing activities in the project area to meadow ecological 

status. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 192 Chapter 3

Alternative 3 

Direct, Indirect Effects 

Alternative 3 would only partially address stand density and forest health objectives. The 

meadow restoration component would be the same as Alternative 2 so direct and indirect effects 

on meadow ecological status would be the same. Indirect or cumulative effects from thinning and 

associated benefits from increased water availability would be reduced from what is expected 

under Alternative 2. Since a higher degree of canopy cover would remain after treatment and 

stand densities would remain higher than in the proposed action the forest canopy would not be 

opened as much as under than Alternative 2. Stands would still be opened to allow better access 

by livestock, but stand density would be higher than Alternative 2. The effects of increased light, 

nutrients and reduced competition may benefit the production of herbaceous understory 

vegetation, but to a lesser degree compared to Alternative 2.

Monitoring Recommendations

Establishment of additional long term meadow condition and trend monitoring plots for Texas 

Flat Meadow and Progeny Meadow sites are recommended in order to assess meadow ecological 

status and trend and trend and also to determine the effectiveness of the channel restoration and 

conifer removal on these ecological factors. 

Cumulative Effects

Cumulative effects would be the same as alternative 2. 

Effects to Range Management from proposed changes in treatments

The proposed treatment changes [in Units T-18 and Rx-9] for the FEIS would not change or alter 

the determination of the direct, indirect or cumulative effects on rangeland resources in the 

project area from the DEIS determinations.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 193 Chapter 3

Hydrology/Water Quality _____________________

The direct, indirect and cumulative effects to the Hydrology and Water Quality are summarized 

from the Hydrology and Water Quality report for the Grey’s Mountain Ecological Restoration 

Project (Stone A., 2012)

Affected Environment

Watershed Summary

The majority of the Greys Mountain Project is located in the Willow Creek 5th-field HUC 

Watershed (Figure 19). The north fork of Willow Creek is the principal drainage in the project 

area and flows into Bass Lake, which is three miles south of the project area. NF Willow Creek 

tributaries with the SF Willow Creek approximately 6 miles downstream of Bass Lake, and the 

main stem of Willow Creek flows into the San Joaquin River approximately 0.5 miles 

downstream of Redinger Lake. The western edge of the project area is drained via Nelder Creek 

to the Fresno River. The main tributaries (i.e., 4th-order and higher streams) to NF Willow Creek 

within the project area include Chilkoot Creek and an unnamed perennial creek that originates 

from meadow 504M211 near Greys Mountain. Table 35 provides a summary of the affected 

drainages and associated water bodies in the project area (Figure 20). 

There is a manmade diversion ditch (located near Soquel Meadow Ranch) called the Soquel 

“Siphon”, that was installed in the early 1880’s and was used to divert water from north fork of

Willow Creek to the Willow Creek Mill and a flume that flowed to the California Mill #3 near 

Nichols meadow. After the historic mills in the area closed (probably around the turn of the 

century), the siphon was routed to an un-named 3rd-Order drainage network that eventually 

tributaries with California Creek. From California Creek, the diverted water makes its way into 

Nelder Creek, Lewis Fork, and eventually the Fresno River. The channels associated with the 

siphon have been severely down cut (in some cased by 30+ feet) and the impacts can been seen as 

far downstream as California Creek. Most of the down cutting occurred prior to 1950, and since 

then these systems have reached a somewhat more stable condition.

The MID secured the water right for the Soquel siphon diversion and is allowed to divert up to 50 

cubic feet per second (cfs ) between July and October. The diverted water is used to irrigate 

agricultural lands in Madera County in the Central Valley of California. There is a U.S. 

Geological Survey (USGS) gauging station (11242350) located at the diversion with a period of 

record between 1969 and 1977. A 2011 survey of the siphon conduit (i.e., the connector between 

the historic siphon ditch and the un-named tributary feeding the Fresno River watershed) showed 

the cement conduit to be in poor condition; it should be repaired and cleaned before it is used 

again so streams in the vicinity are not damaged by leakage from the conduit.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 194 Chapter 3

Table 35. Stream mile summaries for all 8th-field subdrainages potentially affected by 

project activities.

Main 

Stream 

System(s

)

Watershed

(5th-Field)

Subdrainage

s

(8th-Field)

Stream miles

Perennia

l 

Intermittent/Ephemera

l

Ephemera

l Tota

l

Fresno 

River

Fresno River

(1804000701

)

503.0056

503.0057

503.3002

503.3051

37 100 225 362

NF Willow 

Creek

Willow Creek

(1804000611

)

504.0011

504.0012

504.0013

504.0014

504.0015

504.0059

504.0060

504.0061

504.3001

504.4051
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 195 Chapter 3

Figure 19. Location of Greys Mountain Project in relation to the Willow Creek 5th-Field 

watershed.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 196 Chapter 3

Figure 20. Stream Side Management Zone (SMZ) and subdrainage map of the Greys 

Mountain Project Area. Color-coded lines represent different stream orders, which are 

offered a protection buffer based on designated class. 

Climate Change: Future Predictions in Hydrology 

Miller et al. (2003) modeled future hydrological changes in California as a function of two 

contrasting Global Climate Models (GCMs) (the same GCMs used in Hayhoe et al. [2004] and 

Lenihan et al. [2003; see below]) and a variety of scenarios intermediate to the GCMs. Miller et 

al. (2003) found that annual streamflow volumes were strongly dependent on the precipitation 

scenario, but changes in seasonal runoff were more complex. Predicted spring and summer runoff 

was lower in all of the California river basins they modeled, except where precipitation was 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 197 Chapter 3

greatly increased, in which case runoff was unchanged from today (Miller et al. 2003). Runoff in 

the winter and early spring was predicted to be higher under most of the climate scenarios 

because higher temperatures cause snow to melt earlier. Flood potential in California Rivers that 

are fed principally by snowmelt (i.e., higher elevation streams) was predicted to increase under all 

scenarios of climate change, principally due to earlier dates of peak daily flows and the increase 

in the proportion of precipitation falling as rain. These increases in peak daily flows are predicted 

under all climate change scenarios, including those assuming reduced precipitation (Miller et al. 

2003). The predicted increase in peak flow was most pronounced in higher elevation river basins, 

due to the greater reliance on snowmelt. If precipitation does increase, streamflow volumes 

during peak runoff could greatly increase. Under the wettest climate scenario modeled by Miller 

et al. (2003), by 2100 the volume of flow during the highest flow days could more than double in 

many Sierra Nevada rivers. This would result in a substantial increase in flood risk in flood-prone 

areas in the Central Valley. According to Miller et al. (2003), increased flood risk is a high 

probability outcome of the continuation of current climate change trends, because temperature, 

not precipitation, is the main driver of higher peak runoff. If climate change leads not only to an 

increase in average precipitation but also a shift to more extreme precipitation, then peak flows 

would be expected to increase even more.

Dettinger (et al., 2004) outlines import considerations and challenges facing land and resource 

managers in the Sierra Nevada. These include:

1. Climate model predictions are unanimous in calling for warming of at least a few degrees 

over the Sierra Nevada, and this warming may be increased over the range by orographic 

effects (that is, effects resulting from the presence of mountains).

2. Projections of future precipitation are much less consistent so that we do not yet know if 

the Sierra Nevada would be wetter or drier.

3. Even the modest climate changes projected by the GCM’s (with a conservative value for 

warming and small precipitation changes) would probably be enough to change the 

rivers, landscape, and ecology of the Sierra Nevada, yielding: (1) substantial changes in 

extreme temperature episodes, for example, fewer frosts and more heat waves; (2) 

substantial reductions in spring snowpack (unless large increases in precipitation are 

experienced), earlier snowmelt, and more runoff in winter with less in spring and 

summer; (3) more winter flooding; and (4) drier summer soils (and vegetation) with more 

opportunities for wildfire.

4. GCM projections suggest that global warming at the accelerated pace that would 

characterize the 21st century is already about 30 years old; thus, changes in the recent 

past must also be considered in light of global change. For example, changes in stream 

flow timing are already known to be widespread across most of the Western states.

Climate change and shifting demographics influence the landscape and the social and economic 

systems of California and the Sierra Nevada. Climate change impacts are already evident, as seen 

in declining snowpack’s, changes in runoff timing and intensity, increasing fire frequency and 

severity, increasing drought frequency and severity, and rising temperatures. Determining the 

changing relationships between climate, various ecosystem components, and social and economic 

system components is critical to identifying management’s role in adapting to new climates 

and/or mitigating the effects of climate change. Past research and the majority of resource 

management approaches assumed an unchanging climate. Opportunities exist to explore the 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 198 Chapter 3

relationship of past climates with historical disturbances such as drought, insects and fire in the 

context of the novel future climates. The consequences of climate change are likely to be 

significant, but in light of current uncertainties about their nature, policies that promote flexibility 

and resilience seem most prudent. 

Sustaining the health, diversity, and productivity of the Sierra Nevada would require adaptation 

and mitigation, as well as collaboration and cooperation across the organizational and geographic 

landscape. This can be best achieved through the adaptive management process, where elements 

under management control can be modified to mitigate impacts for those land use practices to 

better suit the evolution of the landscape in response to climate change; however, since there is no 

consensus on exactly how climate change would affect the Sierra Nevada, it will be crucial that 

annual hydrologic monitoring of the GMER project area be conducted to assess watershed 

condition and provide land managers with site-specific data in order to make informed decisions 

on management change as it relates to project activities.

GMERP Road Survey 

An inventory and hydrologic assessment of the project area road system and its impact to 

watershed function has been conducted for “maintenance level 2” (native surface) roads. 

Approximately 75 miles native surface roads were surveyed by a USFS Enterprise TEAM who 

evaluated and mapped road conditions and the degree of hydrologic connectivity and stream 

crossing bypass potential between the road network and the drainage network. Table 36 shows

the key problem areas, identifies the problem and includes a suggested repair solution and Table 

37 summarizes the general hydrologic connectivity problems by subdrainage and road. Road 

condition has also been noted while accessing areas for stream and subdrainage surveys. Most of 

the roads in the area are designated as “maintenance level 2”, (native surface) roads, which 

require a high degree of maintenance, especially in steeper terrain and/or where the soils are more 

susceptible to erosion. Because of limited personnel and funding, the native surface roads in the 

project area have not been adequately maintained. Most of the roads are in moderate to very poor 

condition with drainage control in various states of disrepair or in need of relocation. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 199 Chapter 3

Table 36. List of priority roads that area causing impacts to watershed function by 

hydrologic connectivity. AOP stands for Aquatic Organism Passage.

Road 

Number

Hydrologically 

Connected?

Length of Road (ft) 

Contributing 

Runoff/Sediment

Nature of 

Problem Suggested Fix

UTM location of 

Problem

Northing / Easting

05S095Y Yes 100+/- Log(s) placed as 

cross-drain.

Remove log(s). Grade 

road, repair ditch, 

install culvert, 18 -24 

in. dia.

4145585.31 273281.53

06S002X Yes 200+/-

Partially plugged 

culvert. Eroding 

road bed. Possible 

flow under 

culvert.

Partially plugged 

culvert, clean culvert. 4146073.10 274191.63

06S013 Yes 0

Shot gun culvert, 

10 ft. No AOP, 

fill bank erosion.

Change angle of 

culvert. Install OSD 

or slope drain with 

armoring. Grade / resurface (steep) entire 

route.

4140620.81 272227.16

06S013B Yes 1 acre +/-

Spring flowing 

down road and 

into plugged 

ditch. Entire area 

at end of route 

wet area.

Grade road, repair 

ditch, install crossdrain, 24 -36 in. dia.

4137945.77 272204.63

06S013B Yes 0 Flow under

culvert.

Grade road, repair 

ditch, install culvert, 

24 -36 in. dia.

4138195.77 272051.49

06S013C Yes 250+/-

Failed rolling dip 

causing gully 

down road into 

stream channel.

Repair rolling dip(s). 

Install 24-36 in. dia. 

culvert. Re-surface 

over culvert.

4137420.36 271504.88

06S036 Yes 250+/-

Spring flowing 

down road and 

into nonengineered OSD.

Grade road, repair 

ditch, install catch 

basin style crossdrain, 18 -24 in. dia. 

May need OSD too. 

Spring on cutbank.

4144308.80 276216.29

06S036 Yes 250+/-

Spring flowing 

down road and 

into nonengineered OSD. 

Log(s) placed as 

cross-drain.

Remove log(s). Grade 

road, repair ditch, 

install catch basin 

style cross-drain, 18 -

24 in. dia. May need 

OSD too. Spring on 

cutbank.

4144309.38 276217.06

06S040 Yes 0

Partially plugged 

culvert. Eroding 

road bed. Possible 

flow under 

culvert.

Repair ditch. Install 

catch basin style 

cross-drain, 18 -24 in. 

dia.

4140335.07 274096.16

06S099A Yes 100 ft. +/-

Spring flowing 

down road and 

into nonengineered OSD.

Grade road, repair 

ditch, install catch 

basin style crossdrain, 18 -24 in. dia. 

May need OSD too. 

Spring on cutbank.

4142936.26 275296.07
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 200 Chapter 3

Table 37. Points of hydrologic connectivity and stream crossings with high bypass potential. 

*A “Non-Functional Culvert” is one that has been identified as being 1⁄2 plugged to 

completely plugged or buried.

Subdrainage Road Drain Points Hydrologically 

Connected to Streams or 

Meadows

Stream Crossings with 

*Non-Functional 

Culverts

503.0056 06S011 3 3

06S013 6 0

06S013Y 4 0

503.0057 06S013F 0 1

06S013H 2 1

06S065 3 0

503.3002 06S011 0 1

06S090 8 1

503.3051 06S011 3 7

504.0011 06S13B 0 2

06S13C 2 0

504.0012 06S006 3 1

06S018 4 1

06S032 3 0

06S040 1 0

06S042 9 2

504.0013 06S040 1 2

06S040X 3 10

06S099 0 6

504.0014 05S095 0 7

05S095Y 1 1

06S002X 0 2

06S072 7 1

06S072Y 2 0

504.0015 06S008 0 3

06S038 8 0

06S099 0 3

06S099A 1 0

504.0060 06S008 1 2

06S008B 3 0

06S011 0 3

06S011C 0 1

06S011X 2 1

06S040 2 5

06S040B 4 0

06S040D 1 0

06S040X 1 1

06S040XA 1 2

06S088 1 0

06S099 0 2

504.0061 06S008 0 5

06S036 1 0

06S036A 1 0

06S038 7 4

06S038C 0 1

06S072 2 0

504.4051 06S008 7 10

06S010X 1 0
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 201 Chapter 3

06S026X 0 1

06S036 12 0

06S095 1 0

Cumulative Watershed Effects

CWE are those effects resulting from the incremental impacts of the proposed action when added 

to past, present, and reasonably foreseeable future actions. Cumulative watershed effects can 

result from individually minor but collectively significant actions taking place over space and 

time. The objective of CWE analysis is to protect the identified beneficial uses of water from the 

combined effects of multiple management activities. 

A CWE analysis was conducted following established protocol, consistent with Regional 

Methodology for CWE assessment described in Forest Service Handbook 2509.22. This method 

assumes that an acre of road represents the greatest (common) management disturbance, and 

normalizes all other activities to this standard, called Equivalent Roaded Acres (ERAs). 

Established coefficients are used to convert acres of other land disturbing activities into ERAs. 

The “ERA %” is the percentage of the watershed that is impacted by roads or road-equivalent 

disturbance. ERA % is calculated by dividing the total ERA’s by the watershed size (in acres). 

Watershed sensitivity is determined by evaluating various geological conditions (e.g., landslide 

potential, soil type, channel bifurcation ratio, etc.), which rates the watershed’s Lower Threshold 

of Concern (or TOC %). For example, a 4% Lower TOC % is considered very sensitive to 

disturbance, 5% moderately sensitive, and 6% as having low sensitivity to disturbance. Thus, if 

the ERA % exceeds the Lower TOC %, then an IDT field evaluation is triggered to determine if a 

CWE response is occurring or could occur as a result of project activities. The upper limit for the 

TOC % is 14%. If a subdrainage has a total ERA % (with the Proposed Action and reasonably 

foreseeable future actions) equal to or greater than 14%, then ground disturbing activity (e.g., 

tractor logging) will be reduced, restricted, or modified, unless otherwise directed by the signing 

official.

Table 38 shows the CWE results for the Greys Mountain Project. Subdrainages over their lower 

TOC% have been inspected for CWE response potential in the field by an IDT or surveyed using 

various methods (e.g., SCI, Pfankuch). All of the subdrainages are considered sensitive to 

moderately sensitive to disturbance (i.e., 4 - 5% Lower TOC %). The baseline or existing 

condition of most of the subdrainages is below the Lower TOC %, but subdrainages 503.0056 

and 503.3051 are over their Lower TOC %. When adding in the proposed action, none exceeded 

the Upper TOC of 14%. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 202 Chapter 3

Table 38. Calculated base ERA % and ERA % with the Proposed Action or Alternative 3.

Subdrainag

e

Subdrainag

e Acres

Lower 

%TO

C

Allotme

nt 

%ERA

Roads 

%ERA

Harvest 

%ERA

Total 

(Existing

) 

Baseline 

ERA%

Proposed 

Action ERA% 

(Includes 

Tractor and 

Rx)

Total 

ERA%

CWE 

Potential

503.0056 1,211 4 1.02 0.96 7.26 9.25 4.27 13.97 Moderate 

to High

503.0057 1,246 4 0.39 0.79 0.10 1.28 0.00 1.28 Unlikely

503.3002 2,472 5 0.62 0.99 1.94 3.55 0.11 3.66 Unlikely

503.3051 1,484 4 0.71 1.20 10.62 12.55 0.15 12.70 Low

504.0011 1,972 4 0.52 1.10 0.29 1.91 2.30 4.21 Unlikely

504.0012 3,033 5 0.66 1.05 0.60 2.32 0.44 2.76 Unlikely

504.0013 1,369 5 0.72 1.11 0.46 2.29 2.04 4.33 Unlikely

504.0014 1,078 5 1.02 1.57 1.34 3.93 1.31 5.24 Unlikely

504.0015 455 5 0.84 1.19 0.57 2.6 6.39 8.99 Low

504.0059 1,866 4 0.48 0.61 0.05 1.13 0.76 1.89 Unlikely

504.0060 2,737 4 0.64 1.43 1.45 3.52 7.27 10.79 Low

504.0061 1,262 5 0.88 1.37 1.14 3.39 3.91 7.30 Low

504.3001 1,496 4 0.61 0.51 0.68 1.81 0.88 2.69 Unlikely

504.4051 1,534 5 0.57 1.31 1.22 3.10 1.08 4.18 Unlikely

Post-harvest prescribed fire is proposed for many of the tractor units within the project area. Reentry could occur any time after the logging operation is complete, but since it is difficult to 

predict when this might occur, a three year re-entry was estimated (i.e., 2015). As such, three 

years was used as a recovery factor for a CWE analysis of the post-harvest prescribed burn. 

Table 39 shows the CWE results.

Table 39. CWE results for post harvest prescribed fire in 2015. The baseline ERA% is 

prorated (i.e., “recovered”) for each year between actions. As a result, the baseline ERA% 

is somewhat reduced.

Subdrainage Subdrainage 

Acres

Lower 

%TOC

Baseline 

ERA%

Proposed

Rx 

ERA%

Total 

ERA%

CWE 

Potential

503.0056 1,211 4 12.01 1.03 13.03 Low to 

Medium

503.0057 1,246 4 1.15 0 1.15 Unlikely

503.3002 2,472 5 3.29 0.04 3.33 Unlikely

503.3051 1,484 4 11.43 0.02 11.45 Low

504.0011 1,972 4 3.79 0.3 4.09 Unlikely

504.0012 3,033 5 2.48 0.36 2.84 Unlikely

504.0013 1,369 5 3.9 0.33 4.23 Unlikely

504.0014 1,078 5 4.71 0.06 4.77 Unlikely

504.0015 455 5 8.09 2.43 10.52 Low

504.0059 1,866 4 1.7 0.28 1.98 Unlikely

504.0060 2,737 4 9.71 1.34 11.05 Low

504.0061 1,262 5 6.57 0.68 7.25 Low

504.3001 1,496 4 2.42 0.11 2.53 Unlikely

504.4051 1,534 5 3.76 0 3.76 Unlikely
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 203 Chapter 3

Subdrainage 503.0056 still has a moderate to high potential for CWE response based on an 

ERA% of 13.03%. Actions may be necessary in this subdrainage post fire to ensure proper 

ground cover and erosion control. Design criteria have been developed to address this potential. 

See design criteria section of the document for more information.

Summary of Conditions

Although there is evidence that past activities that have caused watershed degradation, overall the 

channels and subdrainages appear to be recovering and reaching a state of equilibrium. The 

current condition for most of the stream reaches is good or fair for channel stability using 

modified Pfankuch, after Rosgen (2004) and this has been corroborated with Stream Condition 

Inventory data. There are, however, several areas within the proposed project boundary that are 

unstable and sensitive to disturbance. Specifically, subdrainage 503.0056 has a very high 

potential for CWE response from project activities. As such, ground disturbance from 

mechanized equipment should be minimized in this subdrainage and harvest methodology should 

use a “light-on-the-land” approach

Maintenance level 2 (“native surface”) roads throughout the project area are in moderate to poor 

condition and are hydrologically connected to the watersheds in which they are constructed. 

Many of these roads lack adequate drainage and have partially to completely blocked culverts that 

would require replacement. Bringing system roads up to maintenance level 3 standards should 

address most of these watershed degradation issues, but additional measures (i.e., rocking) should 

be used in subdrainage 503.0056 to mitigate the very high potential for CWE response likely to 

occur as a result of the proposed action. 

Subdrainages over their lower TOC% have been inspected for CWE response potential in the 

field by an IDT or surveyed using various methods (e.g., SCI, Pfankuch). All of the subdrainages 

are considered sensitive to moderately sensitive to disturbance (i.e., 4 - 5% Lower TOC %). The 

baseline or existing condition of most of the subdrainages is below the Lower TOC %, but 

subdrainages 503.0056 and 503.3051 are over their Lower TOC %. When adding in the proposed 

action, none exceeded the Upper TOC of 14%. 

The main stem of Willow Creek has been listed on the State’s 303(d) list of impaired waters for 

temperature, source unknown. The establishment of a Total Maximum Daily Load (TMDL) is 

scheduled for 2019. It is important to note that, as of this writing, the North Fork of Willow Creek 

(and all other perennial drainages) in project are not included or proposed for the State’s 303(d) 

list of impaired waters. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 204 Chapter 3

Environmental Consequences

Alternative 1 - No Action Alternative

Lack of fuels treatments in the project area would result in a lost opportunity to reduce potential 

for uncharacteristic fire. This lost opportunity has the potential to affect not only the 

communities at risk; it also affects the riparian habitat and water quality in the project area. As 

described in the affected environment, riparian areas have large amounts of organic material 

throughout the drainages. This material is not lying on the forest floor; it is intermingled with 

standing material. In the event of a uncharacteristic wildfire, riparian habitat, channel 

characteristics and riparian vegetation would be adversely affected. 

Under the no action alternative, no physical restoration or vegetation treatments would occur in 

the project meadows. Unstable areas within the meadows (such as gullies and headcuts) would 

continue to erode, decreasing water quality, compromising meadow riparian-aquatic habitat, and 

decreasing forage. Continued erosion and/or conifer encroachment could lower the ground water 

tables enough to cause an accelerated successional change from meadow to forest, which is 

outside the range of natural variability.

Direct Effects and Indirect Effects

Effects of no action alternative would be continued increase of fuels and potential for 

uncharacteristic wildfire, continued degradation of unstable meadow systems, and continued 

watershed impacts from a highly degraded road network. There would be basin wide increases of 

fuels and potential for uncharacteristic wildfire and continued watershed and water quality 

impacts from a highly degraded road and unstable meadow systems.

Cumulative Effects 

Cumulative effects of no action would be displayed under the pre project condition of the CWE 

analysis (Table 38). Essentially the only watershed considered a candidate for CWE response is 

subdrainage 503.0056, which is 1,211 acres and is drained by an un-named tributary to Nelder 

Creek. Much of the water flowing through this subdrainage is sourced from a series of perennial 

springs near the Sivils Ranch. 28% of this watershed has proposed project activity including 148

acres of tractor logging, 113 acres of prescribed fire, and 55 acres of mastication and 24 acres of 

hand thinning. An un-named stream (tributary to Nelder Creek) was inspected near the 

subdrainage outlet and was evaluated for CWE response potential by an IDT. Field observations 

showed that the channel is entrenched with approximately 1.0 - 1.5 meters of incision and terrace 

banks that are unstable in many locations. Sloughing of bank material and the “Jack-Strawing” of 

trees is common. The active channel within the entrenched area shows sign of equilibrium and a 

trend towards a more stable channel form, but the system is at present still unstable. Cursory 

depth measurements of fines in pools in relation to pool depth suggests an excess level of fines 

(>20%) is present and the channel has not achieved equilibrium subsequent to past disturbance. 

The presence of several large stumps on the bank and the age of the conifers in the stand suggest 

this area was widely cutover in the past, including the streamside management zone.The riparian 

zone is complex with multiple canopy layers and is well shaded. No SCI survey was conducted 

on this reach, but a Pfankuch survey classified and rated the channel as a G5 with a numeric score 

of 131 (i.e., a poor stability rating).

Baseline CWE (ERA %) for this subdrainage is high at 9.25%, which resulted from past timber 

harvest activity. With the no action alternative, no tractor related ground disturbance or 

prescribed fire would occur, which, (given sufficient time), would allow the subdrainage to 

recover and stabilize.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 205 Chapter 3

Alternative 2 - Proposed Action

Table 40. Acres of activities proposed within project area subdrainages under Alternative 2 

(approximate maximum acres generated by GIS).

Limited or no direct treatment would occur in SMZ’s. In general, all vegetation and fuel 

treatments conducted in RCA’s would focus on improving forest health, enhancing or 

maintaining hydrologic function and maintaining or enhancing the key attributes of riparian 

habitats. Attributes comprise cool, moist soil conditions; high water quality; retention of large 

snags and down logs in sufficient quantities to provide habitat and woody debris recruitment in 

stream channels; and retention of woody material to provide stability to riparian and aquatic 

habitats. Well-functioning channels have good riparian vegetation, good sediment transport, and 

stable streambanks. These characteristics work together to maintain channel function and 

stability.

A wide range of activity-specific BMP’s (Appendix B) are designed to minimize detrimental soil 

disturbance, protect water quality, maintain physical stability, and hydrologic connectivity of 

riparian and aquatic habitats. There is little potential for the Proposed Action (Alternative 2) to 

adversely affect the geomorphic, hydrologic, or riparian characteristics and aquatic habitats in 

affected subdrainages because of the low-impact characteristics of the proposed stand treatments, 

the limitations that would be imposed on operations within RCA’s and SMZ’s, and the use of 

activity-specific BMP’s (Appendix B). The proposed meadow restoration activity would reduce 

the amount of erosion and impacts on water quality for downstream beneficial use, and thus 

would be a proactive protective measure to watershed resources and forest health. The restoration 

and maintenance of project area stock drive trails, OHV routes, and systems roads would also 

improve watershed condition and move the watershed and its subdrainages toward desired 

condition.

The greatest potential for the proposed action (alternative 2) to affect the hydrologic connectivity 

of streams and aquatic habitat exists at stream crossings or in subdrainages that have the potential 

for a CWE response. To minimize the potential for project-related effects on hydrologic 

connectivity, existing crossings would be used whenever possible. In the event that it is necessary 

to construct a temporary crossing, the methods used for construction would be selected to avoid 

or minimize detrimental soil and vegetation disturbance and to maintain hydrologic connectivity 

between upstream and downstream features. All temporary crossings would be removed 

following the completion of project-related activities and would be treated as necessary to restore 

to pre-project conditions. Implementation of the activity-specific BMP’s (Appendix B) would 

further ensure that hydrologic connectivity in streams and special aquatic features are not 

adversely affected by the proposed action. 

Subdrainage

503.0056503.0057503.3002503.3051504.0011504.0012504.0013504.0014504.0015504.0059504.0060504.0061504.3001504.4051

Tractor 148 0 18 7 120 230 151 88 241 73 984 301 33 74

Rx Fire 216 0 0 0 0 0 0 0 0 0 230 0 0 0

Mastication 55 14 0 0 82 20 18 0 0 0 126 0 0 3

Hand 

Thin/Hand Rx 24 0 13 15 0 13 94 0 0 40 19 0 4 0

Subdrainage

Acres 1211 1246 2472 1484 1972 3033 1369 1078 455 1866 2737 1262 1496 1534

%Subdrainage 28% 1% 1% 1% 10% 9% 19% 8% 53% 6% 50% 24% 2% 5%
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 206 Chapter 3

Temporary Roads

Approximate 1500 feet of temporary road is proposed for construction in unit T-8. This T-unit is 

in subdrainage 504.0011, which has a low total ERA% (4.21%) and is unlikely to experience a 

CWE response from project activities. Construction of temporary roads would follow all Water 

Quality BMPs (BMP 2-22), and be closed and/or obliterated upon completion of project 

activities. As such, no direct, indirect or cumulative impacts are expected.

Common to All Subdrainages

No new permanent system roads are proposed to be constructed as part of the Greys Mountain

Project because there are sufficient numbers to provide the necessary access to each of the 

treatment units (except in unit T-8). The existing road system, however, is currently in poor 

condition and in need of maintenance. In their current state of disrepair, the roads in the project 

area are increasing hydrologic connectivity, contributing to increased sediment input and causing 

overall watershed degradation. As part of the Timber Sale contract, all the roads to be used for 

project activities will be brought up to a maintenance level 3 standard (BMP 2-22). This includes 

maintaining roads in a manner that provides for water quality protection by minimizing rutting, 

failures, sidecasting, and blockage of drainage facilities, all of which can cause erosion, 

sedimentation, and deteriorating watershed conditions. Roads needed for project activities would

be brought to current engineering standards of alignment, drainage, and grade before use, and 

would be maintained through the life of the project. Roads would be inspected at least annually to 

determine what work, if any, is needed to keep ditches, culverts, and other drainage facilities 

functional and the road stable.

Direct Effects

Direct effects are those occurring at the same time and place as the triggering action. The 

proposed action (Alternative 2) could directly affect aquatic resources, primarily as a result of 

vegetation removal, temporary road construction, slash piling, and prescribed fire immediately 

following treatment; such activities could lead to soil disturbance and its associated effects on 

aquatic habitats (e.g., accelerated erosion and sedimentation). Any soil displacement, 

compaction, or change in ground cover would cause a direct effect on watershed condition and 

aquatic habitat. Most treatment units have avoided crossing stream channels. The exception is 

Class V ephemeral draws. Fuels treatments have been laid out to utilize designated and/or 

existing crossings. Figure 20 displays SMZ’s assigned to streams in the GMER project area. 

Stream courses are to be protected under Clause 6.5 of the Timber Sale Contract. Any 

additional streams identified during operations would receive protection appropriate for the 

stream and the treatment. As shown in Table 38 subdrainage 503.0056 is the only subdrainage 

with high CWE potential and therefore it is the only subdrainage that needs further discussion 

of potential effects.

Subdrainage 503.0056

Subdrainage 503.0056 is 1,211 acres and is drained by an un-named tributary to Nelder Creek. 

Much of the water flowing through this subdrainage is sourced from a series of perennial springs 

near the Sivils Ranch. 28% of this watershed has proposed project activity including 148 acres of 

tractor logging, 216 acres of prescribed fire, 55 acres of mastication and 24 acres of hand 

thinning. An un-named stream (tributary to Nelder Creek) was inspected near the subdrainage 

outlet and was evaluated for CWE response potential by an IDT. Field observations showed that 

the channel is entrenched with approximately 1.0 - 1.5 meters of incision and terrace banks that 

are unstable in many locations. Sloughing of bank material and the “jack-strawing” of trees is 

common. The active channel within the entrenched area shows sign of equilibrium and a trend 

towards a more stable channel form, but the system is a present still unstable. Cursory depth 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 207 Chapter 3

measurements of fines in pools in relation to pool depth suggests an excess level of fines (>20%) 

is present and the channel has not achieved equilibrium subsequent to past disturbance. The 

presence of several large stumps on the bank and the age of the conifers in the stand suggest this 

area was widely cutover in the past, including the streamside management zone.The riparian zone 

is complex with multiple canopy layers and is well shaded. No SCI survey was conducted on this 

reach, but a Pfankuch survey classified and rated the channel as a G5 with a numeric score of 131 

(i.e., a poor stability rating).

Baseline CWE (ERA %) for this subdrainage is high at 9.25%, which resulted from past timber 

harvest activity. With the proposed action (i.e., tractor harvest and prescribed fire) the ERA% is 

13.97%, which is high but still below the upper threshold of concern (14%), and, based on the 

current channel stability condition, the likelihood of a CWE response is considered moderate to 

high. A modified approach to traditional tractor logging may reduce the overall impact, which 

could include cut-to-length (CTL) harvesting, helicopter or cable logging; however, these 

methods or equipment may be unavailable or deemed cost-prohibitive. 

Post-harvest prescribed fire is proposed for many of the tractor units within the project area. Reentry could occur any time after the logging operation is complete, but since it is difficult to 

predict when this might occur, a three year re-entry was estimated (i.e., 2015) and used as a 

recovery factor for the CWE analysis. CWE response is low to unlikely for all subdrainages 

except 503.0056. Even with a three year recovery, the upper threshold of concern (14 percent) for 

503.0056 is still being exceeded (15.83 percent). Thus, Subdrainage 503.0056 still has a moderate 

to high potential for CWE response. Additional mitigation measures may be necessary in this 

subdrainage post fire to ensure proper ground cover and erosion control. Please refer to the design 

measures section of the document for more information.

Indirect Effects

Indirect effects are those that occur at a later time or at a distance from the triggering action. 

Indirect effects are expected to be minor. Conservation measures incorporated into the project 

would be implemented to control erosion and sedimentation. The implementation of BMP’s 

(Appendix 1) would avoid or minimize potential increases in sediment loads to streams during 

project implementation such that prescribed fires are not expected to affect aquatic habitats. Over 

the longer term, potential adverse effects on water and soils from implementing the Proposed 

Action are expected to be minor, and substantially less than if an uncontrolled wildfire were to 

occur.

Cumulative Effects 

Subdrainages over their lower TOC% have been inspected for CWE response potential in the 

field by an IDT or surveyed using various methods (e.g., SCI, Pfankuch). All of the subdrainages 

are considered sensitive to moderately sensitive to disturbance (i.e., 4 - 5% Lower TOC %). The 

baseline or existing condition of most of the subdrainages is below the Lower TOC %, but

subdrainages 503.0056 and 503.3051 are over their Lower TOC %. When adding in the Proposed 

Action, none exceeded the Upper TOC of 14%. A modified approach to traditional tractor 

logging in T-Units 7 and 16 may reduce the overall CWE impact. Moreover, addressing the 

hydrologic connectivity and stream bypass problems identified in the system roads survey (Table 

38) would also move the subdrainage to a more stable condition.

Post-harvest prescribed fire is proposed for many of the tractor units within the project area. Reentry could occur any time after the logging operation is complete, but since it is difficult to

predict when this might occur, a three year re-entry was estimated (i.e., 2015) and used as a 

recovery factor for the CWE analysis. CWE response is low to unlikely for all subdrainages 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 208 Chapter 3

except 503.0056. Even with a three year recovery, subdrainage 503.0056 is still somewhat high at 

(13.03%) but well below the upper threshold of concern of 14%. Additional mitigation measures 

may be necessary in this subdrainage post fire to ensure proper ground cover and erosion control. 

Please refer to the design measures section of the document for more information.

Alternative 3 – Lower and Limited Mid-Level Canopy Treatments, All 

Treatment Areas 

Direct Effects

The direct effects would be less than those described under Alternative 2, in that there would be 

less impact because the thinning methodology would only concentrate on ladder and surface fuels 

within the lower and mid-canopy levels, and not include commercial thinning.

Indirect Effects

Indirect effects of Alternative 3 are expected to be similar to Alternative 2 as the actions are 

similar related to actions that affect hydrologic resources.

Cumulative Effects 

Subdrainages over their lower TOC% have been inspected for CWE response potential in the 

field by an IDT or surveyed using various methods (e.g., SCI, Pfankuch). All of the subdrainages 

are considered sensitive to moderately sensitive to disturbance (i.e., 4 - 5% Lower TOC %). The 

baseline or existing condition of most of the subdrainages is below the Lower TOC %, but 

subdrainages 503.0056 and 503.3051 are over their Lower TOC %. When adding in the Proposed 

Action, none exceeded the Upper TOC of 14%. A modified approach to traditional tractor 

logging in T-Units 7, 16, may reduce the overall CWE impact. Treatment methods could include 

cut-to-length (CTL) harvesting, helicopter or cable logging, however these methods or equipment 

may be unavailable or deemed cost-prohibitive. 

Riparian Conservation Objectives Consistency Analysis

A consistency review of the applicable Riparian Conservation Objective (RCO) S&Gs was 

conducted to ensure that project activities adhered to the 2004 SNFPA. There may be an increase 

in hydrologic connectivity and watershed impact from roads under Alternative 1 (No Action), 

which would not be consistent with RCO S&G 100 and 101. RCO S&G 105 is not consistent 

under Alternative 1, and would leave conifer encroached meadows untreated, which is beyond the 

range of natural variability and desired condition. RCO S&G 111 would not be consistent under 

Alterative 1, and increase the risk of catastrophic wildfire in riparian areas. All other applicable 

RCO S&Gs are consistent with all alternatives. The complete RCO consistency analysis is 

available in the project file. Stone A, 11/2011

Effects to Aquatic Biota from proposed changes in treatments

Strategic application of prescribed fire has a substantially lower cumulative watershed (CWE) 

impact than tractor thinning. The disturbance coefficient for prescribed fire has been determined 

to be an order of magnitude lower than that for tractor disturbance and so a re-calculation of 

CWE would show a lower Equivalent Roaded Acre (ERA) impact over the watershed and thus a 

much lower chance of a CWE response. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 209 Chapter 3

Forest Vegetation/Silviculture _________________

The direct, indirect and cumulative effects to Forest Vegetation are summarized from the Forest 

Vegetation /Silviculture report for the Grey’s Mountain Ecological Restoration Project (Smith D., 

2012)

Affected Environment

Existing Condition

The Greys Mountain Project area has a history of past heavy logging activities. Between 1881 

and 1892 a mill in the Soquel area operated by the Madera Flume and Trading Company 

harvested timber within the project area. A flume carried processed lumber through portions of 

the project area. In 1899, the Madera Sugar Pine Co. acquired the assets of the Madera Flume 

and Trading Company. Around 1926-1927 heavy railroad logging was carried out by the Madera 

Sugar Pine Co. through a sizeable portion of the project area. Logs from railroad logged stands 

were transported to the mill at Sugar Pine over its 140 miles of track. The mill operated for 32 

years averaging a 40 million board foot cut each year. Seven locomotives and 100 log hauling 

cars were in use during its peak. In 1900, when the Madera Sugar Pine Co. first began logging, it 

owned 21,616 acres of timberland in Madera and Mariposa Counties including land near 

Wawona, now a part of Yosemite National Park. In subsequent years it purchased additional 

timberlands as well as Forest Service timber. A significant proportion of the lands within the 

project area were private timber holdings at the time they were railroad logged. (Johnson, 1974)

During the railroad logging at the beginning of the last century, logs were yarded by a system of 

cable settings. Deep gouging occurred in a number of places where logs dug into the soil as they 

were yarded to landings. As logs approached landings, more soil was generally displaced. In 

many cases, this reduced soil depths to almost bare rock. Settings can often be distinguished by a 

lack of conifer reproduction and an abundance of brush still today. However, between 

cableways, existing reproduction was often protected from damage. Logging slash was not 

treated following harvest. Today, much of this early reproduction remains as stands of generally

young, even aged, 90 to 110 year old 6 to 24 inch dbh white fir, incense cedar, sugar pine, and 

ponderosa/Jeffrey pine. Scattered larger diameter trees left during the railroad logging days can 

be found through portions of these stands. 

During the 1960s, a significant effort was made throughout California to reforest previously 

forested areas that were understocked. As a part of this effort to reforest understocked areas, 

several ponderosa/Jeffrey pine plantations were created within the project area towards the end of 

this time period. Between the 1960s era plantations and those created in the late 1980s to early 

1990s, approximately 1450 acres of plantations are present within the project area.

In 1980, an approximately 24 acre forest genetics pine plantation was established within the 

project area. Genetically superior ponderosa pine trees representing elevations from 4300 to 

5600 feet and several different seed zones were planted at varying spacings. Several light 

precommercial thinning treatments have since taken place within this plantation over the course 

of this study. 

In order to accelerate the development of key habitat and old forest characteristics and reduce the 

risk of loss to wildland fire (SNFPA ROD (USDA-FS 2004b, p.49), precommercial thinning and 

release treatments have begun to be undertaken within certain plantations within the Greys 

Mountain project area. A 275 acre thinning and release mastication contract was awarded this 

past fall to treat a number of 20 to 25 year old plantations. An additional 400 acres of 20 to 40 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 210 Chapter 3

year old plantations are planned to be thinned and released by mastication over the next several 

years. 

Although pockets of older trees can be found scattered through the proposed project area, past 

railroad and other logging have resulted in little of the area being vegetated with trees older than 

130 years. The natural stands proposed for thinning within the project area generally consist of 

approximately 90 to 110 year old trees that were young, shade tolerant saplings growing beneath 

the overstory trees during the railroad logging era. The majority of wild stands are presently 

considered to be mixed conifer types. These stands, once heavy to more fire resistant, shade 

intolerant, ponderosa and sugar pine, have become very heavy to less fire and drought resistant fir 

and incense cedar. Plot data indicates that in many areas white fir and incense cedar comprise 40 

to 80 percent of the basal area sampled. Mixed conifer aggregations and stands occupy areas near 

cooler, damper, draws and at the mid elevations within the project area. White and red fir stands 

are present at the higher reaches of the project area. Pine, mixed conifer and white fir stand basal 

area stocking varies from 120 ft2 per acre in more open areas to oak pockets to densely stocked 

pockets of 350-400 ft2 per acre or more. Conifer canopy cover varies substantially across the 

project area. Conifer canopy cover ranges from quite dense (80-100%) in overstocked areas to 

clumpy dense patches in less uniformly stocked areas to more moderate (50-70%) to fairly light 

in other locations. Brushfields, mainly the result of early logging, are found within the project 

area. Low site, rock outcrops, and past harvest activities have all contributed to stand 

heterogeneity present today. 

Exclusion of fire from the vast majority of the area has resulted in the development of multilayered stands. The understory layers consist of shade tolerant fir and incense cedar beneath 

young growth stands of incense cedar, white fir, sugar pine and ponderosa/Jeffrey pine with, in 

some cases, an additional layer of brush beneath or adjacent. 

Climatic Shifts

Ferrell (1996) stated in the drought portion of his report on the effects of insects and pathogens on 

forests that tree ring and lake level studies have established that compared to the previous two 

centuries weather during the 20th Century was relatively moist without the decades-long droughts 

that occurred earlier. The period 1937-1986 was the third wettest half century in the last 1,000 or 

more years (Stein, 1996) (Graumlich, 1991). Laudenslayer and Skinner (1995) further confirmed 

that “much of the 20th Century was very moist and relatively warm.” Beginning in the 1970’s 

temperatures began to warm noticeably. This warming resulted in a greater fraction of the Sierra 

Nevada precipitation falling as rain rather than snow, earlier snowmelt and earlier streamflow 

peaks (van Mantgem, 2009)(Knowles, et al, 2006)(Stewart, et al, 2005). This shift appears to be 

the result from still longer term climate shifts (Knowles, et al, 2006). The combination of 

reduced stand vigor and excessive stocking combined with increasing temperatures and 

decreasing soil moisture availability is greatly increasing the threat of loss due to mortality from 

insect attack, diseases, competition, or fire (SNFPA 2004 ROD). North (2009) states that “climate 

will become more extreme, suggesting oscillations between wet and drought conditions will be 

more common.” He goes on to express that “drought stress would make current, high-density, 

Sierra forests more susceptible to pest and pathogen mortality, particularly from bark beetles 

(Ferrell 1996, Fettig, et al. 2007, Maloney, et al 2008, Smith et al. 2005)”.

The wetter than normal 20th Century (SNFPA, 2004) coupled with the exclusion of fire has set the 

stage for stands to become overcrowded with competing conifers, oaks and other vegetation. 

Wide swings in weather conditions over the past thirty years have placed stress on many of these 

stands. Inter tree competition, drought, rising temperatures, and insect attacks are beginning to 

take a toll on both plantation and wild stand trees. White pine blister rust has also been killing a 

number of sugar pine over the past ten to fifteen years. Dead and down fuel loadings have been 

on the rise. These conditions are not unique to the project area. More extreme examples can be 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 211 Chapter 3

found in the Lake Tahoe Basin, San Bernardino National Forest and in Arizona and New Mexico 

where entire stands of trees are dying. In southern California the amount of ponderosa pine 

mortality associated with western pine beetle, D. brevicomis Le Conte, infestations reached 

unprecedented levels after years of extended drought (Fettig, 2007).

Laudenslayer and Skinner (1995) reported that fire suppression, climate shift and human 

disturbance patterns in the last 100 years has resulted in increased tree densities, changes in stand 

structure and spatial patterns, and buildups of dead, flammable material. Their report also stated 

that “although, outbreaks of insects occurred prior to European settlement, they were relatively 

brief and spatially confined.” “These same insects now are affecting entire landscapes nearly 

continuously.” They point out that many forests are in poor health. Large acreages are densely 

stocked and outbreaks of insects and other mortality agents are causing extensive amounts of tree 

mortality especially in white fir and ponderosa pine over short time periods.

Recurrent droughts are characteristic of the Sierra Nevada climate. Summers are usually hot and 

dry, with the bulk of the precipitation occurring in winter, much of it as snow. But in addition to 

the dry summers, there have been droughts of one or more years’ duration in every decade of the

20th Century. Increased mortality usually occurs first at the lower and middle elevations on both 

western and eastern slopes of the range and spreads to the upper elevations only if the drought is 

protracted. During droughts, lack of spring precipitation has a particularly large influence, not 

only by increasing the susceptibility of the trees, as indicated by their rates of growth and beetlecaused mortality, but also probably aiding dispersal of and host selection by the flying beetles. In 

the ponderosa pine type because of the relatively low elevation, water availability, not 

temperature, is the strongest factor limiting forest growth (Ferrell, 1996).

As stated previously, beginning in the 1970s temperatures began to warm noticeably. Seasonal 

snowmelt and streamflow is projected to occur a month earlier during the current century. By the 

end of the 21st Century, 30% less water is anticipated to arrive in reservoirs between April and 

July. Soil moistures would dry out earlier and by summer would be more severely depleted. 

Substantial changes in extreme temperature episodes (fewer frosts, more heat waves) are 

anticipated (Dettinger, 2004). “Climate changes and, in particular, temperature, are playing a 

dominant role, as moderate temperature changes mostly affect mid elevation snowmeltdominated basins most susceptible to melting” (Stewart, et al, 2005). Over the past 17 to 29 years 

noncatastrophic mortality rates were found to have doubled over a series of 76 western forest 

plots which sampled undisturbed, 200 year and older stands. Increasing mortality rates could 

result in substantial changes in forest structure, composition, and function. A persistent doubling 

of background mortality would cause a >50% reduction in average tree age in a forest, and a 

potential reduction in average tree size (van Mantgem, 2009). Van Mantgem (2007) attributes the 

observed mortality to regional warming rather than a response to crowded understory. Current 

projections of warming climates provide a greater opportunity for fire ignitions due to longer fire 

seasons. A higher probability of fire starts coupled with the changes in forest fuel conditions that 

occurred over the past century lead many to predict that large, generally more intense fires would 

become more likely than occurred historically (Skinner and Stephens, 2004).

Desired Condition 

The SNF-LRMP as amended by the SNFPA, 2004 ROD, addressed the desired condition, 

management intent and management objectives for individual land allocations. These were 

brought forward in the Fresno River Landscape Analysis (July 2005) written for the area 

immediately north of the project area. 

Located predominately at mid elevations, the project boundary encompasses many different land 

allocations, some with specific desired conditions, i.e. spotted owl/goshawk/pacific fisher habitat 

and some with generalized desired conditions. In effect, all center on the need to restore both the 
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structure and processes of old forest habitat ecosystems as a long-term goal and with short-term 

strategy of reducing the adverse effect of wildfire and reducing stand susceptibility to

insects/pathogens, competition and drought-related tree mortality through density management. 

A higher percentage of more fire resistant, shade intolerant tree species (pines and oaks) would be 

present in the stand. Stand densities would not only be maintained at levels that would be more 

resilient to predicted changes in weather patterns but also improve perpetuation of healthy 

intolerant tree species. Residual tree diameter and height growth would be increased enabling 

them to acquire old forest characteristics (larger size) more rapidly. Stands would more closely 

resemble those present prior to the heavy railroad logging era.

Density Management Measures

Basal Area Stocking Levels

Normal Yield Tables, generally described in Basal Area per acre, display the maximum basal area 

a site can support for a given species, site quality and age (Oliver, et al, 1996). A normal stand—

or fully stocked stand—is a stand that, so far as any practical consideration is involved, utilizes its 

site completely. Maximum stocking is not implied; it practically never exists over a continuous 

area of more than a few acres (Meyer, 1938). For a short period of time, basal areas in excess of 

“normal” can be maintained in some areas. These “normal” stocking levels were calculated 

during the abnormally wet 20th Century (SNFPA, 2004) and are likely too dense to be maintained 

during the predicted longer, hotter, more moisture stressed summer seasons that are predicted to 

occur as described in the Climate Shifts section. Fairly recent studies have indicated that the 

exclusion of fire may have also resulted in normal basal area densities in excess of what would 

have been found during previous centuries. (Kilgore, 1979)(Parsons, 1979)(Bouldin, 

1999)(Fitzgerald, 2005)(Taylor, 2006)(North, 2009)

Four different species specific yield tables, still used today, are being used to determine normal 

stocking within the project area: 

• Yield of Even-aged Stands of Ponderosa Pine, Technical Bulletin No 630, Meyer, 1938 

(Slightly Revised 1961). 

• Preliminary Yield Table for Second-growth Stands in the California Pine Region, 

Technical Bulletin 354, Dunning and Reineke, 1933 (Mixed Conifer). 

• Yield, Stand, and Volume Tables for White Fir in the California Pine Region, Bulletin 

407, Schumacher, 1926.

• Growth Models for Ponderosa Pine: I. Yield of unthinned plantations in northern 

California, Research Paper, PSW-133, Oliver and Powers, 1978.
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Figure 21. Yield Tables for Ponderosa Pine from Meyers Bulletin 630.

Figure 21, from Meyer’s Ponderosa Pine Yield Table, Bulletin 630, provides an example of one 

of the yield tables used for this analysis. Meyer’s Figure 4 displays basal area per acre curves 

for different sites and ages. Meyer’s Table 4 displays the same information in tabular form. 

Note that except for the very highest growing site (160—uncommonly high site quality), maximum 

basal area per acre is reached by age 60 on a fully occupied site. Total basal area does not 

increase beyond this point as the stand ages as additional basal area growth is offset by basal 

area loss due to mortality. 

As stands approach 80 to 90 % of full stocking, basal area growth rates begin to decline 

significantly, stand vigor begins to suffer, and susceptibility to insect and disease attacks and 

drought stress increases. To reduce growth losses, maintain more viable stands, and retain 

canopy covers less susceptible to crown fires, this project would thin stands to stocking levels that 

with growth would result in reaching 80 % of normal in 15 to 20 years when the next thinning 

entry would need to take place. 
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Utilizing basal area to describe desired stocking automatically takes into account varying 

diameters of trees within stands. For a given basal area, more trees per acre are retained in the 

residual stand in areas with smaller diameter trees than in areas of larger trees. The silvicultural 

prescriptions for ponderosa pine, mixed conifer and fir would be described utilizing basal area per 

acre. 

Figure 22 Displays stand thinning needs over time as basal increases

Figure 22(Smith 1962, 1986) displays a series of thinning entries over time. The upper line in the 

case of this Project represents 80% of normal. The lower line is the target leave basal area. The 

dashed line represents growth after thinning followed by the next thinning entry. Note the 

expected increase in basal area growth as residual trees capture the increase in available 

nutrients and soil moistures.

The desired condition for stocking levels and the measure used for comparison of alternatives is:

 Average basal area in pine, mixed conifer, and white fir grouped by lightly and heavily 

stocked aggregations

• Average potential basal area growth

• Basal area following thinning—ponderosa pine—150 ft2 per acre (50% normal)

• Basal area following thinning—mixed conifer—210 ft2 per acre (60% normal)

• Basal area following thinning—white fir—240 ft2 per acre (60% normal)
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Stand Density Index

Another approach to stocking density management is Stand Density Index (SDI). This method 

compares stocking density to the maximum number of stems found by species which is 

substantially greater than that utilized for normal yield. Mortality studies completed in pine stands 

have been described using this density management approach rather than normal yield tables. 

Since SDI was used as a frame of reference for ponderosa pine in these studies, it would be used 

along with basal area to describe the silvicultural prescriptions for pine stands. SDI studies 

(Long, 2005) have determined that the onset of competition between trees begins when stands 

reach a SDI 100. Long’s study suggests that at a SDI 150 the lower limit of full site occupancy 

begins. Oliver (1995,2009) suggests that beetle kills from endemic populations can begin when 

stands reach a SDI 230—approximately 150 ft2 basal area/acre. He defines a SDI 230 as the 

threshold for a zone of imminent bark beetle mortality within which endemic populations kill a 

few trees but net growth is still positive. As pine stands approach a SDI 365 (approximately 240 

ft2 basal area/acre), Oliver states that “stands usually suffer large losses from bark beetle 

epidemics—losses that equal or exceed periodic growth”. Oliver defines this as the limiting SDI 

for ponderosa pine as defined by Dendroctonus bark beetles. 

Studies have shown that the vigor of trees in a stand is related to their ability to quickly respond 

to thinning and their susceptibility to various pests (Larsson, 1983). A live crown ratio of at least 

40 % has been cited for a number of conifers as representing a generally acceptable level of 

individual tree vigor. “Reducing beetle-caused mortality is an important benefit from thinning, 

but thinning must be heavy enough to keep stand density below a certain critical threshold” 

(Cochran, 1999). Susceptibility to excessive tree mortality from bark beetles can be lessened by 

reducing stand density below 150 ft2 per acre in basal area (Sartwell, 1975) (Oliver, 1995). 

Larsson, 1983, states: “a basal area below 34 m2

/ha (150 ft2/acre) provided most trees with a 

vigor level at which they could withstand at least moderate (insect) attack.” Cochran’s 1999 

study states that the critical upper threshold density increases with site quality and is estimated to 

range from SDI 238 to SDI 270. The Cochran, 1999, report states that the “upper management 

zone for this high site, SDI 240, should lower the probability of serious mortality from mountain 

pine beetle and perhaps western pine beetles.” Based on these studies, in order to ensure prompt 

response to thinning, maintain crown ratios above 40 % and minimize mortality, pine stands 

should be maintained between SDI 230-SDI 270 (approximately 150 ft2

-180 ft2 per acre).

For this proposed project, forested stands would meet stocking (as measured by percent of 

“normal” for the given site) and the associated density levels (as measured by basal area for a 

given site) that would maintain or improve growth rates, would increase resistance to mortality 

agents (insects/pathogens/fire/drought) and would provide the potential to begin the perpetuation 

of both the structure and processes of old forest habitat ecosystems. This desired condition 

incorporates both short and long-term goals, but is focused on the need for continued 

maintenance of stands that are healthy and sustainable.

The desired condition for SDI and the measure used for comparison of alternatives is:

 SDI—ponderosa pine SDI 230 (approximately150 ft2

/acre) 

Methodology for Analysis

In determining the existing condition and analyzing the effects of the alternatives associated with 

the project, many sources of information were utilized. These included aerial photography 

interpretation, field verification of stand conditions, sample and cruise plot data validation, 

evaluation and summarization, (CWHR) site-specific vegetation type correction and verification, 

and experience in the implementation of similarly designed past projects. Scientific and research 

documentation was utilized to evaluate the potential effects of all alternatives and in determining 
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the measures to be evaluated for meeting the purpose and need with regards to density 

management to sustain forest health.

The SNFPA 2004 describes the use of thinning from below as the primary silvicultural 

prescription to utilize in managing stand densities to provide resiliency and sustainability during 

drought conditions and climate variations. (SDI) and basal area (ft2

/acre) are used as common 

measures in determining the effects of management actions on coniferous stands. For retention of 

maximum growth and vigor, thinning entries should be timed to occur before growth rates in 

potential leave trees begin to slow. At this point, leave trees are still retaining substantial crown 

ratios and have the greatest potential for maximum growth. Thinning should be undertaken 

before crown ratios drop below 40 % (Emmingham, 1983) (Long, 1985). As competition 

between trees increases, crown vigor decreases. A stand’s ability to respond to thinning 

progressively declines the longer it remains in competition. Some stands proposed for treatment 

are currently at this maximum potential response level while others are beginning to decline and 

should have already been treated. 

For this project, stand density (number of stems per acre) as well as basal area (ft2

/acre) are used 

to determine which stands/aggregations are considered overcrowded and in need of thinning 

(treatment area designation), at what stocking level the stand/aggregation needs to be (desired 

condition), the silvicultural prescription for each alternative and the associated short (immediate) 

and long-term (length of effectiveness of treatment) effects of design criteria (specifically those 

associated with old forest habitat dependent species), and the effects the S&Gs and land 

allocations have on meeting the purpose and need for forest health. A combination of SDI along 

with basal area (ft2

/acre) would be used for ponderosa and Jeffrey pine stands/aggregations while 

basal area per acre would be used to describe treatments for mixed conifer and fir 

stands/aggregations.

Alternative 1 – No Action

Direct Effects

With this alternative, no commercial or precommercial thinning would be accomplished. 

Understory incense cedar, white fir and brush cover would continue to increase in size and 

density. Fuel ladders and competition between trees would increase. Growth rates and vigor 

would continue to decline as stands, or portions of stands, continue to approach or exceed normal 

stocking. Plantations would become highly susceptible to insect and drought induced mortality. 

Shade intolerant pine and oaks would become less vigorous and continue to drop out of the 

stands. Understocked plantations would not be replanted. 

Indirect/Cumulative Effects 

The indirect and cumulative effects on vegetation resulting from vegetation management are 

generally the result of the vegetation management that occurs within the stand/aggregation or 

sometimes the vicinity of the area under consideration. For the Silvicultural aspects of the Greys 

Mountain project, the Greys Mountain project boundary will be used to display 

indirect/cumulative for all alternatives. Wide swings in weather conditions as has been 

experienced over the past thirty years and is predicted to continue to occur would place increased 

stress on these untreated stands. As described in the Climate Shifts section, during droughts, 

increased mortality usually occurs first at the lower and middle elevations on both western and 

eastern slopes of the Sierra range and spreads to the upper elevations only if the drought is 

protracted. This Project is located predominately in mid elevations. Mixed conifer and fir 

aggregations and stands with stocking levels approaching or exceeding normal would become 

increasingly susceptible to mortality especially in periods of below normal rainfall, increased 
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temperatures and longer periods of moisture depleted soils. Excessive stand/aggregation densities 

in ponderosa pine stands would result in the likelihood of heavy mortality. Drought and insect 

induced mortality would escalate. Intolerant tree species (pine and oaks) would become 

increasingly susceptible to being shaded out. Snags and jack-strawed down material would 

increase. Basal area tree growth of only 15 to 20 ft2 per acre would occur over a 15 to 20 year 

period (if excessive mortality does not occur) in more densely stocked aggregations. Forest 

health in the area would decline and elevate the risk of loss due to wildfire. Not only would the 

potential for loss of these stands to insect attack and drought increase, but their ability to respond 

to future thinning would continue to decline as crown vigor deteriorated as treatment was 

postponed. As forest health declines, the likelihood of increased insect attack in these stands 

spreading onto adjacent private property would increase. Experience has shown that no action is 

not without consequence (Fettig, 2007). Doing nothing would result in forests that continue to 

deteriorate over time because wildfire today no longer operates in its historical fashion, that of 

frequent low-intensity surface fires (Fitzgerald, 2005). 

Fuel continuity would not be broken up. Brushfields and over stocked precommercial size 

conifer pockets would not be treated. The threat of fire moving into or out of population centers 

within the WUI would increase, not decrease. The threat of loss of wildlife habitat designated as 

PACs, HRCAs and fisher conservation areas would increase. Agee, 2005, concludes in his report 

that the “no action” alternative is not a risk-free option, as dry climates regularly predispose 

forests to burn in a typical dry summer. He further states that the impacts of “ no action ” in dry 

forest ecosystems must recognize the likelihood of stand-replacing, intense fire where stand 

density has increased and dead fuel accumulated in excess of historical levels. Over the past 100 

years a number of stand replacing fires have occurred within 10 air miles of the project area. 

Fires occurring in 1910, 1923, 1943, 1959, 2001, and the largest, the 43,000 acre Harlow Fire, in 

1961 all required significant funding to reforest portions of the burned landscape. To obtain 

sufficient natural regeneration to reforest an area following a fire, an adequate number of 

relatively evenly distributed seed trees must be present. An adequate number of seed trees per 

acre often do not survive a stand replacing fire. If seed trees are not present, then planting will be 

required to return the landscape to its previously forested state. These plantations tend to be 

heavy to pine due to poor survival of other planted species in these large open sites. Costs 

required to adequately reforest an area often exceed $1000 per acre. 

Lack of density management would result in an increased likelihood of mortality in these stands. 

Mortality would occur over a range of diameters. The need for additional roadside hazard tree 

sales to minimize risks to the public would increase.

Under all three alternatives, certain actions undertaken on nearby private property could have 

detrimental effects on the surrounding forest vegetation. Thinning of pines at the wrong time of 

year, trenching and land leveling during construction projects, piling of green pine slash as well 

as other vegetation disturbance could all adversely affect the surrounding vegetation. Activities 

such as these have resulted in significant conifer mortality in the past. Piling of green pine slash 

as well as cutting and leaving green pine logs on the ground during winter months has resulted in 

bark beetle attacks in the surrounding stands. Trenching and land leveling that disturbs roots of 

adjacent trees often results in increased stress and reduced vigor resulting in eventual mortality of 

these damaged trees and many times insect infestations that spread into the adjoining stand. 

Alternative 2 – Proposed Action 

Under Alternative 2, the development of Strategically Placed Area Treatments (SPLAT’s) would 

occur. Additional areas would be treated to provide a defensible fuels profile near key 

transportation corridors. In addition to those treatments needed to meet fire and fuels objectives, 

treatments would be undertaken to reduce stand densities (basal area and/or precommercially 
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thin) to a level that maintains or improves the growth and vigor of remaining trees. Treatments 

included in this alternative are: thinning from below in conifer stands (either precommercially or 

commercially), and/or masticating excess vegetation (conifers and brush) to reduce lower, midlevel (suppressed, intermediates and codominants) canopy stand densities; masticating brush and 

shrub patches; prescribed burning, both understory and piles; manually reducing noxious weed 

infestations; and site preparing, planting and subsequently hand releasing openings.

As part of the proposed action, design measures common to all alternatives have been 

incorporated and are part of the proposed action. As such, analysis of the direct, indirect and 

cumulative effects of the action alternative addresses not only the proposed action, but the effects 

of these design measures as they relate to vegetation and silvicultural management in the project 

area.

Direct Effects

Commercial thinning needs to be undertaken in portions of these approximately 90-110 year old, 

even aged, young growth stands to reduce competition and provide room for crown expansion by 

removing the more poorly growing trees, excess trees, and fuel ladders from these stands before 

competition results in much additional reduction in growth or competition, insect, disease, 

drought or fire related mortality increases. Thinning would begin to return stand composition of 

the second growth stands to better resemble stands that were present prior to railroad logging. 

Reduced competition would enable residual trees to increase diameter and height growth rates 

enabling them to more quickly acquire old forest characteristics (larger size).
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Figure 23. Example of thinning release

This ponderosa pine was released from competition at 34 years of age. The diameter inside the 

bark at 34 years was 3.9 inches. The diameter inside the bark 21 years later was 14.6 inches. 

Total diameter at 55 years of age outside bark was 16.5 inches. Average diameter growth for 

the first 34 years was 1/10 of an inch per year. Average diameter growth for the last 21 inches 

was 1/2 inch per year. It took 34 years to reach 3.9 inches in diameter without release. In the 21 

years following release the tree grew another 10.6 inches in diameter. Removing sufficient 

competing vegetation as described in the FEIS would free up moisture and nutrients for the 

residual trees to utilize. Thinning as described in the FEIS that creates room for crown 

expansion would allow retention of 40% or greater crown ratios. These more vigorous residual 

trees would be better able to utilize the increased nutrients and soil moistures made available by 

the reduction of competition resulting in increased growth as seen in Figure 23

Studies have shown that active management through thinning is critical to maintaining healthy 

trees that are less susceptible to mountain pine beetle attack. A Feeney (1998) study assessed the 

effects of thinning from below (alone and in combination with prescribed burning) on tree 

growth, leaf physiology and several environmental factors in ponderosa pine on the Gus Pearson 

Natural Area in Arizona. Soil water content was greater in thinned treatments than in the 

unthinned control. Similar findings have been reported in northern Arizona and western 

Montana, and can be attributed to increased water availability resulting from decreased tree 

competition. Trees in thinned treatments had greater foliar nitrogen content, needle toughness 

and basal area increment. The results suggest that restoration treatments improved tree vigor, 

growth and decreased the likelihood of bark beetle attacks on individual trees. A similar study 

compared measures of tree susceptibility to bark beetle attack in thinned ponderosa pine plots in 
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northern Arizona. Phloem thickness significantly increased with decreasing stand density. 

Duration of resin flow and 24 hr resin flow were significantly higher in thinned plots. Increases 

in these variables suggest improved host vigor and reduced likelihood of bark beetle attack. An 

increase in predawn xylem water potential, net photosynthetic rate, foliar nitrogen concentration 

and bud and needle size resulting in increasing foliar growth and uptake of water and nutrients 

was reported in similar stands. It has been noted that phloem thickness and basal area increment 

were lower in unmanaged stands than in managed. Studies have shown that thinning significantly 

reduced the amount of ponderosa pine mortality caused by mountain pine beetle in northeastern 

California (Fettig, 2007) (Egan, 2010). The largest increase in photosynthetic rate and predawn 

water potential increases due to thinning was found to be during periods of drought (Feeney, 

1998). Several studies have shown that thinning from below not only reduces ladder fuels and 

the risk of torching, but by reducing stand density tree vigor is improved and risk to bark beetle 

attack reduced (Fitzgerald, 2005). By reducing competition through thinning, mistletoe infected 

residual trees would experience increased height growth thus slowing the upwards spread of 

mistletoe into tree crowns (Ferrell, 1996). By increasing tree vigor, diseased trees would be 

better able to withstand the effects of drought or insect attack. 

Cochran and Barrett (1995) concluded that mortality in high (ponderosa pine) stand densities may 

be severe and individual tree sizes would be lower than in stands managed at lower densities. 

They stated: “thinning from below to low densities would speed up the development of large trees 

in second growth stands.” They further stated that “once stands reach commercial size, thinning 

to maintain low stand densities would be necessary to reduce the probability of serious problems 

with mountain pine beetles and perhaps western pine beetles (Dendroctonus brevicomis Le 

Conte).” In a follow-up paper, Cochran and Barrett (1999) concluded that mechanical thinning 

would result in greater stand and individual tree growth than would occur through bark beetle 

mortality that resulted in the same overall stand density. The conclusions stated that density 

management (in second-growth ponderosa pine stands) “is necessary to speed development of 

mid and late seral size and density conditions.” They further concluded that a SDI 240 should be 

the upper management zone on a high site and “should lower the probability of serious mortality 

from mountain and perhaps western pine beetles.” Their study also noted that ponderosa pine 

responds well to increased growing space even at advance ages and should continue to grow well 

until stands are very old. 

Oliver (1995) found that Sartwell’s threshold of 150 ft2 basal area/acre above which density 

stands are susceptible to attack by bark beetles appears to be a reasonable average value for 

California. The Larsson, et al (1983) study stated that stocking at 150 ft2 BA/acre “provided 

most trees with a vigor level at which they could withstand at least moderate attack. Maintaining 

stands at still lower stocking levels, as recommended for intensive management by Barrett 

(1979), can ensure a greater margin of safety.” The Larsson study further concluded that “the 

susceptibility of ponderosa pine stand forests to damage from mountain pine beetle is closely 

related to tree vigor, which has been demonstrated to respond to stocking control.”

This entry would commercially thin wild stands on slopes generally less than 35% outside of 

PACs, and OFLs to stocking levels that, with current growth, would result in returning stands to 

80 % of normal basal area stocking 15 to 20 years following harvesting. Maintaining a stocking 

level that remains at 80 % or less of full (normal) stocking would ensure a healthy rate of growth 

while retaining a level of stocking that would be better able to survive the lower levels of yearly 

precipitation that were common prior to the past century. Black oaks would be retained in treated 

stands longer by reducing competition and overtopping by nearby conifers. Treated stands would 

also be less susceptible to weather fluctuations, increasing temperatures and longer summer dry 

spells which are predicted to become more and more prevalent. Reentry in 15 to 20 years was 

chosen for several reasons: (1) reduce the number of entries into the stand, (2) increase the 

volume removed to make the entry more economically viable, (3) open the stand sufficiently to 
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permit harvest operations with a minimum of damage to the residual stand, (4) treat the stand to a 

level where for a period of at least 10 years fires, except under the most extreme conditions, 

would remain as ground fires and not become crown fires as directed by the National Fire Plan, 

(5) retain canopy covers that meet or exceed those directed under the SNFPA 2004 while 

opening the canopy to maintain or improve growth and vigor over 15 to 20 years, (6) plan for 

reentry at a point where stand growth would respond promptly to thinning and provide an 

opportunity to accomplish fuels maintenance treatments as needed.

To obtain some benefits from thinning, while retaining species specific canopy cover levels 

following harvest, thinning in wild pine stands is proposed to generally reduce stocking to leave 

basal areas of around 150 to180 ft2 per acre depending on age, site, and existing crown condition 

(50-60 % of normal--SDI 230-270). This entry would still result in the retention of basal areas 

substantially above the SDI recommendations for thinning. (150 ft2 should be in locations where 

leave trees have full crowns. 180 ft2 per acre should be in areas with poorer crown leave trees, 

higher growing sites, and older trees and in HRCAs.) (Normal stocking for this site and age is 

270 to 290 ft2 per acre.) Portions of stands with larger diameter trees present would generally 

have fewer residual trees per acre than those with smaller diameter trees. Because this entry 

would retain a higher basal area than the desired condition, to maintain stand resiliency, the next 

thinning entry may need to take place at 10 to 15 years in these pine stands rather than the 

planned 15 to 20 as the more limited growing space becomes reoccupied. 

A shaded fuelbreak runs through the western portion of the project area. Thinning is proposed to 

establish or reestablish this fuelbreak in treatment areas T 5, T 8, T 16, T 21, and T 26. Leave 

basal areas within this approximately 300 foot wide fuelbreak would be 150 ft2 per acre. No trees 

30 inches dbh and larger would be removed with this entry. 

The Progeny (Board Ranch) plantation (H 8) is planned to be returned to the district to be used as 

a seed orchard. Trees to be retained are labeled with metal tags displaying seed zone of origin 

and elevation. Seed collected from these genetically superior trees would be used to grow 

seedlings for district planting needs. Due to the need to protect the genetically superior residual 

trees within this stand, past precommercial thinning treatments have been relatively light. The 

precommercial thinning planned with this entry would consist of two light thinnings 

approximately 4 years apart. This would reduce the amount of pine slash created at one time 

resulting in a decreased chance of insect populations building up in fresh slash. Branches, tops 

and boles to 6 inches in diameter would be hand piled and burned. Boles 6 inches and larger 

would be cut into 4 foot lengths and left in place. Upon completion of the second treatment, 

residual basal area would be around 120 to 140 ft2 per acre. 

Where diameter restrictions permit, young growth, approximately 90-110 year old, mixed conifer 

and white fir stands would be thinned to around 55 to 65 % of normal. Leave basal areas, 

depending on site index and age, would be around 210 ft2 per acre (Mixed Conifer) and 240 ft2

(White Fir). (Normal basal area stocking for 90 to 110 year old mixed conifer stands on similar 

sites ranges from 330 to 360 ft2 per acre. Normal for white fir ranges from 420 to 445 ft2 per 

acre). Canopy covers that meet or exceed those directed under the SNF LRMP as Amended by 

the Sierra Nevada Framework would be retained following treatment. To obtain maximum 

growth and reduce fuel ladders, trees less than 10 inches dbh trees not needed for stocking or 

cover for wildlife are planned to be removed with this entry within the treatment areas not 

designated as mastication or prescribed fire only areas. Except for mastication equipment, 

equipment use on slopes greater than 35 % should be avoided.

Thinning to these target basal areas in these approximately 90-110 year old young growth stands 

should result in basal area increases of 70 to 80 ft2 per acre over 15 to 20 years. If thinning did 

not occur, this increase in growth over the same time period would be 15 to 20 ft2 per acre within 
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the more heavily stocked aggregations if mortality does not occur. Figure 23 provides an example 

of the increased diameter (basal area) growth that can be expected as the result of thinning.

As previously discussed, desired leave basal areas would vary by aggregation species 

composition. Pine aggregations would have a lower leave basal area than mixed conifer. Fir 

would retain the highest. By recognizing the variation in species composition within treatment 

units and treating accordingly, stand heterogeneity would be maintained as varying stocking 

levels are retained across the stand. The North, et al, 2009 paper proposes leaving the highest 

density stocking near the bottom of the slope and the least near the ridgetops. Since fir and mixed 

conifer stands more readily occupy the lower, cooler, damper, locations on the slope, the 

proposed retention basal areas would generally result in heavier stocking on the lower slopes and 

lighter stocking as ridgetops are reached. Pine aggregations would retain the least basal area 

stocking. 

Except where retained for wildlife purposes (see wildlife design criteria for descriptions), 

suppressed, intermediate, damaged and diseased then finally codominant trees, in order of 

removal, would be harvested until the prescribed stocking level has been reached. This is known 

as thinning from below as directed in the SNF LRMP as amended by the 2004 ROD and 

recommended in the North, et al, 2009 paper. The poorest quality trees are generally removed 

first, leaving, for the most part, the best trees in the stand. Thinning from below retains the 

majority of the crown cover and generally the largest trees. Many small, poor crowned trees are 

removed during the operation. Some poorer crowned codominant trees are removed, as needed, 

to create openings on one or more sides of other codominant and dominant trees. These openings 

provide room for crown expansion of the residual trees. Without room for expansion, remaining 

tree crowns would become less vigorous resulting in reduced photosynthesis and declining 

growth. Removal of only intermediate and suppressed trees results in “little more than the 

salvage of trees which would inevitably die” (Smith, 1962). Removal of some of the trees that 

compete for the limited water and soil nutrients would make more water and nutrients available 

for the remaining trees. Thinning also opens the stand’s crown canopy, making more light 

available for the remaining trees. The increased water, nutrients, and light that result from 

thinning increase photosynthesis in the remaining trees. More food is produced making more 

carbohydrate available for new cell formation and growth. After competition begins and the 

stand develops all crown classes, removing only intermediate and suppressed trees may not 

significantly reduce the competition faced by the larger dominant and codominant trees. 

Suppressed trees, in particular do not compete significantly with larger trees. Intolerant species 

(pines) require nearly full sunlight to thrive and grow. A successful low thinning removes all 

suppressed, most intermediates, many codominants, and even some dominant trees (Emmingham, 

1983).

The effects of fuel treatments on tree based carbon storage are currently being studied. Healthy 

forests play an important role in carbon sequesterization. Studies indicate that “in wildfire-prone 

forests, tree-based C stocks were best protected by fuel treatments that produced a low-density 

stand structure dominated by large fire resistant pines (Hurteau, 2009). Average stand diameters 

increase significantly following thinning as smaller diameter trees are removed in favor of 

retaining larger trees. Concentrating removal on the smaller diameter trees also reduces fuel 

ladders and susceptibility to fire loss as average residual diameters and fire resistance increases. 

Follow-up treatments to remove precommercial size trees and brush would further reduce stress 

on the remaining stand. The majority of the stocking 10 inches in diameter and larger within the 

project area is comprised of white fir (around 39 %); incense cedar (around 27%) is the next most 

prevalent species followed by ponderosa pine (16%) then sugar pine (13%). Black oak comprises 

around 5 %. Incense cedar and white fir comprise almost all of the precommercial size trees 

within wild stands. Where choices exist, more fire resistant pines would be favored over fir and 

incense cedar as leave trees. In most areas, stand composition following treatment would consist 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

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of a greater percentage of more fire and drought resistant ponderosa and sugar pine as 

recommended in the North paper (2009). 30 inch harvest tree diameter limitations dictated by the 

SNF LRMP as amended by the SNFPA 2004 ROD would, in many areas, result in basal area 

retention levels in excess of proposed residual basal areas. In some cases in pockets of larger 

trees, no trees would be harvested. In these types of thinnings, the smaller size of the product to 

be removed makes harvest operations much more expensive than those where larger trees are 

removed. 

Thinning to the proposed basal areas would result in increased diameter growth and crown 

expansion on the remaining trees as the residual trees respond to reduced competition. Since 

increased diameter growth would occur over fewer stems per acre, substantial increases in 

diameter would result. Repeated thinning would result in larger diameter, taller, healthier 

crowned trees over much shorter time frames than in unthinned stands. Shade intolerant pines 

and oaks would be retained in a more vigorous condition as a result of more available sunlight 

due to reduced competition (Emmingham, 1983)(Oliver, 1996). As the diameters of the residual 

trees become larger and bark becomes thicker, they would become better able to survive a fire 

should one occur Thinning is an effective technique for creating stands that more closely 

represent those present prior to railroad and other extensive logging and the exclusion of fires 

during the 20th Century and better able to withstand changing conditions (North 2009).

Hand and mastication thinning and release of natural stands/aggregations of conifers and 

plantation trees generally less than 10 inches dbh would be undertaken within treatment units as 

part of this proposal. These thinned aggregations would occupy large and small openings 

surrounded by larger trees as described in the North paper (2009). Depending on tree size these 

stands would be thinned to around 150 to 200 leave trees per acre. Hand thinning slash 

concentrations would generally be tractor piled and piles burned. Slash concentrations on steeper 

slopes would generally be hand piled and burned. Areas of only light slash (10-20 tons per acre) 

would be lop and scattered to 18 inches. Stand heterogeneity would be maintained through 

retention of these precommercially thinned clumps as well as untreated clumps on steeper slopes, 

the more dense clumps of larger diameter trees, SMZ’s, archaeological sites, and the 2 to 3 

untreated larger oaks per acre. An estimated 10-15% of the acreage in units actually designated 

for commercial thinning will not be commercially thinned due to these non treatment 

aggregations. In addition, shrub and understory diversity would be retained throughout the project 

area during follow-up treatments through the retention of 15-20 % of the total understory growth 

in approximately 1/10th to 1⁄4 acre pockets within wild stand treatment units. 

Mastication precommercial thinning/release/fuels reduction treatments are proposed for 6 

treatment areas. These proposed mastication areas range from a section of fuelbreak; to 

brushfields and conifer stands; to a red fir reproduction stand; to M 6, a 24 year old, 23 acre 

plantation (736-115). Except for M 3, the red fir stand, depending on tree size these stands would 

be precommercially thinned and released to around 150 to 200 leave trees per acre. Stocking may 

be less in areas of larger diameter trees. M 6 would be thinned to around 260 to 300 leave trees 

per acre. Mastication provides a mulch layer which helps retain additional soil moisture that can 

be utilized by the residual stand. Brush seed requires heat scarification to germinate. Since white 

leaf manzanita is a non sprouting species, in those areas where large white leaf manzanita has 

been masticated below the lowest live limb, reestablishment of manzanita brushfields would 

mostly need to occur through germination of manzanita seed. The masticated mulch layer 

covering the ground would reduce soil temperatures which would assist in keeping brush seed 

dormant and reduce the likelihood of brushfield reestablishment in whiteleaf dominated 

brushfields. In most cases, areas that have been masticated should not be underburned. 

In addition to the Progeny plantation which is proposed for hand thinning, 7 other hand thin areas 

are proposed for treatment. These have been proposed in locations that would connect other 

treatment areas. Several are adjacent to private property. H 1 would connect T 39 to completed 
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treatments within the Graham Mountain project that connect to the Francis Junction Fuelbreak. 

H2, H 3, and H 4, form a DFPZ connecting the fuelbreak in T 8 to T 39. Thinning within these H 

stands would be confined to trees 10 inches dbh and less. Spacing of residual trees, depending on 

size, would generally be around an average of 18 ft (130 trees per acre). Thinning in pine should 

not take place before July 1st or after October 30th. Green pine slash should remain on the ground 

for at least 30 days to allow for drying before piling reducing the risk of insect infestation.

Three campgrounds (Greys Mountain, Texas Flat, and Chilkoot) are located within the proposed 

project area. Hazard tree removal along with some light thinning are proposed in these areas. 

Standard insect and disease measures following Regional direction would be followed during 

treatments. Precommercial thinning to reduce aggregation densities may also be undertaken. 

Slash concentrations would be spot hand piled and burned. Lighter areas of slash would be lop 

and scattered. 

An existing young 31 acre plantation (736-101) is present within the western portion of proposed 

treatment area T 9. The proposed treatment for this plantation is mastication thin and release. 

This plantation should not be included in the underburn treatments proposed for T 9 due to the 

young age and investment made in this stand. 

Underburning is proposed in a number of T treatment areas as well as in Rx underburn treatment 

areas. Hand treatment areas H 2, H 3, and H 4 are proposed for hand thinning and piling with 

some proposed underburning during pile burning. To minimize damage to residual trees, 

underburning in H 2, H 3, and H 4, should be done only after sufficient rains have occurred to 

soak the duff layer around residual trees. Except for H 2, H 3, H 4, Rx 1 and Rx 2, all 

underburning is proposed for spring underburning only. Two burn entries may take place in Rx 1 

and Rx 2 over a 10 year period. The proposed treatment for treatment areas T 18 and Fx 9 was 

changed from commercial thinning to underburning for the FEIS. Much of treatment area Fx 9 is 

vegetated with smaller diameter trees predominated by fir. To minimize excessive damage to 

residual trees, underburning in Fx 9 should avoid aggregations heavy to young fir. Rx underburn 

stands Rx 3, 4, 5, 6, 7, 15, 22, 23, & 24 consist of previously commercially thinned stands where 

follow-up treatments of either hand precommercial thinning and spot piling of slash 

concentrations or mastication precommercial thinning were done. Although slash concentrations 

were previously treated, duff and slash material adjacent to residual trees was left intact. Studies 

have shown that to minimize damage to the residual stand, spring is the best time for prescribed

underburning when fire is being reintroduced into an area with excessive fuel and duff 

accumulations due to past fire suppression activities (Hood, 2010). Several years ago an area of 

advance reproduction was precommercially thinned by mastication in the upper portion of 

treatment area Rx 3. In order to minimize damage to this younger thinned aggregation, 

underburning should be avoided in this area.

Hood’s 2010 report states that “it is speculated that fire exclusion has allowed fine roots to grow 

into accumulated duff on some sites where frequent fires would typically limit duff development 

and contain roots mostly to the mineral soil horizons (Jain and Graham 2004; Wade1986). The 

presence of fine roots in the duff is an important observation when determining potential tree 

mortality from prescribed burning.” It further states that duff consumption near the tree bole 

during prescribed fire was significant in predicting white fir, sugar pine and ponderosa pine 

mortality. The report stated that cambium is killed at approximately 140 degrees F. “Long-term 

heating of this kind only occurs when there is a large amount of fuel burning near the tree, such as 

a stump, log or deep duff. In long-term unburned areas, duff depth typically increases 

dramatically near the base of the tree, forming a basal mound. The long-term smoldering 

combustion of this fuel accumulation can increase cambium injury even for species with thick 

bark (Ryan and Frandsen 1991). Girdled trees caused by burning may take several years to die 

because the xylem is intact and can continue to transport water to support the crown, but 

photosynthate cannot be transported down to roots. The root system is eventually depleted of 
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stored carbohydrate reserves and stops producing fine roots, which absorb soil water. Therefore, 

the tree dies from water stress (Greene and Shilling 1987; Michaletz and Johnson 2007).” In 

addition to the deeper duff layer around the boles of trees, the duff layer is generally drier under 

tree crowns than between them due to the interception of precipitation by tree crowns resulting in 

less moisture reaching the duff beneath. It further states that bark beetles are attracted to burned 

areas and cause post-fire mortality beyond what is expected from fire injury alone. 

To minimize damage to the residual stand, spring burning should be completed before trees are 

actively growing. Hood’s report states: “burning during the dormant season may reduce bud kill 

more than burning during the growing season when buds are actively growing and ambient air 

temperature is lower.” During burning, pine needles help to shield young pine buds from damage 

from heat until buds elongate to a point where they are about to grow beyond the surrounding 

needles. Fir and oak new growth is much more susceptible to heat related damage than pine. To 

minimize bud damage, underburns should be completed prior to new buds and leaves reaching 

this stage of development. Burning before active tree growth occurs would increase the likelihood 

of additional spring rains occurring after ignition. This would help to minimize prolonged 

smoldering and consumption of the duff layer near residual trees.

Existing slash concentrations within proposed burn units should be spot piled and burned prior to 

underburning to minimize damage to the residual stand. Where needed, trees less than 10 inches 

dbh forming fuel ladders should be felled prior to underburning. 

Proposed treatment areas Rx 2, T 21 and T 8 adjoin the PSW Vista long term soil productivity 

stand. This stand is one of a series of study areas across the United States studying the effects of 

various treatments on long term soil productivity. Extreme precautions need to be taken to 

protect this stand from damage due to proposed adjacent underburning.

Rx 1 and Rx 2 are located on steep, broken ground. The majority of this ground is too steep and 

broken for mechanical treatments. As previously stated, the proposed treatments for Rx 1 and Rx 

2 are underburn only. Underburning is the most practical method to provide connectivity of fuels 

treatments in this area. In order to minimize ground disturbance, roads are planned to be used for 

the upper boundaries for burning. Expected mortality of residual trees resulting from 

underburning would be greater in these two stands than in those with only one proposed spring 

underburn. To minimize damage to the existing stand, two underburn treatments are planned to 

reduce accumulated fuels in increments as a part of this proposal for these two units. The first 

would be a light spring underburn followed by either another light spring or light fall treatment 

several years later. The initial treatment would reduce some of the accumulated down fuels and 

the depth of the duff layer which would result in reducing the likelihood of vegetation injury due 

to long term heating from smoldering duff. Waiting several years before undertaking the second 

underburn in these stands would provide time for feeder roots of trees within the stand to move 

deeper into the duff layer or mineral soil before the follow-up burn thus reducing potential root 

damage during the second underburn. This recovery time frame would also provide time for trees 

to recover from stress resulting from the initial underburn as well as time for more down fuels to 

accumulate to carry fire to ensure a successful second underburn treatment. Following the second 

underburn treatment, these stands would be better able to withstand the effects of a wildfire.

“Carefully restoring fire to long-underburned forests that historically burned frequently would

reduce accumulated fuel and duff, retain old trees, and perpetuate these fire-dependent forests” 

(Hood 2010). Through a combination of spot piling and burning of slash concentrations and light 

spring underburning utilizing the previously discussed measures, more fire resilient stands can be 

obtained. The Silviculturist and Fuels Officer should coordinate all areas to be underburned prior 

to undertaking underburning. 
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Indirect Effects and Cumulative Effects 

Of the 9600 acres within the proposed project boundaries 3,556 acres are being analyzed for 

potential treatments. In addition to the 3,556 acres being analyzed, a mastication contract was 

recently awarded to precommercial thin and release 275 acres of 20 to 25 year old plantations. 

Over the next several years mastication thinning and release is planned on another 400 acres of 20 

to 40 year old plantations within the project boundaries. This project proposes to 

commercially/precommercially thin approximately 1,566 acres, precommercially thin 

approximately 882 acres by hand felling and tractor piling or mastication, precommercially 

thin/release/reduce fuels on another approximately 318 acres by mastication, light underburn on 

approximately 1,842 acres of the proposed commercially and/or precommercially thinned areas, 

and light underburn on another 609 acres of underburn only areas. 

The remainder of the project area is not proposed for treatments and would retain its present 

CWHR classifications. Within HRCAs and OFLs the aim as stated in the SNFPA 2004 is to 

retain 60% or greater canopy cover, where available. (The intent of the project is to retain canopy 

cover of 60 % or greater in CWHR 4 and 5 size classes where it presently exists.) Retention of 

this level of canopy cover would continue to provide sufficient shading to restrict invasion of 

brush species into the understory. Very little change in CWHR classification is anticipated due to 

the proposed thinning treatments. Follow-up light spring underburning before trees are actively 

growing should not result in significant additional canopy cover reduction which would result in a 

CWHR change. Within those portions of Spotted Owl and Goshawk PACs where thinning is 

proposed, the aim is to retain 70 % or greater canopy cover, where available. The vast majority 

of the project area would not be treated as a result of these past or proposed treatments. Under 

this alternative, vegetation present in these untreated areas would remain the same as presently 

found. 

In addition to the denser canopy cover proposed for OFLs, groups or patches of five or more 

larger trees, generally 30 inches and larger, are planned to be retained through the project area. 

These small groups would have residual basal areas of 240 ft2 or more for mixed conifer and 210 

ft2 or more for pine and in many instances may reach 300 to 400 ft2 per acre. Excess trees up to 

20 inches dbh would be removed during thinning, however, no precommercial thinning 

treatments would occur within these pockets. Approximately two to three black oaks 20 inches 

dbh and larger per acre would also have a 35 foot buffer, measured from the bole, around them 

where no fuels treatment would occur.

Retention of these higher basal areas to provide denser canopy cover would result in not fully 

meeting the silvicultural objectives for maintaining or improving forest health. The impact would

not be as great in mixed conifer and fir stands as it would be in pine. Retaining 60 percent or 

greater of normal basal area in pine stands (180 ft2

/ac) leaves them at a level where stand density 

index studies have shown them to be susceptible to insect attack. Pine stands with basal area 

stocking levels at 60 percent or greater begin to exceed a SDI 270 which Cochran’s 1999 study 

considers to be the critical threshold level for density management (upper management zone, 

Cochran, 1994) above which serious beetle induced mortality can begin to occur. Oliver, 

1995,2009, stated that a SDI 365 (approximately 240 ft2

/acre), defines the threshold for a zone of 

imminent bark beetle mortality where pine stands suffer large losses from bark beetle epidemics. 

These losses can equal or exceed periodic growth. Subsequent growth of these stands would add 

further to the problem. Sufficient thinning would occur in some of the proposed scattered clumps 

to provide a short term benefit to stand vigor while in other clumps little, if any, thinning would

occur resulting in a continued decline in clump vigor. Pine clumps left at these higher basal area 

retention levels would continue to be at a very high risk of loss due to insect, disease, 

competition, and/or drought induced mortality. A Negron and Popp 2004 report found that plots 

infested by mountain pine beetle had significantly higher total basal area, ponderosa pine basal 

area, stem density and stand density index (Fettig, 2007). Heavily stocked pine clumps attacked 
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by insects have the potential to serve as infection centers for increased mortality in the 

surrounding pine stands as insect populations build and move into adjacent stands. To maintain 

more vigorous, drought and insect resistant stands, a shorter reentry period would be needed. The 

reentry time frame within HRCA, PAC, and OFL pine stands and these more heavily stocked 

clumps would likely be reduced by 5 or more years. 

Since the vast majority of the crown covers and ground cover would remain in place following 

thinning operations, properly conducted thinning has only a minor short term effect on the 

environment. Leave trees would continue to contribute needles as well as small branches to the 

forest floor. Little soil movement and little, if any, increased runoff should occur as a result of 

this entry. SMZs would be maintained with any thinned trees being endlined out of the SMZs. 

Therefore, stream course stability would not be adversely affected. Long term affects would be 

to maintain or increase growth and vigor of treated stands, accelerate development of old forest 

characteristics in wild stands and plantations, and improve the protection of human communities 

from wildland fires as well as minimize the spread of fires that might originate in urban areas. 

Over the past 18 years, the district has planned and completed several projects, treating several 

thousand acres, similar to the proposed action. Canopy cover retention for these completed 

projects was expected to be 50 to 60% or greater. Field and aerial photo reviews by the District 

Silviculturist following harvest has shown canopy cover to have following harvest has met or 

exceeded expectations. Residual crowns have rapidly filled in openings created by harvest 

treatments.

In addition to the benefits obtained through density management several other benefits have been 

noted in treated stands. Several studies (Amman 1989; Bartos and Amman 1989; Schmid et al. 

1992, 1995) have shown that in addition to increasing residual tree vigor, increasing temperatures 

and windspeeds are common in recently thinned stands. This may accelerate development of 

certain bark beetle species and force them to overwinter in stages that are more susceptible to 

freezing (Amman 1973, 1989) or cause turbulences that disrupt pheromone plumes used for 

recruiting conifer species during initial phases of host tree colonization (Thistle et al. 2004, 2005)

(Fettig, 2008). Moderate thinnings may result in less potential extreme fire behavior compared to 

unmanaged stands. Greater fuel depths, mid–flame wind speeds and lower fuel moistures in 

heavily treated stands (>60% basal area reduction) might increase potential fire behavior 

compared to unmanaged stands. Thinning followed by sufficient treatment of surface fuels 

usually outweighs changes in fire weather factors (wind speed and fuel moisture) resulting in an 

overall reduction in expected fire behavior (Jenkins, et al, 2008). Thinning followed by tractor 

piling and burning or whole tree yarding have been shown to be effective in reducing fire severity 

under severe fire weather conditions. Thinning from below where the largest trees are retained 

within the stand contributed to increased fire resistance (Stephens, 2009). Thinning makes fire 

suppression more efficient. Once heavy fuels are removed, the residence time (duration) of the

fire is reduced, often resulting in a non-lethal surface fire (Fitzgerald, 2005). The thinning 

proposed within the project is designed to reduce existing basal area by generally 30% or less. 

Follow-up treatments are designed to remove fuel ladders as well as slash concentrations. This 

relatively light level of thinning should both realize the benefits of thinning stands to reduce the 

adverse effect of bark beetles and competition while reducing expected potential fire behavior. 

Upon completion of the work planned under this alternative and the previously planned plantation 

thinning and release work, stand vigor will be improved making these stands more resilient to the 

effects of insect attack, drought conditions and predicted future weather variances.

Alternative 3

This alternative proposes to only remove precommercial size fuel ladders/fuels and 

precommercially thin throughout the portions of the treatment areas proposed for commercial 
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thinning under Alternative 2. Other proposed treatments would remain the same as described in 

Alternative 2. 

Direct Effects 

No density management would be accomplished with this alternative in wild stands. Fuel ladder 

removal would occur on suppressed and a very few intermediate trees only. No codominant trees 

would be removed. 100 % of the existing basal area 10 inches dbh and larger would remain. The 

percentage of less drought resistant, more fire prone incense cedar and fir 10 inches dbh and 

larger would remain the same as existing. The average stand diameter would not change. Shade 

intolerant pine and oaks would become less vigorous and continue to drop out of the stands. 

Individual tree growth rates would decline. Post treatment stocking levels would be too dense to 

withstand the stresses of drought and weather variances. The risk of bark beetle induced 

mortality in pine stands would continue to rise as competition continued to increase. 

As stated previously, Smith, 1962, stated that removal of only intermediate and suppressed trees 

results in “little more than the salvage of trees which would inevitably die”. Emmingham, 1983, 

stated that a successful thinning from below requires the removal of many codominants as well as 

most intermediates and suppressed trees. Under this alternative, fuel ladder reduction only 

dealing with precommerical trees would not remove any significant levels of competition to meet 

density management objectives. Removal of only some suppressed trees and little to no 

intermediates would not provide any significant increase in nutrient or water availability to the 

residual stand. Not only would there not be a significant increase in available nutrients or water, 

failure to remove some of the codominants and intermediates growing into the bottom portion of 

the codominant layer of the stand would not create openings in the canopy to provide room for 

crown expansion of the residual trees. Shade intolerant oaks and pines would not be able to 

benefit from increased light and rates of photosynthesis as well as reduced competition provided 

by openings created in the canopy cover. This alternative does not meet the purpose and need for 

density management emphasized in the SNFPA, 2004 decision and being examined as a part of 

this project. 

Indirect and Cumulative Effects 

Since stand densities would continue to increase, wide swings in weather conditions as has been 

experienced over the past thirty years and predicted to continue would continue to place increased 

stress on these untreated stands. Mixed conifer and fir aggregations and stands with stocking 

levels approaching or exceeding normal would become increasingly susceptible to mortality. 

Excessive stand/aggregation densities in ponderosa pine stands and ponderosa pine plantation 

aggregations would result in the likelihood of heavy mortality. Drought and insect induced 

mortality would escalate. Snags and jack-strawed down material would increase. Basal area tree 

growth of only 15 to 20 ft2 per acre would occur over a 15 to 20 year period (if excessive 

mortality does not occur) in more densely stocked aggregations. Forest health in the area would 

decline and elevate the risk of loss due to wildfire. Not only would the potential for loss of these 

stands to insect attack and drought increase, but their ability to respond to future thinning would 

continue to decline as crown vigor deteriorated as treatment was postponed. Experience has 

shown that even a course of no action is not without consequence (Fettig, 2007). Doing little to 

nothing to reduce stand density would result in forests that continue to deteriorate over time.

No revenues would be generated under this alternative. All work proposed would need to be 

funded through very limited appropriated sources. The majority of the proposed vegetation 

management/fuels reduction work would likely not be funded or undertaken. Under burning is 

planned to be conducted in a number of the treatment areas. Since no density management would 

take place, many of the smaller diameter trees which would have been removed under alternative 

2 would be killed as a result of underburning. Others would suffer increased stress and would be 
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Sierra National Forest – 229 Chapter 3

less resistant to bark beetle attack, diseases or drought conditions for several years following 

burning. “Many bark beetle species are attracted to burned areas and cause post fire tree 

mortality beyond what is expected from fire alone” (Hood, 2010). These smaller diameter fire 

stressed trees would serve as potential sources for increased bark beetle activity resulting in the 

increased likelihood of mortality in the surrounding stand. Dead and down fuels would increase 

after the first underburn entry.

As mentioned previously, the lack of density management would result in an increased likelihood 

of mortality in these stands. Mortality would occur over a range of diameters. Additional 

roadside hazard tree sales would need to be undertaken to minimize risks to the public.
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Fire/Fuels __________________________________

The direct, indirect and cumulative effects to Fire/Fuels are summarized from the Fire/Fuels 

report for the Grey’s Mountain Ecological Restoration Project (Smith G., 2012)

Affected Environment

Existing Condition 

Fire represents both one of the greatest threats and one of the strongest allies in efforts to protect 

and sustain human and natural resources in the Sierra Nevada. Residents and visitors alike are 

well aware of the threats posed by summer wildfires. A growing density of homes and other 

structures coupled with the increased amount and continuity of fuels resulting from twentiethcentury fire suppression have heightened concern about threats to life and property, as well as the 

health and long-term sustainability of forests, watersheds, and other natural resources. Yet fire 

has been an integral part of the Sierra Nevada for millennia, influencing the characteristics of 

ecosystems and landscapes. Today, state, federal and local agencies put enormous resources into 

efforts to reduce fire occurrence while at the same time advocating the need to use fire to promote 

healthy ecosystems. The challenge faced is how to restore some aspects of a more natural fire 

regime while at the same time minimizing the threat wildfire poses to human and natural 

resources and values Sierra Nevada Ecosystem Project (SNEP, 1996).

Fire Suppression

Fire is recognized as a keystone process that has influenced the composition, structure, and 

heterogeneity of forested landscapes in the western North America for millennia (Swetnam, 1993, 

Whitlock et al. 2003, Scholl and Taylor 2010) Fire’s role in shaping forest structure and 

composition changed in the mid-to-late 19th century with Euro-American settlement and then 

implementation of a federal policy of suppressing fire in 1905 (Agee 1993).The effects of 

reduced fire frequency have been greatest in forests with surface fires that had burned frequently. 

Excluding fires has increased forest density and surface and aerial fuels, increasing the risk of 

large high-intensity wildfires, including crown fire (Scott and Reinhardt 2001).

Fire Regime

Fire plays a pivotal role in reshaping and maintaining mixed-conifer ecosystems (North, M. et. 

al., 2009). The role fire plays in an ecosystem is characterized by the fire regime attributes that 

describe the pattern of fire occurrence, behavior, and effects. Temporal attributes include 

seasonality and fire return interval. Spatial attributes are fire size and spatial complexity of the 

burns. Magnitude attributes are fire intensity, fire severity, and fire type. Many species and most 

communities show clear evidence of adaptation to recurrent fire, further demonstrating that fire 

has long been a regular and frequent occurrence. This is particularly true in the chaparral and 

mixed conifer communities, where many plant species take advantage of or depend on fire for 

their reproduction and survival. In many areas, frequent surface fires are thought to have 

minimized fuel accumulation, keeping understories relatively free of trees and other vegetation 

that could form fuel ladders to carry fire into the main canopy (Sierra Nevada Ecosystem Project 

(SNEP, 1996).

Variation in fire severity has an important influence on forest heterogeneity because fires may kill 

all trees in some stands and few in others. Stand development after high-severity fire leads to 

even-aged or several-aged stands, while forests that experience low- or moderate severity fires 

have trees in many age classes because few trees are killed in a stand (Agee 1993, Scholl and 

Taylor 2010).
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Scientific studies done on the Yosemite National Park have shown that most areas, both 

historically and recently, have burned at low- to moderate-severity , with occasional small (100-

2000 m2) high severity patches that create canopy gaps and subsequent patches of similar-aged 

tree groups (Scholl and Taylor 2010; Thode et al. 2011). Tree regeneration in gaps is facilitated 

by the torching of single trees or groups of several trees, and the self-limiting nature of the 

historical fire regime. Although more severe fire effects can restore density and basal area to 

reference conditions more quickly (Miller and Urban 2000, Fu ́ le et al. 2004), there was no clear 

evidence of large-scale high-severity fire effects in our forest. Thus, application of high-severity 

prescribed fire beyond the occasional torching of small groups of trees would create novel 

conditions compared to fire effects over the last four hundred years (Scholl and Taylor 2010). 

Numerous peer-reviewed scientific documents have noted striking changes in structural and 

functional components of the Sierra Nevada ecosystems since 1860, largely due to alterations in 

the pre-Euro-American settlement fire regime (Caprio and Graber 2000). The Greys project has 2 

different fire regimes characteristics. The southwest area of the project is characterized as sierra 

ponderosa pine mixed conifer; historically this forest ecology zone displayed a low-intensity and 

frequent fire regime. The northeast area of the project is characterized as red fir historically a 

mixed intensity and frequency fire regime (Sugihara et al, 2006). Presently the fire regime 

condition class (FRCC) for the Greys project consists of;

Percentage of 

project area Condition Class Fire Regime

10% 1 Fire regime is within historical range and the risk of 

losing key ecosystem components is low.

9% 2 Fire regimes have been moderately altered from their 

historical range. The risk of losing key ecosystem 

components is moderate. Fire frequencies have departed 

from historical frequencies by one or more return 

intervals.

80% 3 Fire regimes have been significantly altered from their 

historical range. The risk of losing key ecosystem 

components is high. Fire frequencies have departed from 

historical frequencies by multiple return intervals.

1% 9 These areas consist of unburnable material (rock 

outcropping).

Fire History

During the period before significant Euro-American influence, natural fires and anthropogenic 

burning occurred frequently and were low intensity with return intervals ranging from 5 to 10 

years in these vegetation types. These types of fires produced fire effects of low to moderate 

severity throughout this ecosystem. Occasional patches of high severity fire effects did occur 

where pockets of heavier surface fuel loads and ladder fuels aligned with favorable slope, wind 

and aspect during drought conditions to induce mortality in larger conifer pockets. Areas 

surrounding Soquel was burned by the Native Americans and later years by ranchers (Anderson 

2006).
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Since the 1930s the forest and within the project area have become densely overstocked. 

Wildfires that burn in these areas today, burn at such levels that high magnitude of resource 

damage occur, especially to soil layers. Once these soils are heavily damaged by fire, ecosystem 

components can take longer to recover especially trees which are a key component in forest 

ecosystems. Recent examples of this can be seen locally in the 2001 North Fork Fire the 2003 

Source Point fire and the 2008 Oliver Fire.

Wildfire history cartographic data beginning in 1910 show that between 1917 and 1988 there 

have been 16 fires greater than 10 acres within 3 miles of project area. These fires were mostly 

human caused and ranged in size from 28 to 8,313 acres. Most of these wildfires started and 

burned from the lower elevations around the Oakhurst Basin and Bass Lake area up towards the 

project area.

In 1916, a 74 acre fire started southeast of the Greys Mountain Campground, causing unknown 

damage to the forest. Since 1916, there have been 42 fires contained at 10 acres or less within the 

project boundary. Given the proper burning conditions as documented fire history around the 

project area shows a fire could have the potential to burn with such severity that could result in 

resource damage that would be greater than the ecosystem could sustain. 

Table 41 and Table 42 show the Fire History Records (fires >10 Acres) within and outside of the 

project area. Map 1 in the appendix of this document shows the approximate perimeters of these 

fires and their proximity to the community of project and the project area. 

 Table 41. Fire History within the Project Boundary

Year Size/Acres General Location

1916 74 1⁄2 mile southeast of Greys Meadow Campground

 Table 42. Fire History Outside of the Project Boundary (within a 3 mile radius)

Year Size/Acres Year Size/Acres

1917 399 1928 302

1917 189 1934 3,930

1920 508 1930 701

1920 99 1934 8,313

1924 106 1942 359

1924 1,056 1915 187

1926 4,395 1952 115

1926 540 1988 28

Logging History

From 1852 to 1925 various lumber mills processed timber harvested from the area within the 

project boundary. Timber harvested during this era has resulted in most of the forested areas with 

trees that are less than 130 years of age. Timber harvested after 1925 has generally consisted of 
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Sierra National Forest – 233 Chapter 3

salvage/sanitation, regeneration harvests and commercial thinning, with most occurring from 

1970 to 1995. Fire exclusion from the vast majority of the area since the 1920’s, has resulted in 

development of dense fuel ladders in the natural regeneration areas along with areas that escaped 

early day logging.

Today, hundreds of small trees per acre are common beneath these stands of white fir, sugar pine, 

incense cedar, and ponderosa/Jeffrey pine in the lower elevations and red fir in the higher 

elevations. These stems consist of mostly shade tolerant incense cedar and white fir. Ponderosa 

pine and incense cedar have naturally reseeded into small portions of fire impacted areas where 

they are severely overstocked, creating significant fuel ladders. Due to drought and beetle 

infestation in the late eighties and nineties logging was used in some areas to salvage pockets of 

dead and dying trees. Activity fuels were treated with machine piling and pile burning.

Fire Behavior in current Fuel Loading

Ground and surface fuels within the project area vary throughout the project. The project area has

three dominant arrangements of fuels that influence fire behavior. These are: ground, surface and 

crown fuels. Ground and surface fuels can be described utilizing Rocky Mountain Research 

Station Fuel Models (Scott and Burgan, 2005) for estimating fire behavior. This is used to aid in 

describing the type and average amount of fuel given a particular fuel type and the prediction of 

the type of fire behavior expected under certain weather and topographic conditions. Crown fuels 

are generally described in relationship to the density of crowns (canopy bulk density) and their 

height above the surface fuels (canopy base height). 

Ground and Surface Fuels

Timbered Stand Areas - The ground and surface fuels within the mixed conifer and true fir stands 

that do not have brush as the main understory component fall into four Fuel Models TL3 (conifer 

needle litter) and TL8 (long needle pine litter), TU5 (conifer litter with shrub understory), and 

SB2 (activity fuels and scattered blowdown from wind damage with many trees still standing). 

The difference between these four fuel models comes from the increasing amounts of ground and 

surface fuels.

1. True Fir Stands - Fuel Model TL3 is described as having lighter amount of ground and 

surface fuels associated with it and is used to describe the true fir stands in the higher 

elevations of the project area that have not started to deteriorate from drought stress 

and/or overcrowding and the trees have not begun to fall on their own. Measured surface 

fuel loadings range between 3.5 and 31 tons per acre.

2. Mixed Conifer Stands - Fuel models TL8 describes areas where there is a moderate fuel 

load small saplings and suppressed trees have begun to fill in the understory of larger 

trees. The surface fuels are of smaller size, mostly less than 3” in size. Measured surface 

fuel loadings range between 1 and 35 tons per acre. 

Fuel Model TU5 and SB2 are used to describe conifer stands where natural fuel and 

activity generated accumulations of ground and surface fuels are beginning to increase. 

These surface fuels are of larger size, mostly 3+” in size and can increase the intensity of 

surface fires within the area. These fuels include not only the branches and needles of 

fallen trees, but also include the boles, increasing the tons/acres of natural fuels on the 

ground rapidly. Surface fuel loadings in the project area that are representative of Fuel 

Model TU5 range between 1 and 78 tons per acre and 11 and 115 tons per acre of Fuel 

Model SB2.
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3. Brush/Scrubs Areas -The ground and surface fuels within areas where poor regeneration,

fuelbreaks, and areas consisting of mixed conifer stands and mixed chaparral located on 

the south and southwest facing slopes of the lower reaches of the project area can be best 

described using a Fuel Model SH2. A Fuel Model SH2 is described as dry climate 

woody shrubs’ and shrub litter with moderate fuel load. Surface fuel loadings in the 

project area that are representative of Fuel Model SH2 range between 5 and 25 tons per 

acre

Crown Fuels

The crown fuels in the project area can be described in two ways, crown fuels that can lead to the 

propagation of a crown fire and the crown fuels available to sustain a crown fire. There are two 

elements that need to fall into place for a crown fire to start and for it to sustain itself, fuel ladders 

(vegetation that “stair-steps” up in height and can allow a fire to reach the crowns of trees) and 

canopy density (in simple terms, how close together individual tree crowns are, usually given as a 

percentage of space taken up by the tops of trees).

In white fir and incense cedar stands the project area, fuel ladders are heavy and continuous, 

consisting of regeneration of conifers, brush and of natural regeneration of conifers. These fuel 

ladders start at the surface layer and have grown to the point of having a continuous “stair-step” 

of available fuels into the bases of the canopy trees.

The canopy fuels in the project area are varied from open to heavily closed (approximately 100% 

canopy closure). Areas where there is a combination of heavy, continuous fuel ladders and 

canopy closure is closed (interlocking of crowns in the canopy) the potential for initiation and 

sustainability of a crown fire is the greatest.

Wildland Urban Intermix (WUI)

The project is located within the defense and threat zones of the WUI and situated adjacent to 

residential areas of Redwood Creek to the southwest, Paradise Springs to the northwest, and 

Soquel Meadows to the north. These areas are a priority for fuels treatment. Followed by areas 

where Defensible profile Zones (DFPZ) and fuelbreaks are identified, proceeded by treatment 

areas that have been strategically identified placed for treatment. Standards and guidelines for 

Southern Fisher Conservation Area apply in known home range outside the WUI.

Communities surrounding the Greys Project include Bass Lake to the south, Sugar Pine and 

Cedar Valley to the west. Calvin Crest Christian Camp and Nelder Grove Historical Area of 

giant sequoia also lie to the west of the project. With the continuity of the fuels within the project 

area, a wildland fire originating from within the WUI or Forest Service designated roads, under 

the right conditions, has the potential to spread into the project.

Applicable S&Gs

In the recent past several fire policies and initiatives have been enacted to address the national 

wildfire problem in the United States. These include, but are not limited to the U.S. National Fire 

Plan, Ten-Year Comprehensive Strategy and Implementation Plan, and Healthy Forest 

Restoration Act (Stephens, S. et. al., 2009). These have provided the basis of management goals, 

intents and directions that are within the Forest Land and Resource Management Plans. By 

implementing the Greys Project fire policies and forest plans would be met.

The Sierra National Forest LRMP as amended by the SNFPA ROD provides the management 

direction, goals, and objectives and S&Gs for the action alternatives for the protection of 

resources and the application of the fuels and prescribed fires. 
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Desired Condition 

The SNF LRMP as amended by the 2004 SNFPA ROD establishes a desired condition for each 

land allocation. In particular, the desired condition for each land allocation incorporates how and 

what type of vegetation complexes are desired for each. These are referenced in short and long 

term conditions and are influenced by the temporal and spatial influences of fire. One of the 

broad scale goals is to actively restore fire-adapted ecosystems by making demonstrated progress 

in moving acres out of unnaturally dense conditions (in other words, moving acres from the Fire 

Regime Condition Class (FRCC) 2 or 3 to FRCC 1. The land allocations and their specific 

desired conditions used for this project include:

Wildland Urban Interface: (SNFPA ROD, 2004; page 40-41)

Defense Zone 

 Stands are fairly open and dominated primarily by larger, fire tolerant trees.

 Surface and ladder fuel conditions are such that crown fire ignition is highly unlikely.

 The openness and discontinuity of crown fuels, both horizontally and vertically, result in 

very low probability of sustained crown fire.

Threat Zone - Under high fire weather conditions, wildland fire behavior in treated areas is 

characterized as follows:

 flame lengths at the head of the fire are less than four feet;

 the rate of spread at the head of the fire is reduced to at least 50 percent of pre-treatment 

levels;

 hazards to firefighters are reduced by managing snag levels in locations likely to be used 

for control prescribed fire and fire suppression consistent with safe practices guidelines;

 production rates for fireline construction are doubled from pre-treatment levels; and 

 Tree density has been reduced to a level consistent with the site’s ability to sustain forest 

health during drought conditions. 

Fuels treatments outside of the WUI and within other land allocations are to establish and 

maintain a pattern of area treatments that is effective in modifying wildfire behavior (SNFPA 

ROD, 2004; page 35). There are specific means and conditions by which treatments can be 

conducted within some land allocations because of maintaining habitat needs as well as 

perpetuating such conditions (i.e. old forest emphasis areas).

The Forest Service’s primary responsibility and objective for structure fire protection is to 

suppress wildfire before it reaches structure. (Forest Service Manual, 5137.02). The spatial 

arrangement of stands and homes is crucial to the success of fuel management activities in 

changing the effects of large fires either at the local or landscape scale. (Finney and Cohen, 

2003). Thinning trees to produce gaps in the flame front significantly reduces radiant exposure, 

and that a firefighter’s maximum radiant exposure is well below exposures necessary for piloted 

wood ignitions.

The defensible space requires more vegetation fuel hazard reduction than fuels reductions 

required for preventing piloted wood ignitions. (Cohen and Butler, 1996). Agency WUI fuel 

treatment largely do not address home ignitability but rather areas outside the home ignition zone. 

Fuel treatment in the vicinity is expected to protect homes by creating conditions that enable 

successful fire suppression if a wildfire would to occur. As experienced during the Wallow Fire 

(2011), half (1⁄2) mile wide fuels treatment units located above the community of Alpine slowed 

this crowning fire by causing the blaze to drop from up in the trees to the surface level. The fire 

rate of spread dramatically slowed and flame lengths were low enough to allow firefighters’ to 

safely attack the fire and protect homes and property. Also during this incident, a small 
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Sierra National Forest – 236 Chapter 3

strategically placed fuel treatment served as a successful and effective ‘anchor point” to that 

enabled firefighters to actively engage in fire suppression operation to protect many structures in 

the community of Greer. Many structures survived the fire because of prior fuels treatment, as 

well as stewardship construction and landscaping completed by the land owner. (Bostwik et. al., 

2011).

Preventing WUI fire disasters require the problem be framed of home ignition potential. Because 

this principally involves the home ignition zone, the home ignition zone primarily falls within 

private ownership; the responsibility for preventing home ignition largely falls within the 

authority of the property owner (Cohen, 2008).

Southern Sierra Fisher Conservation Area: (SNFPA ROD, 2004; page 41)

1. Within known or estimated female fisher home range outside the WUI, a minimum of 

50% of forested area has greater than or equal to 60% canopy cover.

2. Where home range information is lacking, use HUC 6 watershed as the analysis area for 

this desired condition.

Environmental Consequences 

Fire not only interacts with the physical, but the living components of the ecosystem (Sugihara, 

N., et. al., 2006). The only portion of the fire behavior “triangle” that can be intervened with is 

fuels by managing vegetation (Sugihara, N., et. al., 2006). Increased stand density, decreased 

overall tree size, and increased surface fuel loads are well documented for many forests of this 

type (Stephens, S. et.al, 2009). These changes concern fire managers because the increased fuel 

loads and altered forest structure have made forest vulnerable to fire intensities and severities 

outside of the desired conditions and outside of historic fire regimes for these ecosystems. But 

how can fire be placed back into the ecosystem, if the potential resultant fire (whether 

management ignited as prescribed fire or natural-caused) is of higher intensity and severity than it 

was historically because of the unnatural accumulations of fuels? Although there is relatively 

little understanding of the ecological effects of fuel treatments, in particular the extent to which 

mechanical treatments might emulate natural ecological processes such as fire (Stephens, S., 

2009), they can be effective tools to modify stand structure and influence subsequent fire severity 

and extent. Mechanical treatments are often a required first treatment in forests containing 

excessive fuels loads (North, M., 2009).

Methodology 

The following subsections discuss the scope of analysis, methodology, and indicators to assess 

the environmental consequences of the alternatives on fire/fuels.

Assessment of Fuel and Forest Structure - Aerial photography (2007) of the project area was 

initially used to determine fuel type (shrub, brush, timber litter, and slash/windblown) within the 

project area. Due to the variability of conditions throughout the project area, The Rocky 

Mountain Research Station Fuel Models (Scott and Burgan, 2005) was used to determine which 

stratum of surface fuel was most likely to carry the spreading fire. These fuel models were used 

to represent the average conditions within each fuel type represented in the area. Because these 

fuel models have associated fuel loading for each time lag fuel category (1, 10, 100-hour fuels) 

the Brown’s planar intercept method was used to collect fuel-loading data by fuel size classes 

within the Forest Inventory and Analysis (FIA) plots.

Predicted Fuel Model Conversion - In assessing the effects of future conditions in the no action 

alternative and the action alternatives, fuel models were chosen to represent the predicted fuel 

group and average post treatment conditions by fuel group being treated. It was assumed that 

treatments would move existing conditions from one fuel model to another, but remain within the 
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same fuel group (i.e. a Fuel Model TU1, Timber Group would post treatment convert to a Fuel 

Model within the Timber Group). For the shrub group, dependent on the type of treatment, it 

may be converted from the shrub group into any of the fuel groups. Studies within the Sierra 

Nevada range and similar to those existing and resulting from the treatments proposed (Kaufman, 

2002; Stephens, S., 2009; USDA Forest Service, PSW, 2001) were used to determine and verify 

the fuel models chosen as well as field verification in areas on the district where similar treatment 

prescriptions have been implemented.

Crown Fire Prediction - In order to determine the potential for crown fire initiation and/or the 

type of crown fire (if initiated), average canopy bulk density as well as average canopy base 

height were needed for stands within the project area. Tree list were developed utilizing timber 

cruise sample plot data collected within the project area and processed through the Forest 

Vegetation Simulator (FVS) program for verification. The collected data was for trees measured 

over 10 inches at dbh only. Utilizing studies conducted within the Sierra Nevada Range and in 

similar conditions as that within the project area (Kaufman, 2002; Stephens, S., 2009; United 

States Department of Agriculture (USDA) Forest Service, Pacific Southwest (PSW), 2001) 

average existing and post treatment canopy characteristics were determined. Average canopy 

base heights were based on measured tree heights, stand position and field verification for both 

existing and post treatment condition.

Modeling for Potential Fire Behavior and Fire Effects -Modeling of potential fire behavior and 

the resultant intensity and severity of such fire behavior requires several inputs for calculation. 

These include, but are not limited to fuel, weather and topography conditions of the area being 

analyzed. These conditions can change slowly over time and space or can change rapidly. For 

this analysis, conditions (except for fuel model) were held constant and were based on what are 

considered 90th percentile weather conditions for the project area. 90th conditions, as used here, is 

representative of the high fire weather conditions under which wildfire behavior in treated areas is 

to be characterized for desired conditions (SNFPA ROD, 2004; page 46).

Fire Family Plus (a program used for analyzing historic weather and fire danger rating records) 

was used to determine what 90th percentile weather conditions are from representative Remote 

Automated Weather Station (RAWS) historic weather records. Twenty years of recorded weather 

data (1990-2010) from the Batterson and Minarets RAWS were analyzed. Conditions analyzed 

and used were: 1-hour, 10-hour and 100-hour dead fuel moistures, live fuel moistures, air 

temperature, and wind speed. Because treatments are proposed on slopes generally less than 35 

percent, an average slope of 20 percent was used for fire behavior modeling. It is assumed that 

with an increase in slope percentage, fire spread and intensity would increase.

Fire behavior was modeled, for existing, short term conversions and post activity treatments, 

using BEHAVE Plus 5 BEHAVE Plus 5 was used to model surface fire behavior for the initial 

fuel models selected for existing, short term conversions and post activity treatment conditions as

well as the predicted mortality of conifers within the stands given the constant weather conditions 

and the representative fuel bed. The modeled results were compared to observations made of past 

wildfires burning under the same conditions and same fuel models to determine if modeled results 

were representative and/or realistic. The inputs utilized for this analysis are;

Fuel Models: SH2, TL3, TL8, TU5, and SB2 (for existing conditions)

1-hour Fuel Moisture (%): 3

10-Hour Fuel Moisture (%): 4

100-Hour Fuel Moisture (%): 6
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Live Woody Fuel Moisture (%): 80

Foliar Moisture (%): 80

Air Temperature (%): 80

20 foot Windspeed (mph):

Wind Reduction Factor:

15

0.3

Canopy Bulk Density (lb/ft3): 0.0119 and 0.0874

Canopy Base Height (feet): 10 and 20 For timber 0.1 and 5 

For brush

Slope (%): 20

Indicators

Analysis Indicators Measured - The SFNPA ROD 2004 includes specific characteristics 

(indicators) of fire behavior as desired conditions for fuels treatments. These are used as the 

“indicators” in this analysis. These include Fire Behavior Characteristics Indicators based on 

existing and resultant of:

 Fuel Model

 Crown Fire Potential

 Average Rate of Spread(ROS)\Resistance to Control

 Average Flame Length (FL)

 Average Tons per Acre of Surface Fuels

 Average Fireline Intensity

 Average Mortality in Ponderosa Pine, red and white fir conifers (range of average size 

existing 10” dbh; for post treatment 30” dbh).

When interpreting fire behavior and predictions, guidelines or “trigger-points” have been 

established to determine the most effective means or resources that should be used on fires based 

on rates of spread, flame length and fireline intensity that are observed or predicted for given 

conditions. Intuitively, a resource(s) used to suppress a fire must have line building capability 

faster than the rate of spread to be effective in stopping the fire’s spread. Rate of Spread, flame 

length and fireline intensity determine which type of resources and how “close” to the fire they 

can attack it. These effects result to the resistance to control or the difficulty to control a fire. 

Resistance to control relates the difficulty of constructing and holding a control line as affected 

by resistance to line construction and by fire behavior. Because every fire is different these are 

used as general guidelines in assisting fire managers in determining appropriate tactical decisions

Table 43 and Table 44 displays trigger points for assisting in making these decisions.
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Table 43. Adapted from How to Predict the Spread and Intensity of Forest and Range Fires. 

Richard C. Rothermel, 1983 and Rocky Mountain Research Station Fuel Models, Scott and 

Burgan, 2005

ROS (Ch/h) Flame 

Length 

(Feet)

Fireline 

Intensity 

(Btu/ft/s) Interpretations

0 - 5 <4 <100 Fire generally can be attacked directly at the 

head or flanks by using hand tools. Use of hand 

crews with tools is effective.

Hand line should hold fire.

5-20 4-8 100-500 Fires are too intense for direct attack at the head 

of the fire by persons using hand tools.

Hand line cannot be relied on to hold fire.

Equipment such as fire engines, dozers, and 

aerially delivered fire retardant can be effective 

in control efforts on the fire.

20-50 8-11 500-1,000 Fires may present serious control problems as 

the following can be expected in forests: 

torching of trees, initiation and spread via a 

crown fire and the occurrence of spot fires up in 

front of the main fire. 

Control efforts at the head of the fire would

probably be ineffective.

50-150 >11 >1,000 Crowning, spotting, and major fire runs are 

probable. Fire usually spreads via rapid runs in 

surface fuels and crown fires in timber stands. 

Major fire spread and spotting 1 to 2 miles in 

front of the main fire is expected.

Control efforts at the head of the fire are 

ineffective.

To measure the degree of change between existing and resultant conditions between alternatives, 

the table above and an adjective class guide below was used as a guide to quantify the spread 

rates, FL, fireline intensity and resistance of control. These guide the ROS, and FLs for predicted 

fire behavior and are referred as being very low, low, moderate, high, very high, and extreme. 

Because every fire responds differently to various environmental conditions and topography 

actual predictions may be slightly high or lower. 
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Table 44. Rocky Mountain Research Station Fuel Models, Scott and Burgan, 2005

ROS (Ch/h) FL (Ft) Adjective Class

0-2 0-1 Very Low

2-5 1-4 Low

5-20 4-8 Moderate

20-50 8-12 High

50-150 12-25 Very High

>150 >25 Extreme

Alternative 1 – No Action 

Direct Effects

There are no treatments to reduce the potential extreme fire behavior under the no-action 

alternative and therefore, no direct effects. However, natural fuel accumulations would continue 

to increase as more trees begin to succumb to overcrowding, drought, insect and pathogens. This 

would increase the amount of ground and surface fuels within the area. This increase in ground 

and surface fuels would gradually begin to shift the potential fire behavior in the area, to a more 

severe stature if a wildfire were to start. This increase would be to a more severe surface fire as 

the type of fuels changed from branches and needles (0-1” material) to the larger size material 

(3+”). This change is best represented by fuel model changes or conversions mixed conifer areas 

that begin as Fuel Model TL8 would convert to Fuel Model TU5. As accumulated natural surface 

fuel loadings increased, a further conversion from Fuel Model TU5 to Fuel Model SB2, similar to 

that of a moderate slash fuel loading could occur in some areas.

Fuel Model SH2 is used to present the surface fuel conditions in existing in bush/shrub areas and 

some mixed conifer stands. Under Alternative 1, this would not change, but additional 

accumulations of larger diameter branch wood, twigs and perhaps boles of trees could increase 

the average tons/acre of surface fuels, increasing the fireline intensity and resistance to control. 

Firefighters with hand tools or water from fire engines would become less effective. Crown fire 

(a fire that advances from the top to top of trees or scrubs more or less independent of surface 

fire) potential would also remain high because none of the elements needed to propagate and 

sustain a crown fire would be removed (fuel ladders and canopy density). Because of the 

increased amount of surface fuels and the increased fire behavior associated with them, these 

potential crown fires would have the potential to propagate over a larger area. The Table 

45shows the indicators for current existing conditions and those associated with the conversions 

in Fuel Models under Alternative 1. Some helpful definitions to understand Table 45 include:

FL - Average Flame Length

ROS - Average Rate of Spread 

FLI - Average Fireline Intensity

Crown - Crown Fire Potential 

Resistance to Control - Resistance to Control Average

Fuel Loading - Average Fuel Loading 

Mortality - Mortality in White Fir / Ponderosa Pine
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Table 45. Indicators for Fuel Models in Timbered Brush/shrub Covered Areas.

Fuel Model

FL

(ft)

ROS 

(ch/hr)

FLI 

(Btu/ft/s)

Crown (transition 

and fire type)

Resistance to 

Control (low, 

mod., high)

Probability 

of Mortality 

(%) WF/PP

Sierra Mixed Conifer

Existing Conditions– TL8 4.0 7.6 117 Yes;Crowning Moderate 7/7

Future Conditions – TU5 8.6 11.3 606 Yes;Crowning Mod/High 34/44

Further Future -

Conditions -SB2

7.3 19.4 431 Yes;Crowning High 21/22

Brush/Shrub Areas

Existing Conditions– SH2 5.3 8.4 217 Yes/Crowning Moderate 12/9

Future Conditions – SH5 15.7 68.0 2,259 Yes/Crowning Extreme 99/80

It is assumed that mortality in the brush species would be from stand replacing (100%) or patchy 

dependent on the percent of the brush cover. For mortality to occur in the scrub there needs to be 

enough fire to girdle the main stem. With the predicted fire behavior, as shown above it is 

anticipated that in the Fuels model SH2 as currently exists, there would be mortality, but not as 

great as in Fuel Model SH5 (heavy shrub load covering at least 50% of the site), because of the 

lower amount old dead woody material found on the brush.

The above tables give an indication of what type of fire behavior could be expected if a fire were 

to occur within these fuel beds as they currently exist and in the anticipated fuel beds into the 

future with no management action taken. Because of the variability in the three facets needed to 

predict fire behavior; fuel, weather and topography that exist within the project area, there would 

be variations in the conditions and results of wildfire. On northern aspects, conditions would be 

expected to be cooler than southern aspects, lending to slightly slower and slightly less intense 

fires. Lower fuel loadings could produce slower rates of spread and intensities than predicted 

above. There are conditions that could produce higher rates of spread and intensities than in the 

above tables as well. These would include increased slopes, wind conditions, greater surface fuel 

loadings (both small and large down-woody debris) and increased density of ladder fuels.

Indirect Effects

In choosing the no action alternative the SNF managers would be accepting the risk and effects of 

possible severe wildfire to the watersheds, the WUI communities, and the Pacific fisher. There 

would be very limited to no potential for the utilization of prescribed fire as a form of restoration 

treatment or allow fire to play its natural role on the landscape. The risk of escape and the 

consequential effects associated with utilizing fire without some form of management activity to 

reduce current surface fuel loadings and ladder fuels would be too great. Although prescribed fire 

could be implemented under more “controlled” conditions than those conceivably present during 

the summer fire season, it would be a very narrow prescription window that could produce 

reasonable outcomes that would be beneficial versus detrimental. Just like wildfire, prescribed 

fire produces air quality concerns, risk of escape, potential negative impacts to resources (from 

control lines and fire itself), resource commitments and political/social impacts.

Cumulative Effects

Fire danger that exists in the Greys project areas does not stop at the project area boundary. As 

described in the “Affected Environment” section, the fire hazard is considerable and spreads 

throughout the national forests of the Sierra Nevada Mountains. Because the problem is so large, 
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it is necessary to concentrate fuels treatments on high priority areas where important forest 

ecosystems and the human environment coexist. Because of the large scale of the fire hazard and 

the potential spread of wildfire from outside the project area, the landscape scale is used as the 

geographic boundary for cumulative effects analysis. The ongoing and foreseeable vegetation 

management projects identified in table 8 within the Greys project area is of limited scope in 

reducing hazardous fuel conditions but conditions would intensify as described in table 5.

Fire Suppression

As surface fuels continue to accumulate naturally, with no additional management actions, 

suppression efforts would gradually become more difficult, whereby direct attack could no longer 

be used in suppressing a fire, but have to be changed to more indirect tactics, whereby more area 

has the potential to be affected by fire, in some cases high intensity and more severe fire. With the 

increases in fire behavior generated by these surface fuel changes, fire suppression forces would 

have higher resistance to control due to fuel loading and by fire behavior. Aerial retardants 

would be less effective due to closed continuous canopy. If fire were to start in or burn into the 

project area, ground and aerial initial attack operations as well as extended attack would become 

less effective and firefighter and public safety would be difficult to ensure.

Fire Effects

Fire influences many portions of a fire dependent ecosystem by either its presence or even its 

absence. Forest stand structures, wildlife habitat, aquatic communities, watersheds, plant 

communities and soil conditions, to name a few can be influenced. Without frequent fire to clean 

the understory of stands, excessively dense stands lead to drought stress and bark beetle 

outbreaks, resulting in wide spread mortality of trees in many areas and the potential for extensive 

mortality. This leads to a large increase in the amount and continuity of both live and dead forest 

fuels, resulting in a substantial increase in the probability of large, severe wildfires 

(Weatherspoon, C.P., 1996). These are directly correlated to the conversions of Fuel Models 

discussed in the Existing Conditions section.

With increased rates of spread, flame lengths, and fireline intensities there is potential for greater 

fire effects to occur. Because of existing changes in tree species composition, from fire resistant 

to fire susceptible, tree mortalities would increase with small incremental changes in wildfire 

intensity. This, in combination with drought or insect/pathogen induced mortality in overstocked 

stands, could greatly increase the amount of surface fuel loading, thus increasing fire behavior 

and intensity of subsequent wildfires. Under Alternative 1, there would be no reduction in 

surface and ladder fuels; to raise mean canopy base heights and/or decrease canopy bulk densities 

as has been suggested in the desired condition for creating fire resilient stands. Vertical 

continuity of fuels from the forest floor to the crowns of overstory trees would be present and 

with sufficient radiant/convective heat could produce crown fire. Some studies and models, 

however, suggest a crown fire entering a stand is rarely sustained (i.e., sustained only under 

extreme weather conditions) (North, M., et.al, 2009). Calculated and predicted crown fire 

potential (Table 46) show that conditions are present in the project area to produce the potential 

for crown fire. This could be in the form of torching single trees, groups of trees and/or active 

crown fire dependent on weather, fuels and topography of where the fire were to occur.

Crown fires remove much of the entire tree canopy in a particular area, essentially resetting the 

successional and growth processes of stand and forests. These fires typically, but not always kill 

or temporarily reduce the abundance of understory shrubs and trees. Crown fires have the largest 

immediate and long-term ecological effects and the greatest potential to threaten human 

settlements near wildland areas (Graham, R., et.al, 2004). For wildlife species dependent on 

diverse forested landscapes (heterogeneity) characteristics for habitat, this successional “setback” could pose negative consequences.
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Although crown fires would be considered of higher consequence of negative effects, surface and 

ground fires with higher intensities similar to those predicted and anticipated in this alternative, 

can also have negative impacts. While surface fires can reduce vegetation and woody, moss, 

lichens and litter strata, ground fires that consume large amounts of woody fuels and organic soil 

horizons can produce disproportionately large amounts of smoke. Ground fires reduce the 

accumulation of organic matter and carbon storage and contribute to smoke production during 

active fires and long after flaming combustion has ended. These fires can also damage and kill 

large trees by killing their roots and the lower stem cambium. Because ground fires are often of 

long duration, they may result in greater soil heating than surface or crown fires, with the 

potential for reducing organic matter, volatilizing nutrients, and creating a hydrophobic layer that 

contributes to erosion. Areas where the ground cover is removed and severely burned would

likely see decreased infiltration of water, increased surface runoff and peak flows, and the 

formation of pedestals, rills and gullies (Graham, R., et.al, 2004).

Depending on the setting (in particular topography and soil), perennial streams downstream from 

fires can be impacted by large volumes of sediment. Depending on the recovery of the hill 

slopes, these fire effects can be long lasting, and relatively little can be done to stop the problem. 

Large amounts of sediment can be delivered to reservoirs, reducing water storage capacity and 

potentially affecting fish and macro invertebrate habitat (Graham, R., et.al, 2004). 

Summary of Effects 

Alternative 1 would not meet the purpose and need for this project. There would be no thinning; 

commercial and precommercial thinning accomplished. Forest health in the area would continue 

to decline. No connection and augmentation of fuel treatments within and adjacent to the WUI 

would be completed. No DFPZ and fuelbreak work would be completed.

The predicted rate of spread, flame length, and fireline intensity would increase due to fuel 

accumulation if left untreated. Full suppression would continue to be the management direction 

for the Greys Project area. Because of the continued and potential increased threat to life and 

property, under Alternative 1, firefighting resources would focus strategies and tactics on 

reducing the impacts on communities, protecting infrastructure and private property as the highest 

priority followed by protection of natural resources. The resistance to control would increase 

from Low/Moderate to Moderate to Very High. Aerial fire suppression would not support ground 

forces due to the inability of retardants to reach ground fuels because of closed canopy cover.

Alternative 2 – Proposed Action 

Design Features and Mitigation Measures

Treatments are proposed to reduce surface fuels, ladder fuels, and some aerial fuels to meet the 

purpose and need of reducing stand densities to restore forest structure and composition towards 

heterogeneity and biodiversity, and reduce the potential for uncharacteristically severe wildfire. 

This is to occur, if one of these alternatives were chosen, through the use of mechanical methods 

as well as management ignited fire in the form of prescribed fires such as pile burning, and 

understory burning. Prescribed fire would be applied to the project area for three purposes: 1) as 

a final “cleaning” after vegetation management treatments to further reduce 1, 10 and 100 hour 

fuels (those fuels that have the greatest influence on fire spread); 2) to maintain the lower levels 

of the 1, 10, and 100 hour fuels; 3) to reintroduce the fire element back into a fire dependent 

ecosystem.

First treatment areas were designed to create SPLAT’s to reduce the intensity and spread of 

wildfires in and around WUI. Treatment areas near key transportation corridors and within the 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 244 Chapter 3

defense zone of the WUI were designed next then followed by linear DFPZs and fuelbreaks 

located near roads and along ridges used as a line of defense or control point for fire suppression 

activities. Treatment areas were further designed to not only focus on those treatments needed to 

meet fire and fuel objectives (treatments defined for fire/fuels are designed to reduce the ladder 

and surface fuels and occur within the lower and limited mid-level canopy) but areas where the 

stands were considered overstocked with conifers and are in higher levels than can be sustained 

with changing environmental conditions and are vulnerable to loss from insect, disease and 

wildfire (ecological and forest health objectives) (treatments defined for ecological restoration are 

designed to reduce basal area and stocking to such a level that the stands are resilient to changing 

environmental conditions, increase growth and are vigorous with reduced susceptibility to insect 

and disease attack and wildfire. These treatments occur within the lower and mid-level canopy).

The utilization of prescribed fire only as a form of restoration treatment would be conducted in 

treatment areas identified as “Rx” units. These units would have at least two prescribe fire entries 

within the lifespan of the project. Utilization of prescribed fire after structural restoration 

treatments have been completed would be conducted in treatment areas identified as “H” and “T”. 

These units may include pile burning, understory burning or a combination of both. 

Direct Effects 

Under this alternative, thinning from below, through precommercial and/or commercial means 

would focus first on the smaller trees for removal gradually moving through the lower canopy 

levels with the potential to remove trees within the mid-level canopy to reach a silvicultural 

prescribed basal area and stocking level. Through the treatments in Alternative 2, the 

recommendations in Table 1 are accomplished by reducing surface and ladder fuels, increasing 

canopy base height, decreasing crown density, retaining larger trees and retaining fire resistant 

tree species.

Fuel Model Changes

Under Alternative 2, the existing fuel model would be converted to another fuel model, typically 

a fuel model with lower surface fuel loadings and reduced fire behavior. In areas currently 

represented by Fuel Model SH2, mastication would be used to convert it to a Fuel Model SB1 

(light dead and down activity fuel) and/or SB2. Mastication in effect does not remove the fuel 

from the site, but changes the structure of the fuel from a vertical orientation to a horizontal 

orientation. Small chips, shredded material and/or crushed fuels (dependent on masticator head) 

are left on site. A fuel model that represents an increase in fuel loading in the 10 and 100-hour 

time lag categories is needed to show this. SB1 and SB2 are used as base fuel models with 

increases in 10 and 100-hour fuel loadings to approximately 10 - 30 tons per acre each and the 

removal of live woody fuel loading to approximate this conversion.

In timbered stands represented as Fuel Model TL3 and TL8, there would be or no conversion to a 

different fuel model. In stands represented by Fuel Model TU5 and SB2, would convert them to 

a Fuel Model TL8 dependent on the overstory and surface fuels remaining. In some cases, a 

short-term conversion to a Fuel Model SB2 or TU5 may occur until post activity treatments were

completed, and then a conversion to a Fuel Model TL8 would result.

The fuel model conversions shown are used to depict the conditions anticipated in the surface fuel 

bed changes as a result of the treatments proposed in this alternative. This alternative is also 

anticipated to raise canopy base heights, with the thinning or removal of ladder fuels from an 

average of 0-10 feet to an average of 20 feet. Canopy bulk density would also be decreased 

through the thinning of lower and mid-level canopies. It is estimated that, on average the canopy 

bulk density would be changed from 0.0119 lb/ft3 to 0.00874 lb/ft under Alternative 2.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 245 Chapter 3

Surface and ladder fuels

The removal and/or thinning of the lower canopy in effect removes the ladder fuels that can 

provide the means for surface fires to “climb” into the overstory canopy. In areas where there is a 

significant amount of ladder fuels present, combination of tractor or hand piling and burning 

would be used to remove excess material. In areas where brush species are the dominant 

vegetation cover, masticators would be used to in effect change the vertical continuity of the fuel. 

While mastication does not actually remove fuel from the area, it does change the structure from 

a vertically oriented fuel (ladder fuel) to a horizontal fuel potentially making fire suppression 

resistance to control lower and fire effects less in most cases. In areas where there are lower 

amounts of ladder fuels and/or smaller areas, mastication and/or hand cutting would be used to 

open or separate the lower canopy from the mid to upper level canopy. Typically, these areas 

have lower levels of surface fuels existing (smaller amount of trees/vegetation, less amounts of 

naturally accumulated or activity generated surface fuels).

Dependent on the type of harvest system used for removal of excess commercial-sized material, it 

is anticipated there may be a short-term increase in surface fuel loading or no significant increase. 

Whole-tree yarding, used as a harvesting system, can minimize the amount of activity generated 

fuels (Stephens, S., 2009). If whole tree yarding is not used, additional post harvest treatments 

would be needed to reduce surface fuel loadings that are in excess of 20 tons/acre (SNFPA ROD, 

2001). These post activity treatments would include dozer and/or hand piling and burning and/or 

broadcast/jackpot burning. 
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Fire Behavior / Fire Effects 

Table 46. Shows the predicted results of fuel model conversions anticipated with this 

Alternative.

Fuel Model FL

(ft)

ROS 

(Ch/hr)

FLI 

(Btu/ft/s)

Crown

(Transition and 

fire type)

Resistance to 

Control

(Low/Med/

High)

Probability 

of Mortality 

(%) WF/PP

True Fir

(above 6,000 ft)

Existing Conditions- TL3 1.3 2.2 9 No/CondCrown Low 0/0

Short Term Conversion- TL5 2.6 5.7 44 No/CondCrown Low/Mod 4/6

Future Condition -TL1 .7 1.2 3 No/Surface Very Low/Low 0/0

Future Condition - TL3 1.3 2.2 9 No/Surface Low 0/0

Sierra Mixed Conifer

(moderate fuel loading w/some brush)

Existing Conditions- TL8 4.0 7.6 117 Yes/Crown Low/Mod 7/7

Short Term Conversion- TL5 2.6 5.7 44 No/CondCrown Low/Mod 4/6

Short Term Conversion- SB2 7.3 19.4 431 Yes/Crowning Moderate 21/22

Future Condition - TL1 0.7 1.1 3 No/Surface Very Low/Low 0/0

Future Condition - TL8 4.0 7.6 117 No/Surface Low/Mod 0/0

Sierra Mixed Conifer

(moderate-heavy fuel loading)

Existing Conditions- TU5 8.6 11.3 606 Yes/Crowning Mod/High 34/44

Short Term Conversion- SB2 7.3 19.4 431 Yes/Crowning Moderate 21/22

Short Term ConversionTU5 8.6 11.3 606 Yes/Crowning Mod/High 34/44

Future Condition - TL8 4.0 7.6 117 No/Surface Low/Mod 0/0

Sierra Mixed Conifer

(heavy fuel loading)

Existing Conditions- SB2 7.3 19.4 431 Yes/Crowning Moderate 21/22

Short Term Conversion- SB2 7.3 19.4 431 Yes/Crowning Moderate 21/22

Future Condition - TL8 4.0 7.6 117 No/Surface Low/Mod 0/0

Brush/Shrub

(includes some mixed conifer stands 

with brush understory)

Existing Conditions-SH2 5.3 8.4 217 Yes/Crowning Moderate 12/9

Future Condition - SB1 3.7 8.0 100 No/Surface Low/Mod 0/0

Future Condition - TU1 2.0 3.3 27 No/Surface Low 0/0

Future Condition - SB2 7.3 19.4 431 No/Surface Low/Mod 17/14

Table 46 gives an indication of what type of fire behavior could be expected if a fire were to 

occur within these fuel beds as they currently exist, short term conversion after the treatment but 

before the disposal of activity created fuels, and anticipated future condition fuel beds after 

disposal of activity created fuels were to occur. The range of fuels models in the future condition 

are based on mitigation measures in mixed conifers areas and brush density in plantations. 

Because of the variability in the three facets needed to predict fire behavior; fuel, weather and 

topography within the project area, there would be variations in the conditions and results of 

wildfire. On northern aspects, conditions would be expected to be cooler than southern aspects, 

lending to slower and less intense fires. Lower fuel loadings could produce slower rates of spread 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 247 Chapter 3

and intensities than predicted above. There are conditions that could produce higher rates of

spread and intensities than in the above tables. These would include increased slopes, wind 

conditions, greater surface fuel loadings (both small and large down-woody debris) and increased 

density of ladder fuels. Figure 24 graphically displays the modeled fire behavior changes with 

each alternative. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 248 Chapter 3

Figure 24. Hauling Chart displaying modeled surface fire behavior by fuel models for each 

project alternative.

Indirect Effects 

Past and present actions for the project area, along with fire management policy of full 

suppression at the smallest size (97 percent of all fires will be controlled at 10 acres or less from 

SNF LRMP, 1996) have contributed to the current existing condition for the project area and are 

used to depict the existing condition and the resultant fire behavior within the project area.

Cumulative Effects 

Past, Present and Reasonably Foreseeable Activities

Table 47 summarizes the effects that the past, present, and reasonably foreseeable action would 

have on fire behavior within and outside the project area. These effects cumulatively show both 

reduction and increase of potential wildfire behavior and associated effects on resources (wildlife 

habitat, soil, aquatic habitat). Not all projects affect fire behavior and fuels but would have an 

overall effect of improving the resiliency of the forest to severe wildfire.
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Table 47 Cumulative Effects: Past, Present and Reasonable Foreseeable Activity, summary.

Activity Type Description YearTimeframe

Cumulative Effects on 

Project Area

Cedar Valley 

Thinning Project

Thinning and pile burning to reduce the 

potential for severe fire. Located east of 

the project area.

2006

Past

Treatments reduce density 

also reduce fire severity. 

Increases area that is more fire 

resilient

Redwood Creek 

Project

Thinning and pile burning to reduce the 

potential for severe fire. Located 

southeast of the project area.

2008

Past

Similar to Cedar Valley 

Project.

Bass Lake RD 

Fuelbreak Projects;

Granddad, Sivels, 

Chepo

Create and maintain 3 fuelbreaks and 

maintain 1 existing fuelbreaks in the 

Grey Project.

Past, present, 

foreseeable 

Treatments that reduce 

density, surface and ladder 

fuel loads also reduces fire 

intensity and severity. 

Increases area that is more fire 

resilient.

Timber Sales Timber management projects. 1970 -

Present

Similar to Cedar Valley 

Project. Fuels continue to 

accumulate over time and 

would cause increases in fire 

behavior and resistance to 

control.

Roadside Hazard 

Tree Removal 

Removal of damaged, rotten, dead trees 

to abate roadside hazard. 

1990 Past, 

present, 

foreseeable

Biomass removal reduces 

resistance to control.

Plantation 

Maintenance 

Thinning, hand release, chemical 

release, mastication, and planting in 

plantations.

Past Similar to Bass Lake RD 

Fuelbreaks.

Cultural Resource Past mitigation treatments and practices 

- flag and avoid cultural resource sites. Past - Present

Increased fuel load and 

density may increase fire 

severity and higher resistance 

to control.

Private Land 

residential 

development 

Subdivision, timberland conversion to 

housing tract. Foreseeable

Increases level of risk due to 

increase in WUI from general 

forest.

Private Land – One 

Mind Parcel

Unknown history of vegetation 

management. Ongoing

Increases level of risk due to 

fire ignition from private 

property to general forest.

Campgrounds -

Texas Flat, 

Chilkoot, Greys 

Mountain 

Improve and maintain campground 

facilities and surroundings.

Past, present , 

foreseeable

No effect on facilities but pest 

management through biomass 

removal reduces resistance to 

control.

Motorized 

Recreation Trails

4X4, Off Road Vehicle (OHV), travel 

on designated routes. Continued trail 

maintenance. 

Ongoing, 

Past, present , 

foreseeable

Treatments reduce density 

also reduce fire severity. 

Increases area that is more fire 

resilient

PG&E 

Transmission Line Right of way maintenance. 

Ongoing Past, 

present , 

foreseeable

Vegetation Management. –

PG&E Transmission Line 

Livestock Grazing Grazing of light fuels.

Ongoing Past, 

present , 

foreseeable 

Livestock Grazing could 

reduce rate of spread and 

resistance of control.

Roads Maintenance of existing roads (grading, 

brushing and cleaning of culverts) 

Ongoing Past, 

present , 

foreseeable

Lack of maintenance could 

cause a delay in response to 

fire suppression activities or 

escape.
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Sierra National Forest – 250 Chapter 3

Fire Suppression

Alternative 2 reduces ladder fuels which in turn increases canopy base height. Canopy density (in 

the form of canopy bulk density) would be decreased through the thinning of the mid-level 

canopy, and to a small extent through the reduction in fuel ladders. These, in combination, 

reduce rates of spread, flame length, fireline intensity, resistance to control and the potential for a 

fire to transition into crown fires. Decreasing crown density may increase surface winds (less 

canopy to reduce winds before they reach the ground) and surface fuels may be drier (more 

sunlight reaching the ground). These do have the potential to increase fire behavior. It is 

estimated that Alternative 2 would not open canopies to the extent needed to realize these 

concerns. It is estimated that in most areas, canopies would remain at 60 percent or greater in the 

overstory even after treatment. This change would not be significant enough to change the 

amount of wind reaching the surface. There would be small amounts of increased sunlight to dry 

fuels, but not significant enough to dramatically change fire behavior. 

If full fire suppression continues as the management strategy for unplanned ignitions within the 

project area, fire suppression resources would have an increased capacity to control fires at initial 

attack with minimized risk to their safety (and the public) and increased ability to keep these fires 

small in size with the use of direct attack tactics versus indirect tactics. Fires would typically 

drop from the crowns to the forest floor. Aerial firefighting resources would be better able to 

penetrate the canopy to aid ground resources with reduced canopy density, even moderate 

amounts as an indirect effect of treatments in Alternative 2.

Design features used to minimize effects and/or retain habitat structures preferred by wildlife 

species such as; grouping of larger trees, oak retention with ladder fuels retained under them and 

OFLs with limited treatments would have lower potential for loss since there would be treated 

areas between them and are not continuous. This would be similar to the variability in forest 

conditions produced by frequent fire (North, 2009). 

In utilizing mechanical treatments, as in Alternative 2, stand structures are modified quickly and

more precisely than with prescribed fire alone (North, 2009). Under this alternative, treatments 

are effective in breaking up the horizontal and vertical continuity of live fuels in the lower canopy 

layers and/or in effect pre-treating the stands to more readily allow prescribed fire to be 

introduced. Silvicultural cuttings can only partially substitute for fire and are needed in addition 

to or in lieu of fire in many areas to move conditions away from dense forests to more open 

forests dominated by large trees. (Weatherspoon,1996). This alternative allows increased 

potential to utilize prescribed fire as either a maintenance treatment and/or in conjunction with 

mechanical treatments as a follow-up process to achieve forest resilience. Fire could mimic the 

natural ecosystem functions of frequent low-to-moderate severity fire. Under this alternative, 

prescribed fire, whether burning of piles and/or broadcast burns can be implemented with less 

risk of escape, with a broader range of acceptable conditions and in some cases less impacts to air 

quality (Weatherspoon, 1996).

Fire Effects

With the removal of what is considered the suppressed, intermediate and some co-dominates 

within a stand, the vegetation considered ladder fuels would be removed. Conifer species such as 

Ponderosa Pine and Sugar Pine, which are considered more fire resistant, would be favored to 

remain in a stand over shade tolerant and fire sensitive species, such as incense cedar and white 

fir. Incense cedar and white fir make up the largest percentage of conifers found in the 

understory of stands in the project area (based on sampled plot data). These species also tend to 

have increased susceptibility to wildfire as well tend to have limbs that stay closer to the ground 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 251 Chapter 3

providing increased ability to take surface fires into the crowns in the form of single tree torching 

or group torching. With species composition favored towards the more fire resistant, shade 

intolerant species and fire behavior modified, effects to stands (mortality) would be decreased.

As part of this alternative, treatments would be implemented to reduce surface fuels, where 

needed. In most cases, as been experienced in past projects similar to this alternative, these areas 

are not continuous over the entire treatment area. If a fire was to start in an area where these 

surface fuels have not been reduced, fire behavior would be increased (as represented by Fuel 

Model SB2). The results of wildfire impacts on areas treated only with mechanical methods are 

mixed. Some burned with higher intensity, than those where mechanical treatments were 

followed by prescribed burning, though with lower severity than untreated control areas 

(Stephens, S. 2009). The timing and sequence of these “clean-up” treatments are dependent on 

several factors, such as adequate funding and completion of harvesting operations. Those 

treatment areas closest to WUI would be treated first and then would progress into other areas 

from there. As stated earlier the surface fuel load changes would be largely based on harvesting 

system used. If whole-tree yarding is used, post treatment areas where natural fuel accumulations 

are above 20 tons/acre would be the areas where secondary treatment would be used. These are 

areas expected to be less (acres) in need of surface fuel reduction.

With reduction in fire behavior, the effects of fire on other ecosystem components would be 

reduced and perhaps enhanced. Many are resistant or often have favorable responses to low to 

moderate fire intensity and severity. The idea of preemptive work that restores historic fire 

regimes has not been widely discussed, considered, or used to address both the ecological and 

social issues surrounding fires and watershed resources. The same can be said for many of the 

wildlife species that live and depend on the forested ecosystem. At-risk species, and the 

ecological functioning systems they depend on, cannot be sustained or recovered without the 

immediate and longer-term ecological functioning provided by fire. In Alternative 2, integrating 

fire and fuels management objectives and forest health restoration with at-risk species 

conservation and protection are made. This is needed to provide both the viability of human 

communities and at-risk species where both overlap (Sugihara, N., and et.al. 2006).

Climate Change and Fire Severity Relationships

As stated earlier, weather has a large influence on fire behavior and is also the most difficult to 

predict. High-severity fire in California mixed-conifer forests has increased in frequency and 

extent in recent decades because of the combined effects of increasing forest fuels from fire 

exclusion and climate change, particularly temperature, on burning conditions in these fuel-rich 

forests (Miller et al.2009). Associated with the purpose and need to reduce stand densities to 

levels where trees would be more resilient to drought conditions, reducing surface and ladder 

fuels to reduce wildfire intensity and spread, can also produce benefits in drought conditions. 

Research suggests global mean minimum temperatures may have already begun to rise. One 

effect of this change for western forests would be earlier spring melt of mountain snow packs. 

An analysis of western U.S. fire season length over the last 50 years suggests that during the last 

two decades, fires begin earlier in the spring and occur later in the fall possibly due to this trend 

in elevated nighttime minimum temperatures (Westerling et al. 2006). Though there are 

variations in predictions and models, one point of consensus is that most agree the climate will 

become warmer and more extreme, suggesting oscillations between wet and drought conditions 

will be more common (North, 2009). Climate projections with increased atmospheric carbon 

dioxide and general circulation models predict continued warming in California into the 21st 

century (Hayhoe et. al. 2004).

Climate change heightens the risk of stand-replacing fire in these highly altered forests. 

Restoration of the self-limiting fuel–fire–forest structure mosaic that characterized these forests 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 252 Chapter 3

before fire suppression with prescribed fire would reduce the risk of unusual high-severity fire 

(Scholl 2010). Changing climates in the next several decades may further complicate fire 

management by increasing temperatures and fire season length (Stephens, S. et.al, 2009). Fires 

now occur less frequently and cover much less area, but are likely to be large and severe when 

they do occur (SNEP, 1996).

Managing forests under these conditions will be challenging. In the face of uncertainty, adaptive 

strategies should focus on three responses; resistance (forestall impacts and protect highly valued 

resources), resilience (improve the capacity of ecosystems to return to desired conditions after 

disturbance), and response (facilitate transition of ecosystems from current to new conditions) 

(North, 2009). Alternative 2 uses the first two strategies (resistance and resilience) and attempts 

to build, through its purpose and need, the adaptive capacity of forest ecosystems to climate 

changes and uncharacteristic fire behavior that occurs under extreme weather and ignition 

conditions (North, 2009; Stephens et al. 2010).

Summary of Effects 

Under Alternative 2, ladder and surface fuels are reduced to levels that would meet the purpose 

and need for fire and fuels. The development of Strategically Placed Area Treatments (SPLAT’s) 

which reduces the risk of wildfire and modifies fire behavior over the broader landscape would 

occur. Additional areas would be treated to provide a fuelbreaks and defensible fuels profile near 

key transportation corridors and within the defense zone of the wildland urban intermix. By 

decreasing fuel ladders, which raises canopy base heights and reducing surface fuels, fuelbeds are 

converted from ones that produce moderate to high fire behavior to fuelbeds that produce 

moderate to low fire behavior. In addition to those treatments needed to meet fire and fuels 

objectives, treatments would be created to reduce stand densities (basal area) to such a level as to 

improve the growth and vigor of remaining trees. 

Alternative 3 

In Alternative 3, treatment areas would remain the same as in Alternative 2, treatments within 

these areas would include only those needed to reduce the surface and ladder fuels (within the 

lower and limited mid-level canopy levels) needed to achieve fire and fuels objectives. Under 

Alternative 3 there would be no additional treatments (i.e. additional thinning in the mid-level 

canopy) to fully address stand density and forest resiliency.

Direct Effects 

Under Alternative 3, there would be no significant change in the direct effects from those listed 

under Alternative 2. There is a potential for a decreased amounts of additive surface fuel loading 

within all “T” treatment areas resulting from less conifers being removed. As stated in 

Alternative 2, resultant increases or decreases in surface loadings from harvesting operations are 

dependent on the type of harvesting operations that are used. By increasing canopy base heights 

and reducing surface fuel loadings, fire and fuels objectives are met. 

Indirect Effects 

Under Alternative 3, there would be no significant change in the indirect effects from those listed 

under Alternative 2. There is a potential for aerial firefighting resources to be less effective in all 

“T” treatment areas with no reduction in mid-level canopy densities. Increased crown densities in 

the den site area would make it difficult for retardant and/or water dropping from helicopters to 

penetrate to the ground. In assuring the reduction in ladder fuels to raise canopy base heights 

from 0-10 to 20 feet and reducing surface fuel loadings, fire intensity and spread are reduced to 

desired condition levels and meet the fire and fuels objectives stated in the purpose and need of 

the project.
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There is little to nothing done to reduce forest stand densities within the Fisher den site area 

though with this alternative and could produce losses from drought induced mortality, insect and 

disease. Long-term, these types of disturbances could induce increases in surface fuel loadings 

and/or increased snag levels producing conditions similar to those already existing in the project 

area with resultant fire behavior (intensity and spread rates) similar to those predicted in

Alternative 1, with the exception of crown fire potential. It is assumed that with the reduction in 

ladder fuels, there would be increases in rates of spread; increase flame lengths, increased fireline 

intensity, and increased resistance to control, similar to that seen in Fuel Model TL8 in 

Alternative 1, but this would be as a surface fire with potential for crown fire reduced and/or 

eliminated. Fire intensities could cause the potential for single or group tree torching because of 

the increased number of fire susceptible trees such as white fir and incense cedar left in the stand, 

but this is expected to be less than in Alternative 1

Cumulative Effects 

Under alternative 3, there would be no significant change in cumulative effects from those listed 

under alternative 2. 

Summary of Effects 

Alternative 3 reduces ladder and surface fuels to levels that will meet the purpose and need for 

fire and fuels. Although Alternative 3 shows there is a greater potential and risk for condition 

crowning due to closer crown density than Alternative 2. Alternative 3 does little to nothing for 

the multi-objective purpose and need of the project which includes reducing stand densities to 

improve forest health.

Comparison of Alternatives

Fuel models displayed are based on averaged worst case scenarios after post treatment. Table 48

shows that treatments in the proposed alternative and alternative 3 are effective in reducing 

potential flame length, rate of spread, fireline intensity, and resistance to control. Alternative 3 

shows there is a greater potential and risk for condition crowning due to closer crown density.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

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Table 48 Comparison of Fire Suppression and Effects Measured By Indicators.

Indicators

Alternative 1 –

No Action

Alternative 2 –

Proposed Action

Alternative 3 -

Mixed 

Conifer SB2 

Brush / 

Shrub SH5

True fir

TL3

Mixed 

Conifer 

TL8

Mast

SB2

True fir 

TL3

Mixed 

Conifer 

TL8

Mast

TU1

Fire Suppression

FL

(feet)

7.3 15.7 1.3 4.0 7.3 1.3 4.0 7.3

ROS 

(ch/hr)

19.4 68 2.2 7.6 19.4 2.2 7.6 19.4

FLI (Btu/ft/s) 431 2,259 9 117 431 9 117 431

Resistance to 

Control (low, 

mod., high)

High Extreme Low Low/Mo

derate

Low/Mod

erate

Low Low/Mode

rate

Low/Mode

rate

Fire Effects

Crown 

(transition and 

fire type)

Yes/

Crowning

Yes/

Crowning

No/

Surface

No/

Surface

No/

Surface

No/CondC

rown

No/CondC

rown

No/CondC

rown

Mortality (%) 

WF/PP

21/22 99/80 0/0 0/0 17/14 0/0 0/0 17/14

Effects to Fuels Management from proposed changes in treatments

The 128 acreage change from light mechanical thinning to prescribed burning only would not 

significantly alter effects determination to Fire/Fuels Management because fuels would still be 

reduced through the form of prescribed fire. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 255 Chapter 3

Air Quality _________________________________

The direct, indirect and cumulative effects to Air Quality are summarized from the Air Quality 

report for the Grey’s Mountain Ecological Restoration Project (Smith G., 2012)

Introduction

This report analyzes the direct, indirect and cumulative effects to Air Quality and visibility from 

the alternatives proposed to meet this purpose and need as well determines the General 

Conformity of these actions to the Clean Air Act. The direct, indirect and cumulative effects to air 

quality and visibility are summarized from the Air Quality Report for the Greys Mountain Project 

(Smith, G. 2010).

Overview of Issues Addressed

Fire is an important part of California ecosystems, but it also produces combustion by-products 

that are potentially harmful to human health and welfare. Carbon dioxide and water are the two 

products of complete combustion and generally make up 90 percent of the total emissions from 

wildfire. In incomplete combustion that occurs under wildfire conditions, smoke is composed of 

carbon dioxide, water vapor, carbon monoxide, particulate matter, hydrocarbons, and other 

organic compounds, nitrogen oxides, trace minerals and several thousand other compounds. 

Particulate matter is the principle pollutant of concern to human health from wildfire smoke for 

the short-term exposures typically experienced by firefighters and the public. Studies indicate 

that 90 percent of smoke particles emitted during wildland burning are particles that measure less 

than ten microns in size (PM10), and about 90 percent of these are less than 2.5 microns in size 

(PM2.5). Hydrocarbons and nitrogen oxides from large wildfires contribute to increased ozone 

formation (which causes injury to plants) under certain conditions (Ahuja 2006). 

Issues Relevant to Air Quality

There are two general strategies to managing wildfire smoke: (1) emission reduction and (2) 

emission redistribution. All pollutants except nitrous oxide are negatively correlated with 

combustion efficiency, so actions that reduce one pollutant result in the reduction of all. 

Emission redistribution techniques may effectively keep smoke impacts away from sensitive 

areas, but does little to reduce the amount of emissions produced. But optimal use of reduction 

techniques can reduce emissions by approximately 20 to 25 percent, assuming all other factors 

(vegetation types, acres, etc.) were held constant and land management goals were still met. 

Emission reduction techniques can include reducing the area burned, reducing fuel loading, 

reducing fuel production, reducing fuel consumption, and scheduling burning before new fuel 

appears and increasing combustion efficiency (Ahuja 2006). These reduction techniques, which 

can include prescribed fire, mechanical harvesting (which includes road work, cutting, and 

hauling of material) and vegetation management treatments (mastication and mechanical piling) 

can produce emissions that can affect human health and visibility.

Affected Environment

Fire is an important part of California ecosystems, but it also produces combustion by-products 

that are potentially harmful to human health and welfare. Carbon dioxide and water are the two 

products of complete combustion and generally make up 90 percent of the total emissions from 

wildfire. In incomplete combustion that occurs under wildfire conditions, smoke is composed of 

carbon dioxide, water vapor, carbon monoxide, particulate matter, hydrocarbons, and other 

organic compounds, nitrogen oxides, trace minerals and several thousand other compounds. 

Particulate matter is the principle pollutant of concern to human health from wildfire smoke for 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 256 Chapter 3

the short-term exposures typically experienced by firefighters and the public. Studies indicate 

that 90 percent of smoke particles emitted during wildland burning are particles that measure less 

than ten microns in size (PM10), and about 90 percent of these are less than 2.5 microns in size 

(PM2.5). Hydrocarbons and nitrogen oxides from large wildfires contribute to increased ozone 

formation (which causes injury to plants) under certain conditions (Ahuja 2006). 

There are two general strategies to managing wildfire smoke: (1) emission reduction and (2) 

emission redistribution. All pollutants except nitrous oxide are negatively correlated with 

combustion efficiency, so actions that reduce one pollutant result in the reduction of all. Emission 

redistribution techniques may effectively keep smoke impacts away from sensitive areas, but does 

little to reduce the amount of emissions produced. But optimal use of reduction techniques can 

reduce emissions by approximately 20 to 25 percent, assuming all other factors (vegetation types, 

acres, etc.) were held constant and land management goals were still met. Emission reduction 

techniques can include reducing the area burned, reducing fuel loading, reducing fuel production, 

reducing fuel consumption, and scheduling burning before new fuel appears and increasing 

combustion efficiency (Ahuja 2006). These reduction techniques, which can include prescribed 

fire, mechanical harvesting (which includes road work, cutting, and hauling of material) and 

vegetation management treatments (mastication and mechanical piling) can produce emissions 

that can affect human health and visibility.

The Greys Project is within the San Joaquin Valley Air Pollution Control District (SJVAPCD) for 

Madera County. The district is responsible for implementing and regulating sources that degrade 

air quality and is responsible for meeting Federal and State air quality standards. The Air 

Resources Board (ARB) has oversight authority to monitor performance of district programs. 

The affected environment (geographic area) in this analysis includes areas that would or could 

experience degradation as a result of the actions proposed. SJVAPCD is considered the air basin 

downwind from the Greys Project and is the air basin direct, indirect and cumulative impact 

analysis is focused on.

The Greys Project is located within the defense and threat zones of the Wildland Urban Interface 

(WUI) and situated adjacent to residential areas of Redwood Creek to the southwest, Paradise 

Springs to the northwest, and Soquel Meadows to the north. Communities surrounding the Greys 

Project include Bass Lake to the south, Sugar Pine and Cedar Valley to the west. Calvin Crest 

Christian Camp and Nelder Grove Historical Area of giant sequoia also lie to the west of the 

project. 

Communities, State Highways, Class I Airsheds, and recreation sites are considered smoke 

sensitive receptors where smoke and air pollutants can adversely affect public health, safety and 

welfare. These areas could be affected by smoke if weather patterns produce a stable air mass and 

smoke is unable to vent into the upper atmosphere. Since PM10, PM2.5and ozone are public health 

hazards, prescribed burns would be planned during periods of unstable air, which would allow for 

proper ventilation and temperatures less than 95 degrees. However, since prescribed underburns 

could last for several days or weeks there is the potential for recurring shifts in air masses toward 

more stable conditions. For this reason, all prescribed fire activities are coordinated with the 

SJVAPCD and would be implemented under optimum conditions using best available control 

measures (listed in Chapter 2 under Air Quality to prevent smoke concentrations from affecting 

local communities. Sensitive receptors were considered within 100 kilometers (10 miles) of the 

project area and are listed in Table 49 below.
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Table 49.Sensitive receptors identified within 10 miles of the Greys Project

Sensitive Receptor Type Location

Towns, Communities, Residential Areas Sugar Pine, Cedar Valley, Oakhurst, Paradise springs,, 

Bass Lake, Redwood Creek, Old Corral

Recreation Areas Designated Motorcycle Trails, Westfall Day Use, Lewis 

Creek Natural Scenic Trail, Goat Meadow Winter Sports 

Area, Yosemite Sugar Pine Railroad, Bass Lake, Calvin 

Crest Christian Camp, Paradise Springs, Jones Store

Campgrounds Nelder Grove, Big/Little Sandy, Kelty Meadow, Fresno 

Dome, Summerdale, Summit, Soquel, Westfall, Greys 

Mtn., Bass Lake C.G.s, Greys Mountain, Texas Flat

FS Work Center/Ranger Station Westfall, Batterson, Oakhurst Visitor Information Center

Roads State Highway 41, Forest Service and County Roads

Class I Federal areas See Table 3 for Class I areas

Other Private land within and adjacent to the project area

Existing Condition

The air quality in the San Joaquin Valley is among the poorest in the state. On average, the San 

Joaquin Valley experiences 35–40 days when it exceeds the federal health-based standards for 

ground-level ozone, and more than 100 days when it exceeds the state ozone standard. While 

levels of airborne particulates exceed the federal standard less than five times annually, the state 

standard is set at a lower and more protective level. The valley exceeds the state particulate 

standard an average of 90–100 days per year (www.arb.ca.gov; Trends Summary).

Desired Condition

The desired condition for Air Quality and Visibility in the Greys Project is to meet the purpose 

and need for the Greys Project while accomplishing the Sierra National Forest Land and Resource 

Management Plan (SNF-LRMP) goal to manage Forest activities so air quality is compatible with 

federal, state and local laws, including a program that achieves the Clean Air Act (CAA) 

responsibilities.

Applicable Standards and Guidelines

The SNF LRMP as amended provides the standards and guidelines for the proposed action. It 

states that “Forest activities will be managed so air quality is compatible with federal, state and 

local laws; including a program that achieves the CAA responsibilities” (SNF LRMP 1992, pg. 4-

2). The SNF LRMP has Standards and Guidelines for Air Quality (SNF LRMP 1992, pgs. 4-25) 

that includes the following:

1. Avoid cumulative impacts to air quality by coordinating prescribed burning activities 

within the Forest, with burning activities conducted by others (SNF LRMP 1992 S&G # 

216)
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2. Mitigate fugitive dust impacts on air quality by including dust abatement as a 

requirement for construction activities that have potential to generate dust (SNF LRMP 

1992 S&G # 217).

3. Avoid prolonged effects from prescribed burning activities on air quality by burning only 

on Air Quality Control Board (AQCB) approved burn days when satisfactory wind 

dispersion conditions prevail (SNF LRMP 1992 S&G # 218).

4. Participate with AQCB to qualitatively define air quality control regulations and 

guidelines and effects of air quality on the Forest, from sources outside the Forest (SNF 

LRMP 1992 S&G # 219).

5. Obtain appropriate permits prior to conducting prescribed burning activities (SNF LRMP 

1992 S&G # 220).

6. Incorporate air quality management considerations into fire management (SNF LRMP 

1992 S&G # 230).

Federal Conformity Requirements - The CAA require that all projects receiving federal funds 

must conform to the appropriate State Implementation Plan (SIP). Federal actions are subject to 

either the Transportation Conformity Rule (40 CFR 51[T]), which applies to federal highway or 

transit projects, or the General Conformity Rule (40 CFR 51[W]), which applies to all other 

federal actions. Because the Greys Project is not a federal highway or transit project, it is subject 

to the General Conformity Rule.

General Conformity Rule Requirement - The purpose of the General Conformity Rule is to 

ensure that federal actions conform to applicable SIPs so that they do not interfere with strategies 

employed to attain the National Ambient Air Quality Standards (NAAQS). The rule applies to 

federal actions in areas designated as nonattainment, or in some cases maintenance, for any of the 

six criteria pollutants. The rule applies to all federal actions except:

• Programs specifically included in a transportation plan or program that is found to 

conform under the federal transportation conformity rule.

• Projects with associated emissions below specified de minimus threshold levels.

• Certain other projects that are exempt or presumed to conform.

A general conformity determination would be required if a proposed federal action’s total direct 

and indirect emissions fail to meet one of these two conditions:

• Emissions for each affected pollutant for which the region is classified as a maintenance 

or nonattainment area for the NAAQS are below the de minimus levels indicated in Table 

2.

• Emissions for each affected pollutant for which the region is classified as a maintenance 

or nonattainment area for the NAAQS are regionally insignificant (total emissions are 

less than 10% of the area’s total emissions inventory for that pollutant).

If either of these conditions is met, the requirements for general conformity do not apply because 

the proposed action is presumed to conform to the applicable SIP for each affected pollutant. As a 

result, no further analysis or determination would be required. If neither of these conditions is 

met, a general conformity determination must be performed to demonstrate that total direct and 
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Sierra National Forest – 259 Chapter 3

indirect emissions for each affected pollutant for which the region is classified as a maintenance 

or nonattainment area for the national standards would conform to the applicable SIP.

The Greys Project is within the San Joaquin Valley of Madera County. Currently, the San Joaquin 

Valley is classified by both the federal and state standards as Extreme non-attainment for groundlevel ozone and as serious maintenance status for PM10. The valley is designated as in 

attainment for all other criteria pollutants. (www.valleyair.org). This air basin is considered in 

attainment for all other criteria pollutants.

The Environmental Protection Act (EPA), for determining conformity, has developed de minimus

levels for each of the criteria pollutants based on an air basins attainment status for each pollutant. 

The table below shows these de minimus level thresholds and are bolded based on air basin status. 

Table 50.Federal de minimus Threshold Levels for Criteria Pollutants based on Air Basin 

attainment status.

Pollutant Area Type Tons/Year

8 –Hour Ozone (NOCsx or VOC) Extreme nonattainment (SJV Air Basin, Madera 

county)

10

PM-10 Attainment and Serious maintenance (SJV Air 

Basin, Madera County)

100

Carbon Monoxide, (SO2 and NO2) Unclassified (Madera County) 100

Note: Federal de minimus threshold levels in bold type are those where status is non-attainment or 

maintenance. 

California Clean Air Act - Responsibility for achieving California’s air quality standards, which 

are more stringent than federal standards, is placed on the ARB and local air districts, and is to be 

achieved through district-level air quality management plans that are incorporated into the SIP. In 

California, the EPA has delegated authority to prepare SIPs to the ARB, which in turn has 

delegated that authority to individual air districts.

The ARB has traditionally established state air quality standards, maintaining oversight authority 

in air quality planning, developing programs for reducing emissions from motor vehicles, 

developing air emission inventories, collecting air quality and meteorological data, and approving 

SIPs.

Responsibilities of air districts include overseeing stationary source emissions, approving permits, 

maintaining emissions inventories, maintaining air quality stations, overseeing agricultural 

burning permits, and reviewing air quality–related sections of environmental documents required 

by California Environmental Quality Act (CEQA).

The California Clean Air Act (CCAA) of 1988 substantially added to the authority and 

responsibilities of air districts. The CCAA designates air districts as lead air quality planning 

agencies, requires air districts to prepare air quality plans, and grants air districts authority to 

implement control measures. The CCAA focuses on attainment of the state ambient air quality 

standards, which, for certain pollutants and averaging periods are more stringent than the 

comparable federal standards.
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The CCAA requires designation of attainment and nonattainment areas with respect to state 

ambient air quality standards. The CCAA also requires that local and regional air districts 

expeditiously adopt and prepare an air quality attainment plan if the district violates state air 

quality standards for CO, sulpher dioxide (SO2), NO2, or ozone. These air quality attainment 

plans are specifically designed to attain these standards and must be designed to achieve an 

annual 5% reduction in district-wide emissions of each nonattainment pollutant or its precursors. 

Where an air district is unable to achieve a 5% annual reduction in district-wide emissions of each 

nonattainment pollutant or its precursors, the adoption of “all feasible measures” on an 

expeditious schedule is acceptable as an alternative strategy (Health and Safety Code Section 

40914(b)(2)). No locally prepared attainment plans are required for areas that violate the state 

PM10 standards, but the ARB is currently addressing PM10 attainment issues.

The CCAA requires that the state air quality standards be met as expeditiously as is practicable 

but, unlike the federal CAA, the CCAA does not set precise attainment deadlines. Instead, the 

CCAA establishes increasingly stringent standards for areas that will require more time to achieve 

the standards.

Local Air Districts - Local districts are given the responsibility to develop programs and plans 

for achieving both Federal and State air quality standards and are given the authority to 

implement control measures to reduce emissions of each nonattainment pollutants or its 

precursors. This is implemented through the use of Rules and Regulations.

Smoke Management

In accordance with the California Code of Regulations, Title 17, all persons or entities subject to 

subchapter 2 Smoke Management Guidelines for Agricultural and Prescribed Burning shall 

comply with the requirements therein and those requirements adopted by applicable districts in 

local smoke management regulations. Such persons or entities proposing to conduct prescribed 

burning must submit a Smoke Management Plan (SMP) to the air district of jurisdiction and: 1) 

receive a permit to burn, 2) receive authorization to burn on a given day, and 3) maintain 

communication with the local air district and report on the status of the burn until it is concluded.

San Joaquin Valley Air Pollution Control District - As agreed upon by San Joaquin Valley Air 

District staff and the Southern Sierra Interagency Smoke Management Group, all land managers 

planning to implement prescribed fire treatments will follow the Unified Guidelines and 

Procedures for Smoke Management, which includes the submission of a required Prescribed Fire 

Burn Plan and Smoke Management Summary. The Smoke Management Summary is received 

through the Prescribed Fire Information Reporting System (PFIRS). These are reviewed by 

district personnel and are conditionally approved. Burners are required to register prescribed 

burns prior to the fall burn season and authorization to burn is required prior to ignition based on 

air quality conditions and forecasts. For Prescribed Understory burning, seven days prior to 

ignition a Prescribed Fire Ignition Advisory (PIFA) form must be completed and submitted to 

district meteorology and compliance staff to begin receiving forecast for burn day potential. 

Participation on daily smoke management conference calls for burn project coordination is also 

required on a daily basis prior to and during implementation. On the day of ignition, final 

approval must be received from the compliance officer at the district. Pile burning approval is 

received through the calling the Hazard Reduction Burning phone number on a daily basis. A 

burn fee is applied to the total blackened acres accomplished on a yearly basis. These conditions 

are enforced through Air District Rules and Regulations (Rule 4103, Rule 4106).

Prevention of Significant Deterioration - The Prevention of Significant Deterioration (PSD) 

provisions of the CAA require measures to “preserve, protect and enhance the air quality in 
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national parks, national wilderness areas, national monuments, national seashores, and other areas 

of special national or regional natural, recreation, scenic or historic value.” The most stringent 

requirements for air quality apply to those established as Class I areas. These include 

international parks, national wilderness areas greater than 5,000 acres, national memorial parks 

greater than 5,000 acres, and national parks greater than 5,000 acres, and national parks greater 

than 6,000 acres established prior to August 7, 1977.

There are no Class I airsheds within the project area. However, there are Class I airsheds nearby 

that must be considered and protected. These airsheds are listed in the Table below.

Table 51. Class I airsheds near the Greys Project area.

Class I Airshed Proximity to Project Area

Yosemite National Park Southern Park is located 10 north of project 

area.

Ansel Adams Wilderness Area Western wilderness boundary approximately 10 

miles northeast of project boundary.

Visibility Protection - Visibility is an air-quality related value that is protected in all federal 

Class I areas. Since 1984, states have been required to protect the visibility in national parks and 

wilderness areas, as mandated by the 1977 Clean Air Act Amendments. The 1977 amendments 

established a national goal for the “prevention of any future and the remedying of any existing 

impairment of visibility in mandatory Class I federal areas which impairment results from 

manmade pollution.” The regulations specifically require states to consider strategies for 

reducing visibility impairment from prescribed burning.

Environmental Consequences

Methodology 

For each alternative proposed for the Greys Project, associated emissions are calculated. This is 

used to determine if any alternatives total direct and indirect emissions fail to be (1) below 

Federal de minimus thresholds, in this case thresholds for ozone (precursors NOx and VOC) and 

PM-10, or (2) considered regionally insignificant (less than 10% of the area’s total emissions 

inventory for that particular pollutant). If any alternative’s estimated emissions do not meet either 

of these conditions, a General Conformity Determination must be performed to ascertain how the 

proposed action would conform to the applicable SIP. 

Smoke Emissions Modeling - Four pieces of information are needed to calculate potential 

emissions produced from either wildfire or prescribed fire; acres burned, fuel loading, fuel type 

and type of burning (pile, understory or wildfire) that can determine the amount of fuel 

consumed. The actions proposed by each alternative are used to estimate these as well as 

information within the Fire/Fuels Report-Greys Project. Associated emissions for criteria 

pollutants are derived utilizing an emissions spreadsheet developed and approved for prescribed 

fire emission reporting purposes. This form was developed and built by the Interagency Smoke 

Management Group and SJVAPCD staff from emission formulas from publications (EPA, AP42).

Vegetation Harvesting Equipment Emissions Modeling - Information needed to calculate 

associated emissions produced by vehicular traffic from road work and mechanical treatments 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

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included in Alternatives 2 and 3 (thinning operations, mastication and dozer piling) are; type of 

equipment and the number of hours this equipment is expected to run. The actions proposed by 

each are used to estimate these. Equipment hours are based on average production rates from 

similar projects. Equipment typically used for this type of work includes; heavy duty dieselpowered vehicles (tractor-trailers log trucks), wheeled skidders and loaders, track type 

dozers/masticators, road graders, and smaller gasoline powered engines such as chainsaws. 

Emission factors for criteria pollutants are from “A Desk Reference for National Environmental 

Policy Act (NEPA) Air Quality Analysis” (CH2Hill 1995) and converted to total tons of pollutant.

Fugitive Dust Emissions - The Forest Service routinely requires timber sale operators to abate 

dust during use of the forest development roads. This is required for several reasons among 

which are: retaining road surface fines which help keep the larger supporting aggregate together; 

reduce dust visibility traffic hazards; reduce environmental dust plumes; and minimize loose fine 

material accumulations which can create muddy, road rutting conditions. (Lowe, 1994)

Fugitive (visible) dust emissions (VDE) by general vehicle movement are calculated at 10 pounds 

per day for 5 vehicles per day on unpaved roads. This figure is reduced to 3.63 pounds per day 

per mile of VDE after dust abatement. This is accomplished through watering of roads or other 

dust abatement measures which are incorporated into the project design. Dust abatement is 

required for roads below 3000 feet in elevation in the San Joaquin Valley Air Basin. The Greys 

Project is above 3,000 feet in elevation and is exempt from Regulation VIII, Rule 8011 General 

Requirements (www.valleyair.org), though dust abatements is still required by the Forest Service.

Because of this exemption and the use of abatement measures when they are not a requirement, 

specific calculations for fugitive dust emissions are not used in the analysis of potential emissions 

from this project, but are considered part of the direct, indirect and cumulative effects.

Modeling Used in Analysis - Associated emissions for criteria pollutants are derived utilizing an 

emissions spreadsheet developed and approved for prescribed fire emission reporting purposes. 

This form was developed and built by the Interagency Smoke Management Group and SJVAPCD 

staff from emission formulas from publications (EPA, AP-42).

• Forest Vegetation Simulator with the Fire/Fuels Extension was used to model PM2.5 

emissions to show a comparison between the action and no-action alternatives. PM2.5 

was used as a surrogate for PM10 emissions. FVS models a fire in the year 2022, 10-

years after treatments.

Incomplete and Unavailable Information

Assumptions - This determination assumes that prescribed burning would occur under optimal 

atmospheric conditions for the transport of smoke and pollutants away from the San Joaquin 

Valley as regulated by SJVAPCD. Burning of natural and activity created dead and down woody 

material would occur under Best Available Control Measures (BACMs) for air quality as defined 

in Chapter 2.

Spatial and Temporal Context for Effects Analysis

Past, Present, and Foreseeable Activities Relevant to Cumulative Effects 

Analysis

Past Activities - Air quality in the San Joaquin Valley air basin is among the poorest in the State. 

With the hot, dry summers, the San Joaquin Air Basin, in 2009, experienced 98 days above the 
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federal standard for 8-hour ozone and 122 days above the state standard. Madera County, by 

itself, was above the federal 8-hour ozone standard 13 days and 27 days above the state standard 

(www.arb.ca.gov ; Trends Summary). For PM10 in 2009, the estimated days over the federal 

standard was two, with 123 days estimated over the state standard. For PM2.5 in 2009, the annual 

average days over the federal standard were 23, with 21 days over the state standard 

(www.arb.ca.gov ; Trends Summary).

Present Activities – Mariposa County is considered in nonattainment for both federal and state 

standards for ozone, Madera County is considered in nonattainment for state PM10, PM2.5 and 

ozone standards. The air basin is in federal attainment (maintenance level) for PM10, but is in 

federal nonattainment for PM2.5 and is expecting a reclassification from serious to extreme 

nonattainment for 8-hour ozone.

The BLRD’s prescribed fire program continues to be part of the district program of work. The 

cumulative effect of smoke emissions and degradation of visibility may occur if prescribed burns 

were to continue during stable atmospheric conditions that are present when wildfires occur. For 

this reason, all prescribed fire activities are coordinated with SJVAPCD and would be 

implemented under optimum conditions using best available control measures to prevent smoke 

concentrations from affecting local communities. 

Foreseeable Activities – Foreseeable projects on the BLRD that could contribute to cumulative 

effects include the afore-mentioned district prescribed burn program, the Yosemite National Park 

prescribed fire program, Sugar Pine Adaptive Management, Cedar Valley and Fish Camp 

projects, cattle grazing, special use permits, vegetation management within plantations 

(mastication), hazard tree sales, (OHV) use, and private land management activities.

Projects that could and possibly would contribute to air quality cumulative effects from exhaust 

emissions and/or fugitive dust through vehicle and heavy equipment can be expected from 

mechanical treatment for the Sugar Pine Adaptive Management and Cedar Valley project, 

vegetation management (mastication) within plantations, hazard tree sales, and OHV use. It is 

unknown how much heavy equipment use and vegetation management may occur on private 

property.

Projects that could and possible would contribute to air quality cumulative effects from 

particulate matter PM10 and NOx include Yosemite National Park prescribed fire program, 

BLRD’s prescribed fire program, vegetation treatments through prescribed fire for the Sugar Pine 

Adaptive Management project. It is unknown how much prescribed burning may take place as 

part of the Yosemite National Park burning program. All prescribed burn activities on private 

and public lands follow the same general conformity rules and are governed by the decisions of 

the Mountain Counties APCD, SJVAPCD and the SNF.

In conjunction with the typical period when prescribed burn implementation occurs, is an 

increased use of wood burning stoves and hazard reduction burning by local residences in the 

area. There are restrictions in place on the valley floor (residences below 3000 feet in elevation) 

to limit the use of wood burning stoves during poor dispersion days, but because older residences 

above 3000 feet in elevation typically only have wood burning stoves as their sole source of heat, 

there are little restrictions above 3000 feet elevation. Hazard reduction burning is regulated by a 

permitting process as well as burning only on “affirmative” burn days when meteorological 

conditions are adequate for good dispersion and dilution of pollutants. These affirmative burn 

days are fairly sporadic and can lead to high numbers of residences burning on the same day, 
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especially during weekends. The SJVAPCD has created an educational program for the public on 

how to burn “cleaner” and presented some of the BACMs for hazard reduction burning activities.

Alternative 1 – No Action

No actions would be taken to reduce stand densities to improve ecological restoration and reduce 

the intensity and spread of wildland fires The opportunity would be loss for undertaking 

treatments to reduce the impacts that a wildland fire, starting in hot dry conditions, would cause 

the environment; both the forest environment and the airshed.

Direct Effects

No direct effects from management actions to air quality or visibility would occur under this 

alternative since no treatments would be completed outside of that which is already permitted or 

authorized.

Indirect Effects

The indirect and cumulative effects include the potential for unplanned ignitions and uncontrolled 

wildfires to occur in the area. The resultant smoke caused by these would have large amounts of 

emissions released and could potentially be of long duration. Values measured such as PM10 and 

visibility range used to determine the Health-Protective Value would be in the ranges assumed to 

be Unhealthy. Values associated with this rating are PM10 ranging from 176 to 300 μg/m3 and 

visibility of 1.24 to 2 miles (considered moderate smoke conditions). This would be considered 

the lower of the Health-Protective Values a wildfire would produce, if it occurred in the area. It is 

anticipated that for short periods of time the values may rise to the levels considered Very 

Unhealthy or perhaps Hazardous. The Statewide Emission Inventory in 2002 reported emissions 

(tons/day, annual average) from wildfires (Ahjua 2006) and is demonstrated in Table 52.

Table 52 Statewide Emission Inventory for Natural Sources-Wildfire

Emissions

Total 

Organic 

Gases

Reactive 

Organic 

Gases

Carbon 

Monoxide

Nitrogen 

Oxides

Sulfur 

Oxides PM10

Natural Sources: 

Wildfire 6,522 3,046 17,474 3,441 302 2,418

Total Organic Gases (TOC) and Reactive Organic Gases (ROC) are similar to Volatile Organic 

Gases (VOC) and all are used by the air resources board to describe gases that lead to Ozone 

formation.

The high summer temperatures and light wind speeds that occur during the summer months, 

places a cap on valley air with no means for cleansing itself by dispersion or transport. Because of 

the poor air quality associated with the San Joaquin Valley Air Basin it does not take large 

amounts of additional emissions to degrade air quality into unhealthy ranges especially in the 

summer and fall months, where storm systems are less likely to occur and disperse smog and 

emissions. Emissions from a wildfire could potentially have long lasting impacts beyond the 

initial burning period because of this. Uncontrolled wildfires are clearly responsible for the most 

widespread, prolonged, and severe periods of air quality degradation (Ahuja,. 2006). For 

comparison purposes with the purposed Alternative, Table 53 below demonstrates the emissions 

produced from a wildfire if the acres in the Greys Project were affected by an uncontrolled 

wildfire during typical fire season. 
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Table 53 Potential emissions if a wildfire were to burn within the entire Greys Project 

boundary.

Emissions

Fuel 

Type

Total 

Acres

Fuel 

Loading 

(t/a)

Total 

tons

Tons 

PM10

Tons 

PM2.5

Tons 

NOx

Tons 

SO2

Tons 

VOC

Tons 

CO

Forest 9600 20 192000 2352.00 2112.00 336.00 9.60 1392.00 22368.00

Cumulative Effects

The BLRD underburns approximately 350 acres per year, this program would continue unaffected 

by the alternative chosen. The district’s underburn program covers approximately 25,000 acres. 

None of these are within the project area. The underburns are in ponderosa pine or mixed conifer 

vegetation and most have had at least one entry of prescribed fire. Most of the underburns are 

considered to be in maintenance status and will continue to be burned on a rotational schedule. 

Cumulative effects may also be the occurrence of respiratory or pulmonary distress if a wildland 

fire were to occur in the area while a prescribed fire was being conducted. This would be a rare 

occurrence. Table 54 displays the tons of estimated emissions from the BLRD underburns each 

year. The 53.1 tons of PM10 emissions is the cumulative effect for the underburn program by 

project. It reflects the potential smoke emissions affecting residents of the local communities.

Table 54 Tons of Estimated Pollutants per Individual Project-Annual Underburn Program 

of Work.

Bass Lake Rd Annual 

Under burning (Acres) PM10 PM2.5 NOx SO2 VOC CO

350 53.11 48.08 12.95 .19 33.64 494.38

PM10 = Particulate matter <10 microns in size, PM2.5 = Particulate matter <2.5 microns in size, 

NOX = Nitrous oxide, SO2 = Sulfur dioxide, VOCs = Volatile Organic Compounds, CO = Carbon 

monoxide Past analysis has shown that emissions associated with thinning operations and road use is 

minimal due to contractual dust abatement requirements.

Common to Alternative 2 and 3

Treatments are proposed to reduce surface, ladder fuels and some aerial fuels to meet the purpose 

and need of reducing the intensity and spread of wildland fires as well as reduce stand densities. 

This is to occur, if these alternatives were chosen, through the use of mechanical methods 

(thinning from below and mastication) as well as management ignited fire in the form of 

prescribed fires such as pile burning, understory burning and/or broadcast burning. Prescribed 

fire would be applied to the project area for three purposes: (1) as a final “cleaning” after 

vegetation management treatments to further reduce 1, 10 and 100 hours fuels (those fuels that 

have the greatest influence on fire spread); (2) to maintain the lower levels of the 1, 10, and 100 

hours fuels; (3) to reintroduce the fire element back into a fire dependent ecosystem.

Emissions from smoke produced by prescribed fire implementation are estimated using the 

number of acres to be burned, the surface fuel loading of the area being burned and the amount of 

consumption.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 266 Chapter 3

Within the treatment areas and based on the criteria provided in the Fire/Fuels Design Criteria 

Common to all Alternatives, it is estimated that approximately 3,225 acres could have prescribed 

fire used for maintenance treatment of surface fuels. Of these acreages 774 acres would be piled 

and burned and 1,842 acres would utilize underburning units after pile burning has been achieved. 

There is a total of 609 acres that is proposed to utilize prescribed fire as the primary treatment 

type (RX treatment areas). These areas would require a second prescribed fire entry to achieve 

desired goals to restore and reintroduce fire into the ecosystem. This treatment involves the 

application of prescribed fire over a broad area and would need to have specific conditions prior 

to ignition. It is estimated that, as conditions permit, these types of prescribed fires could take up 

to 10 years to fully implement and would be used, as needed, to maintain surface fuel loadings at 

or below 10 to 20 tons/acre.

Dependent on where and how prescribed fire treatments are being utilized, the fuel loading can 

range from 3 to 30 tons per acre and be in the form of machine or hand created piles and/or in 

concentrations across a broad area such as the case in understory burning. On average the fuel 

loading for an area requiring prescribed fire as a primary treatment, maintenance and/or post 

activity treatment would be 20 tons/acre. 

The main focus of prescribed fire implementation is to reduce surface fuel loadings that 

contribute to fire behavior rates of spread and flame length the greatest. These are the 1, 10 and 

100 hour time lag categories (mainly needles, twigs and branches less than 3 inches in diameter). 

Prescribed fire burn plans set objectives for what percent consumption of these fuels are to be 

accomplished by the implementation of the prescribed fire. For pile burning, burn plan objectives 

typically set the objective at 75 to 80 percent consumption. Pile burning is conducted when the 

fuels have had a period of time to dry and are no longer green. For understory burning, burn plan 

objectives typically set the objectives at 60 to 70 percent consumption (or reduction) of these 

fuels, though this would not be across the entire burn area. A typical understory burn is 

implemented to create a “mosaic” burn pattern, leaving patches of unburned areas amongst 

burned areas.

Alternative 2 – Proposed Action

Associated emissions from mechanical equipment used in masticating, thinning and hauling 

operations and emissions produced from burning are shown in table 7. Hazard fuels treatments, 

including prescribed fire, proposed for this proposed action can be found in Chapter 2 –

Alternatives Considered in Detail of the Greys Environmental Impact Statement

Design Features and Mitigation Measures

The following are BACMs for prescribed fire as required under Section 190 of the Clean Air Act, 

as amended in 1990. The U.S. Environmental Protection Agency developed implementation 

strategies and BACMs for areas that are designated serious non-attainment for particulate matter 

less than 10 microns (PM10) in 1992. Specific techniques to reduce fire emissions include the 

following:

• Employ commonly used reduction techniques such as burning units after harvest 

before new live fuels appear; burning in the springtime prior to “green-up,” burning 

when 1,000-hour fuels (woody debris larger than 3 inches in diameter) moistures are 

high, and burning when the duff is wet (after fall precipitation, or during winter and 

spring).
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 267 Chapter 3

• Employ avoidance techniques such as burning on cloudy days when the plume and 

residual smoke cannot be seen, burning during periods of atmospheric instability for 

better smoke dispersal, and burning during periods of low visitor use.

• Employ techniques to optimize flaming combustion, including burning piled fuels 

rather than broadcast burning, reducing the amount of soil in piles, and employing 

rapid ignition to create a high intensity fire.

• Ensure that all activities conform to the State Implementation Plan (SIP)

• Conduct a full conformity analysis, as required by the Clean Air Act and the SIP to 

assess whether the proposed action produces less than de minimus emissions. (For 

full determination, refer to the Kings River Project Air Determination, available in 

the project record.).

Direct Effects 

Smoke Emissions - This alternative proposes to accomplish up to 3,225 acres of prescribed fire; 

both underburning and pile burning combined. If feasible, there could be the option to dispose 

activity fuels through masticate thus reducing the need of pile burning in some areas. When 

completed, prescribed fire activities proposed under this action would create the following 

emissions.

Table 55 Total Emissions from All Prescribed Fire Treatments Proposed in this Action (in 

tons)

Treatment

Type

Total 

Acres

Tons 

per 

Acre

PM10 PM2.5 NOx SO2 VOC CO

Hand Pile 124 10 15.09 13.64 2.17 0.06 8.99 144.46

Dozer Pile 650 15 38.03 35.59 25.35 .05 30.71 321.75

Underburn 

after pile 

burning 

1842 20 451.29 405.24 64.47 1.84 267.09 4291.86

Underburn 

Only 609 20 149.21 133.98 21.32 0.61 88.31 1418.97

PM10 = Particulate matter <10 microns in size, PM2.5 = Particulate matter <2.5 microns in size, 

NOX = Nitrous oxide, SO2 = Sulfur dioxide, VOCs = Volatile Organic Compounds, CO = Carbon 

monoxide

Vegetation Harvesting Equipment - Equipment hours are based on average production rates 

from similar projects on the BLRD. Most of the material would be thinned by chainsaw and 

skidded. Piling and mastication of activity created slash and brush would be with a track type 

tractor. For this analysis, all emissions are based upon use of wheeled skidders and loaders, 

heavy duty diesel powered highway truck and track type dozer or dozer with mastication head.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 268 Chapter 3

Table 56 Total tons of emissions for mechanical treatments and road maintenancereconstruction activities for the completion of operations in Alternative 2.

Type of Equipment

Total 

Number of 

Hours

PM Exhaust 

Hydrocarbons NOx CO SOx

Wheeled Tractor 1344 0.09 0.13 0.85 2.48 0.06

Wheeled Loader 378 0.01 0.02 0.16 0.04 0.01

Heavy Duty Diesel 

Powered Truck 7404 0.95 0.71 15.42 6.64 1.68

Track Type Tractor 14,000 0.78 0.85 8.82 2.42 0.96

Motor grader 77 0.00 0.00 0.03 0.01 0.00

Total

(Entire Project) 23,203 1.83 1.71 25.28 11.59 2.71

Fugitive Dust Emissions - The Forest Service routinely requires timber sale operators to abate 

dust during use of the forest development roads. This is required for several reasons, including 

retaining road surface fine particles, which helps keep the larger supporting aggregate together; 

reducing dust visibility traffic hazards; reducing environmental dust plumes; and minimizing 

loose fine material accumulations which can create muddy, road rutting conditions (Lowe 1994 as 

cited in USDA Forest Service 2008).

Visible dust emissions (VDE [PM10] by general vehicle movement are calculated at 10 lbs per 

day for 5 vehicles per day on unpaved roads. This figure is reduced to 3.63 pounds per day per 

mile of VDE after dust abatement through watering of roads or other dust abatement measures, 

which are incorporated into the project design features. For the proposed action, 3.63 pounds per 

day x 22 days to haul = 79.86 pounds, which is below de minimus. De minimus is set at 100 

pounds per day for 50 vehicle trips on unpaved roads. Dust abatement is required for roads below 

3,000 feet in elevation. The Greys Project area is above 3,000 feet in elevation and is exempt 

from Regulation VIII, Rule 8011 General Requirements, though dust abatement is still required 

by the Forest Service.

Table 57 Emissions conformity to General Conformity Rule for Criteria Pollutants

Total Emissions

(smoke and equipment)

PM10

175.43

PM2.5

158.74

NOx

44.55

Percent of Areas Total 1.45% 0.5% 0.08%

 Criteria Pollutants are those that determined by EPA to have de minimus levels

Indirect Effects 

The communities of Fish Camp and Bass Lake, state highways, Class I Airsheds, and recreation 

sites are considered smoke sensitive areas. These areas could be affected by smoke if weather 

patterns produce a stable air mass and smoke is unable to vent into the upper atmosphere. Since 

PM10 and ozone are public health hazards, prescribed burns would be planned during periods of 

unstable air, which would allow for proper ventilation of smoke and temperatures less than 95 

degrees. However, since prescribed underburns could last for several days or weeks there is the 

potential for recurring shifts in air masses toward more stable conditions. For this reason, all 

prescribed fire activities are coordinated with SJVAPCD and would be implemented under 

optimum conditions using best available control measures (listed in the Proposed Action) to 

prevent smoke concentrations from affecting local communities. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 269 Chapter 3

Cumulative Effects

Annual trends in ozone and PM air pollution are decreasing largely due to State regulations for 

vehicle emissions. This is expected to continue as technology and regulations to reduce 

emissions are implemented. In addition, mechanical treatments (harvesting) contribution to air 

pollution in particular appears to be on a downward trend likely due to decreased logging activity. 

The incremental effects of Alternative 2 when added to past, present and foreseeable future 

activities, are not likely to influence this trend of reduced logging associated emissions.

From past implementation of prescribed burning on the Bass Lake Ranger District and in 

particular prescribed burns within the vicinity of the Greys Project, mitigations limiting the 

number of acres burned per day, burning during optimal transport wind directions/speeds, higher 

mixing heights and the quantity of other prescribed fires being conducted are considered prior to 

air district final approval to reduce potential impacts to sensitive receptors. This has been 

extended into limiting the number of days burning can occur, and requiring all active ignitions to 

end by late afternoon to reduce smoke production at night time and to limiting the number of 

consecutive days burning can occur to reduce the amount of emissions produced at any one time. 

Close communication with the APCD compliance staff before and during implementation and 

monitoring smoke conditions will aid in determining if there are impacts on sensitive receptors 

and Class I airsheds in the area are beginning and additional mitigations are required.

Cumulative effects can be caused by outside influences not associated with the project itself. 

Because of the rural surroundings, many residences utilize wood burning stoves as their main 

source of home heating. Hazard reduction burning is also permitted in rural communities in 

Madera and Mariposa counties. This can lead to cumulative impacts if prescribed fire is 

conducted on what is considered a marginal dispersal day when added to wood stove smoke and 

increased numbers of hazard reduction burns within the communities in or surrounding the 

project area.

Summary of Effects 

This project meets the General Conformity Rule; it does not interfere with the strategies 

employed to attain NAAQS. The emissions from this project are considered regionally 

insignificant (total emissions are less than 10%) of the area’s total emissions inventory for PM10

and NOx. This conformity is accomplished by maintaining burn ignitions and acres within rules 

and guidelines developed by the SJVAPCD, as provided for by the CARB, under the Unified 

Guidelines for Smoke Management as developed by the Southern Sierra Interagency Smoke 

Management Group. These guidelines and rules are based on the requirements found in the 

following:

Based upon meeting the SIP standards of CARB, the Unified Smoke guidelines discussed above 

and SJVUAPCD rules, the project is determined to be in compliance with SIPs General 

Conformity Rule and Title 17 of the California Code of Regulations. It is important when 

considering the determination that compliance with SIP is based upon meeting rules and 

guidelines managed by SJVUAPCD. These rules and guidelines are designed to meet historical 

emissions levels and keep projects from violating the SIP. The alternatives propose activities that 

will meet the rules and guidelines. Rules and guidelines along with daily SJVUAPCD direction 

control acres and ignitions. Meeting the acres and ignition rules and guidelines meets conformity 

with the SIP emission standards.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 270 Chapter 3

Alternative 3 

Direct Effects 

Alternative 3 would not alter the number of acres where ladder and surface fuels are to be 

reduced through treatments, but would potentially have lower amounts of post activity surface 

fuels (tons/acre). As in Alternative 2, prescribed burning would be utilized to reduce surface fuel 

loading as either an initial treatment (understory/broadcast) or as a post activity treatment (pile 

burning). Mastication and road reconstruction/maintenance would continue with Alternative 3. 

With no commercial thinning operations, emissions from mechanical treatments would be 

reduced significantly from Alternative 2 and would have the potential of reducing the amount of 

acres in which pile burning would be needed reducing the amount of emissions from prescribed 

burning. Understory burning would remain the same as in alternative 2. Thus the direct effects 

of Alternative 3, would be the similar to Alternatives 2, but would be to a lesser degree.

Indirect Effects 

Indirect effects in this alternative are the same to those described in Alternative 2.

Cumulative Effects 

The cumulative effect of this alternative is similar to those under Alternative 2. The changes in 

the diameter limit of thinning among the alternatives alter the amount of trees removed under 

each alternative. These changes alter the amount of emissions that would be generated by 

prescribed fire. The differences in each alternative are represented by the amount of smoke that 

would be produced by a wildfire. 

Summary of Effects 

The incremental effects of smoke, dust and emissions created by the proposed actions in 

Alternative and 3 when added to the past, present and foreseeable future activities are not 

expected to 1) cause or contribute to any new violation of any standard in any area; 2) increase 

the frequency or severity of any existing violation of any standard in any area; or 3) delay timely 

attainment of any standard or any required interim emission reductions or other milestones in any 

area. (CAA Sec 176 (c) (1)) as further defined by San Joaquin Valley APCD Rule 9110-General 

Conformity, §51.853 and is expected to conform to the State Implementation Plan for the 

associated criteria pollutants of NOx, VOC, PM10 and PM2.5. This determination would be in 

compliance with the Sierra National Forest Land and Resource Management Plan’s goals as well 

as meet the Standards and Guidelines written for air quality and visibility.

Effects to Air Quality from proposed changes in treatments

The 128 acreage change from light mechanical thinning to prescribed burning only would not 

significantly alter effects determination to air quality because the associated emissions would 

remain below the de minimus threshold levels.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 271 Chapter 3

Engineering / Transportation __________________

The direct, indirect and cumulative effects to Transportation are summarized from the 

Engineering/Transportation report for the Grey’s Mountain Ecological Restoration Project 

(Hosford A., 2012)

Introduction

Roads within the project area provide needed access for public use of the National Forest and 

access to private lands. Most roads receive low traffic volume but are considered important by 

their users for dispersed recreation experiences of many types. Maintenance level 2 roads are 

generally open to legal OHV use. These roads also provide needed access for Forest Service 

administrative uses including fire suppression, fuels reduction, recreation administration, timber 

harvest, reforestation, and assessment of biological resources.

Reduced funding and road maintenance activities by timber sales have limited opportunities to 

maintain the road system to proper standards. It is estimated that 80% of the road system fails to 

meet current road maintenance standards. 

Regulatory Framework

All road maintenance, reconstruction and new construction would follow the SNF LRMP S&Gs. 

BMPs developed for road maintenance activities would be incorporated into the design of this 

proposed project. 

Existing Condition 

The existing transportation system for the project consists of approximately 77 miles of National 

Forest System Roads (NFSR). The transportation system for the analysis area is complete. 

Small areas may be identified during project planning where a minor amount of new temporary 

road construction is needed. 

Of these 77 miles there are 56.5 miles of NFS native and aggregate surfaced roads and 

approximately 20.5 miles of paved roadway. These native surfaced roads are not suited for wet 

weather use due to erosive soils and lack of armoring. 

Most system roads are in poor condition and are experiencing erosion problems due to limited 

road maintenance, wet weather use, and erosive soils. Many of the local roads have received 

little to no maintenance over the years and would require heavy maintenance and/or 

reconstruction to eliminate resource damage and to meet acceptable standards established in the 

Forest Service Handbook 7709.58.

This relatively low traffic volume road system has received less maintenance in recent years. 

These roads, mostly maintenance level 2, comprise most of the miles of the road system. Many 

of them are brushing in and washing out. The results are negative effects on access and 

environmental resources and loss of the infrastructure investment.

Existing road densities, in general, are acceptable from a wildlife perspective. Any system roads 

or unclassified roads not needed should be decommissioned to enhance wildlife habitat and 

reduce road densities to a more desired level.

There are multiple recorded archeological and historical sites within the project area. A 

preliminary map review of the location of recorded sites and specified roads shows several
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 272 Chapter 3

road/site conflicts. These road/site conflicts are of concern because of the impact of the 

continued use of the roads, the significance of the sites, or the conflicts are not easily mitigated. 

Desired Condition 

Desired conditions for BLRD road management is safety for the traveling public and employees 

and improvement and restoration of roads with resource or access needs.

Environmental Consequences 

Mitigation 

The following road related design activities would be required for the Greys Mountain Ecological 

Restoration project.

#1) Maintain all NFS roads to standards established in the Forest Service Handbook 7709.58. 

Perform road maintenance, reconstruction and new road construction activities to support 

project access needs. Insure drainage structures are functional and stable to prevent potential 

resource damage and degradation of water quality. (S&G #78, #79, #124, #206 and BMPs)

#2) Perform a final field review of project roads to determine reconstruction needs prior to 

project activities. Where economically feasible, place aggregate on existing native surface 

roads located in areas with High and very High Soil Erosion Hazard ratings. (S&G #129) 

#3) Close all temporary roads required for unit access upon completion of use; remove all 

culverts, rip and ditch landings, construct waterbars, block the entrance with a log and dirt 

berm, and disguise the entrance with brush to discourage additional traffic.

Alternative 1 – No Action 

Indirect Effects 

Under the no action alternative, no project activities would take place. Existing road maintenance 

and reconstruction needed to eliminate resource damage and support equipment access would not 

take place. No road reconstruction activities would take place on local roads and no new road 

construction would be needed. The transportation system for the area would not be updated and 

improved by this project to meet current access management direction.

Cumulative Effects

Under Alternative 1, proposed road maintenance and reconstruction needed to mitigate resource 

damage and support equipment access would not take place. The transportation system for the 

area would not be updated and improved by this project to meet current access management. 

This would lead to further degradation of the transportation system and continuing contribution to 

additional resource damage.

Alternative 2 – Proposed Action 

Direct and Indirect Effects 

The project is proposing to perform road maintenance and/or road reconstruction activities on all 

or portions of roads planned road reconstruction and road maintenance activities for the project

would be reviewed by the District Archeologist to develop mitigation requirements for 

archeological /road site conflicts prior to work activities. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 273 Chapter 3

The logging systems plan has identified approximately 0.25 miles of temporary road construction 

for unit access. These roads would be closed upon completion of use. 

Cumulative Effects

Under Alternatives 2 and 3, proposed road maintenance and reconstruction would take place. 

This would mitigate current resource damage, help in mitigating future resource damage and 

improve general access within the project area.

Alternative 3 – Lower and Limited Mid-level Canopy Treatments, All 

Treatment Areas 

Direct and Indirect Effects 

In Alternative 3, treatment areas would remain the same as in Alternative 2. Effects would be the 

same as in Alternative 2 because the alternatives affect the transportation system in identical 

ways.

Compliance with the Forest Plan and Other Regulatory Direction

Road maintenance and reconstruction would be required for identified roads that do not meet 

acceptable standards for the proposed service level and transportation system. This work may 

include installation of culverts, rolling dips, water bars; and aggregate surfacing where soil 

erosion is evident; riprap at outlets of culverts, dips and water bars when needed; and minor 

clearing and widening to a twelve-foot road width for equipment access. NFS Roads used for this 

project would be kept open for public use during sale and post sale activities. Existing landings, 

skid trails, and temporary roads would be used for timber access when available. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 274 Chapter 3

Economics _________________________________

The economics effects are summarized from the Economics report for the Grey’s Mountain 

Ecological Restoration Project (Napier K., 2012)

The Greys Mountain Ecosystem Restoration Project area was selected for treatment based on the 

need for ecosystem restoration in the upper Willow Creek watershed. Restoration activities 

include the use of thinning, mastication, and prescribed fire to reduce stand density and the buildup of hazardous fuels. The area also supports many recreation opportunities on the SNF, 

including special use permits issued by the forest. Treatments are needed to prevent similar 

situations that occurred in the last decade in Arizona and New Mexico and on the San Bernardino 

National Forest, where thousands of acres of trees died from insect mortality due to over-stocked 

conditions, as well as catastrophic wildfires. Fuel reduction and density management treatments 

proposed would: (1) generate saw timber volume, (2) help stimulate the economy through the 

utilization of forest projects, and (3) maintain jobs in the local timber and vegetation management

industries. 

Currently (2011) the Sierra NF is providing timber for three remaining sawmills, Sierra Forest 

Products (SFP), Terra Bella, CA, and Sierra Pacific Industries (SPI), at Chinese Camp, CA, and 

at Standard, CA. The SFP mill is the last remaining sawmill in California south of Yosemite 

National Park. This mill also operates a wood-fired electrical power plant co-located with its 

mill, which utilizes a portion of its lumber manufacturing waste product. Lumber manufacturing 

waste products are also utilized in several other markets including landscaping. SFP is a 

qualifying Small Business and SPI is a Large Business in computations for Small Business 

Administration market share monitoring purposes. SFP is approximately 80% dependent upon 

raw material from Federal Lands. Conversely, the Sierra, and Sequoia National Forests are 

almost 100% dependent upon the SFP milling infrastructure to process and give value to excess 

tree inventories in the woods when considering fuels and fire management, forest health 

maintenance, and wildlife habitat restoration. In order to implement the types of projects 

considered in this analysis, an economically viable infrastructure is necessary now and into the 

future. Maintenance of such an infrastructure is voiced as a concern by some segments of the 

public.

Local sawmills are in dire need of forest products to keep them open and their employees 

employed. If these mills close, the ability to utilize forest products in the future and offset 

treatment cost will be lost. The district finds that at the present, the cost of the proposed 

treatment is higher than the value of the saw timber and will require appropriated funds to fulfill 

the objectives. Treatments prescribed were developed with regard to those activities necessary to 

reduce the intensity and spread of wildfire and reduce stand density, not to provide positive 

economic returns. An economic analysis is required to comply with NEPA guidelines and can 

generally be helpful in selecting an alternative by showing comparative costs and\or revenues 

between alternatives. However, economics will not be a deciding factor for selecting any action 

alternative for the Greys Mountain Ecosystem Restoration Project. Instead, alternative selection 

will be based on the alternative that best accomplishes the purpose and need of the project. This 

economic analysis will give the public an approximate comparison of costs between alternatives.

The economic analysis for the Greys Mountain Ecosystem Restoration Project is divided into 

three sections. The first section is the net value of harvested saw timber taking into account the 

value of the saw timber minus the stump to mill cost. The second section is the cost of other 

prescribed treatments within the project area that address non-commercial vegetation treatments. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 275 Chapter 3

The final section is an analysis of employment benefits both directly and indirectly based on the 

relationship between employment and harvesting. Besides the above described cost and benefits, 

other fixed costs are associated with the proposal. The cost of producing the environmental 

document is approximately $95,000. Prior to project implementation there are project preparation 

costs of $11.80/ccf. During project implementation there are contract administration costs of 

$10.80/ccf.

Table 58 and Table 59 display the comparison of both action alternatives for product value, 

implementation costs, and employment benefits. Both action alternatives would require 

appropriated dollars to complete the work. Alternative 2 would require less appropriated dollars 

to complete the work at a cost of $339,502. Alternative 3 would require $612,321 more in 

appropriated funds than Alternative 2 to complete work. The employment benefits for Alternative 

2 would be approximately $4,264,784 more than Alternative 3. The economic costs for 

Alternative 3 are higher overall to implement and it would not treat the 1,566 acres for density 

management, providing improved stand vigor and creating a more resilient forest to density 

induced mortality. Biomass operations would cost approximately $64,107.68 for both action 

alternatives, with a value of $111 total. This figure would not change between alternatives 2 and 3 

as any unmerchantable timber (less than 10” diameter) would be removed.

Fire and fuel objective treatments in the project area would reduce fire hazard and provide public 

benefit. Measurement of this benefit is outlined in the paper Investment in Fuel Removals to 

Avoid Forest Fires Result in Substantial Benefits (Mason et al, 2006). For both action 

alternatives, fire risk would be reduced in units proposed for commercial thinning (1,566 acres) 

and those treatment areas where hand thinning/tractor pile/burn pile, mastication, and under burn 

take place outside of Alternative 2 cut units. The fire reduction benefit could be as much as 

$1,678,014 in either action alternative.

This analysis compares the project value based on product value, implementation cost, and 

employment benefits for the action alternatives. The no action alternative does not have any 

product value or implementation costs, but has the cost of producing the environmental document 

and the benefit of providing Forest Service employment. The no action alternative is neutral in 

respect to this analysis because its cost equals its benefit. 

The employment benefit of implementing product removal and fuel reduction treatments is an 

important aspect in project economics. Whenever you have a project that puts people to work 

and provides a product to the free market, there are societal benefits derived. Woods workers, 

truck drivers, and mill workers are directly employed and the taxes they pay benefit both Federal 

and State Government. Yield taxes are collected from Purchasers upon cutting saw timber and 

are paid to the State. Processed materials from mills eventually reach retail stores and provide 

jobs for retail workers and income and sales tax to Federal and State Government. These societal 

benefits are a by-product of the prescribed treatments designed to meet the purpose and need of 

this project. When greater amounts of forest products are removed from a project, more societal 

benefits are realized. Alternative 2 would provide the greatest societal benefits. Generally, for 

each million board feet of product removal, approximately 13.2 jobs are supported both directly 

and indirectly. This ratio can range from 9 jobs to 28 jobs depending on location and the type of 

products removed. In addition to product removal, other vegetation treatments in the project area 

help support the local economy. Table 60 displays the anticipated number of full time jobs 

supported by vegetation treatments other than product removal.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 276 Chapter 3

Table 58. Greys Mountain economic analysis for alternative 2

Value - Sawtimber1

Total Acres = 1566

% by 

Species 

Volume

Volume/Species Advertised 

Rates Total Value

PP 10 inch - 29.9 inch 

sawtimber 16%

2,386 ccf x $134.79 /ccf $321,609 

1,281 mbf [250.98/mbf]

SP 10 inch - 29.9 inch 

sawtimber 12%

1,842 ccf x $143.65 /ccf $264,603 

989 mbf [267.55/mbf]

WF 10 inch - 29.9 inch 

sawtimber 37%

5,583 ccf x $178.11 /ccf $994,388 

2,998 mbf [331.69/mbf]

IC 10 inch - 29.9 inch 

sawtimber 34%

5,219 ccf x $259.56 /ccf $1,354,644 

2,803 mbf [483.28/mbf]

LP 10 inch - 29.9 inch 

sawtimber 1%

154 ccf x $150.37 /ccf $23,157 

82 mbf [282.40/mbf]

Biomass 442.0 ccf x $0.25 /ccf $111 

Total Value 15,184 ccf (8,153 mbf) $2,958,401 

Conversion Factor for 

ccf to mbf: 

0.5370

Stump to Mill Cost 

Stump to truck Cost 15184 ccf @ $60.83 /ccf $923,643 

Other Cost 15184 ccf @ $3.92 /ccf $59,521 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 277 Chapter 3

Road Reconstruction Cost 15184 ccf @ $8.76 /ccf $133,012 

Road Maintenance Cost 15184 ccf @ $2.96 /ccf $44,945 

Temp Road Cost 15184 ccf @ $0.12 /ccf $1,822 

Haul Cost 15184 ccf @ $80.58 /ccf $1,223,527 

Sawtimber Scale 1898 trips @ $1.60 /trip $3,037 

Biomass

442 ccf tons @ $145.04 /ccf

$64,107.68 2211 tons @ $28.99 ton

Advertise Rate Sawtimber 15184 ccf @ $2.86 /ccf ($43,426)

Total Other Cost $2,410,188 

Net Value $548,213 

Forest Service Agency Responsibility

Full-time 

jobs3

Mastication 318 acres x $545 /acre 1 $173,310 

Hand/T Units Thin 124 acres x $170 /acre 4 $21,080 

Hand Units Pile 124 acres x $900 /acre 4 $111,600 

Hand Units Burn Piles 124 acres x $75 /acre 2 $9,300 

Tractor Pile 325 acres x $280 /acre 1 $91,000 

Underburn T units 1855 acres x $150 /acre 1 $278,250 

Underburn Rx units 596 acres x $300 /acre 1 $178,800 

Burn Tractor Piles 325 acres x $75 /acre 2 $24,375 

16 jobs

Total Non Harvest Cost $887,715 

Total Project Value ($339,502)

Fire Reduction Benefits2 $606 /acre 2769 acres $1,678,014 

Harvest Employment3 108 jobs

Total Full Time Jobs 124

Total Employee-Related Income $4,944,784 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 278 Chapter 3

Table 59. Greys Mountain economic analysis for alternative 3

Value - Sawtimber1

Total Acres = 2769

% by 

Species 

Volume

Volume/Species Advertised 

Rates Total Value

PP 10 inch - 29.9 inch 

sawtimber 0%

0 ccf x /ccf $0 

0 mbf

SP 10 inch - 29.9 inch 

sawtimber 0%

0 ccf x /ccf $0 

0 mbf

WF 10 inch - 29.9 inch 

sawtimber 0%

0 ccf x /ccf $0 

0 mbf

IC 10 inch - 29.9 inch 

sawtimber 0%

0 ccf x /ccf $0 

0 mbf

LP 10 inch - 29.9 inch 

sawtimber 0%

0 ccf x /ccf $0 

0 mbf

Biomass 442.0 ccf x $0.25 /ccf $111 

Total Value 0 ccf $0 

Stump to Mill Cost 

Stump to truck Cost 0 ccf @ /ccf $0 

Other Cost 0 ccf @ /ccf $0 

Road Reconstruction Cost 0 ccf @ /ccf $0 

Road Maintenance Cost 0 ccf @ /ccf $0 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 279 Chapter 3

Temp Road Cost 0 ccf @ /ccf $0 

Haul Cost 0 ccf @ /ccf $0 

Sawtimber Scale 0 trips @ /trip $0 

Biomass

442 ccf 

tons @ $145.04 /ccf

$64,107.68

2211 tons @ $28.99 ton

Advertised Rate Sawtimber 0 ccf @ /ccf $0 

Total Other Cost $64,108 

Net Value ($64,108)

Forest Service Agency Responsibility

Full-time 

Jobs3

Mastication 318 acres x $545 /acre 1 $173,310 

Hand/T Units Thin 124 acres x $170 /acre 4 $21,080 

Hand Units Pile 124 acres x $900 /acre 4 $111,600 

Hand Units Burn Piles 124 acres x $75 /acre 2 $9,300 

Tractor Pile 325 acres x $280 /acre 1 $91,000 

Underburn T units 1855 acres x $150 /acre 1 $278,250 

Underburn Rx units 596 acres x $300 /acre 2 $178,800 

Burn Tractor Piles 325 acres x $75 /acre 2 $24,375 

17 jobs

Total Non Harvest Cost $887,715 

Total Project Value ($951,823)

Fire Reduction Benefits2 $606 /acre 2769 acres $1,678,014 

Harvest Employment3 0 jobs

Total Full Time Jobs 17

Total Employee-Related Income $680,000 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 280 Chapter 3

1

Quality Value from R5 Transactional Evidence Appraisal Spreadsheet

2

C. Larry Mason et al. Jan/Feb 2006. Investment in Fuel Removals to Avoid Forest Fires Result in 

Substantial Benefits. Journal of Forestry:27-31 (total of firefighting cost avoided and timber loss avoided)

3

Based on historical relationships between employment and harvest in the Pacific Northwest, each million board feet

harvested supports 13 jobs. The number of jobs created fluctuates with different studies, some ranging from as few as 9

to as many as 28. The Leppke and Mason report from November 2005 reports direct forest industry employment.

Estimates depend on type of harvest and degree of manufacturing in a given area. Jobs are also created in forestry 

operations, logging, hauling, processing, or renewable energy. Indirect jobs are also created through local expenditures

by workers, support services within community, or government services.

Lippke, Bruce; Mason, Larry. Nov. 2005. Implications of Working Forest Impacts on Jobs and Local Economies 

 Discussion Paper

The restoration and fuel work would support additional direct and indirect employment.

Table 60. Full time Job relationship to specific project tasks

Task # of 

Workers

Production Acres of 

Treatment

Direct full 

time jobs

Indirect full 

time jobs

Total Full time 

Jobs

Mastication 2 4 ac./day 318 0.6 0.9 1

Hand/T Units Thin 1 1 ac./day 124 0.5 0.7 1

Hand Units Pile 2 2 ac./day 124 0.5 0.7 1

Hand Units Burn Piles 7 5 ac./day 124 0.7 1.0 2

Tractor Pile 2 5 ac./day 325 0.5 0.7 1

Underburn T Units 10 30 ac./day 1855 2.4 3.4 6

Underburn Rx units 10 30 ac./day 596 0.8 1.1 2

Burn Tractor Piles 7 15 ac./day 325 0.6 0.8 1
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 281 Chapter 3

Short-term Uses and Long-term Productivity ____

NEPA requires consideration of “the relationship between short-term uses of man’s environment 

and the maintenance and enhancement of long-term productivity” (40 CFR 1502.16). As declared 

by the Congress, this includes using all practicable means and measures, including financial and 

technical assistance, in a manner calculated to foster and promote the general welfare, to create 

and maintain conditions under which man and nature can exist in productive harmony, and fulfill 

the social, economic, and other requirements of present and future generations of Americans

(NEPA Section 101).

Maintenance and enhancement of long-term productivity is accomplished through restoration 

treatments that reduce basal area and number of stems (stand density) in over crowed stands. 

Stands that exist presently are no longer sustainable or resilient to changing environmental 

conditions that can and are occurring now and into the future. Drought induced stress, insect or 

disease attacks and wildfire all can have detrimental effects on the forest of today. Short-term 

activities described in the action alternatives are intended to lead to the enhancement of long-term 

productivity by beginning to restore forest conditions that resilient to disturbances.

Actions described in Chapter 1 lead to enhancement of long-term productivity, especially:

 The need to increase the proportion of large trees across a landscape, 

 The need to increase the proportion of fire resistant species such as pines,

 The need to reduce wildfire intensity and spread across the landscape, and 

 The need to reduce stand density.

Unavoidable Adverse Effects__________________

No unavoidable adverse effects would occur in the project area.

Irreversible and Irretrievable Commitments of 

Resources _________________________________

Irreversible commitments of resources are those that cannot be regained, such as the extinction of 

a species or the removal of mined ore. Irretrievable commitments are those that are lost for a 

period of time such as the temporary loss of timber productivity in forested areas that are kept 

clear for use as a power line rights-of-way or road. 

Approximately 0.25 miles of temporary road construction is proposed for the project. Road 

construction results in removal of surface soils and subsoil and complete loss of soil productivity 

within the road prism. 

The 0.25 miles of road is approximately 0.45 acres of ground with total loss of soil productivity. 

The direct effect of this new road construction is irreversible and irretrievable. Erosion on newly 

constructed roads is usually higher immediately after the road is constructed. There is potential 

that accelerated erosion could occur off the road prism and reduce soil productivity off site and 

after the road is constructed. Applicable soil and water conservation BMPs would be 

implemented, including erosion control measures, such as water bars, straw mulching of fills and 

fertilization of soils to re-vegetate the bare soils. Road reconstruction and road maintenance 

operate within the road prism and have little effect to the soil resource. However, there can be a 

positive effect to the soil resource outside of the road prism from road reconstruction by restoring 

proper drainage features of the road. Restoration of drainage features would result in less surface 

erosion and soil loss that leads to loss in soil productivity.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 282 Chapter 3

Legal and Regulatory Compliance _____________

NEPA at 40 CFR 1502.25(a) directs “to the fullest extent possible, agencies would prepare draft 

environmental impact statements concurrently with and integrated with ...other environmental 

review laws and executive orders.” The proposed action and alternatives must comply with the 

following regulation.

Principle Environmental Laws 

The following laws contain requirements for protection of the environment that apply to the 

proposed action and alternatives.

Endangered Species Act 

The Forest Service is directed to comply with this Act and does so through Biological 

Assessments and Evaluations that are used to analyze the effects of the proposed alternatives. 

These assessments and evaluations make determinations on Federally-listed endangered, 

threatened, candidate and proposed species and their habitat. The analysis was conducted in part 

to determine whether formal consultation or conference is required with the USFWS, pursuant to 

this act.

The project, through the inclusion of design criteria established for all action alternatives for 

species covered under this Act as well as the completion of BE/BAs for Botanical, Aquatic and 

Terrestrial species, is in compliance with this act. 

Clean Water Act

The project would comply with this Act by adoption of Best Management Practices and other 

design criteria established for all action alternatives as detailed in Chapter 2. 

Clean Air Act

Under the General Conformity Rule the project has been determined to comply with this Act and 

the California SIP through the implementation of treatments following Best Available Control 

Measures BACMs for prescribed burning as well as Rules and Regulations established by the 

SJAPCD and Mountain Counties APCD as required under section 190 of this Act, as amended in 

1990. 

National Historic Preservation Act (NHPA)

The USDA Forest Service is directed to identify, evaluate, treat, protect, and manage historic 

properties by several laws. However, the NHPA of 1966, as amended (16 U.S.C. 470 et seq.) 

provides comprehensive direction to Federal agencies about their historic preservation 

responsibilities. 

Section 106 of the NHPA and the ACHP implementing regulations, Protection of Historic 

Properties (36 CFR Part 800), require that Federal agencies take into account the effect of their 

undertakings on historic properties, and that agencies provide the ACHP with an opportunity to 

comment on those undertakings. Programmatic agreements (36 CFR 800.14(b)) provide 

alternative procedures for complying with 36 CFR 800. Pacific Southwest Region 5, USDA 

Forest Service has such an agreement: Programmatic Agreement among the U.S.D.A. Forest 

Service, Pacific Southwest Region, California State historic Preservation Officer, and Advisory 

Council on Historic Preservation Regarding The Identification, Evaluation and Treatment of 

Historic Properties Managed by the National Forest of the Sierra Nevada, California (Sierran 

PA). This agreement provides specific standards for conducting cultural resources inventory, 

evaluation, and management, including Forest Heritage Program requirements, identification 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 283 Chapter 3

standards, standard procedures for protecting cultural resources, reporting and public 

participation.

Cultural resource design criteria are established for all action alternatives and are based on 

stipulations within the Sierran PA. All alternatives would be in compliance with historic 

preservation law, policy and regulation, as this project meets the stipulations of the Sierran PA.

National Forest Management Act (NFMA)

The NFMA (16 U.S.C. 1604) and the Multiple-Use Sustained-Yield Act of 1960 (16 U.S.C. 528–

531) gives direction to National Forests to develop National Forest Land and Resource 

Management Plans that (A) insure consideration of the economic and environmental aspects of 

various systems of renewable resource management, including the related systems of silviculture 

and protection of forest resources, to provide for outdoor recreation (including wilderness), range, 

timber, watershed, wildlife, and fish; (B) provide for diversity of plant and animal communities 

based on the suitability and capability of the specific land area in order to meet overall multipleuse objectives, and for steps to be taken to preserve the diversity of tree species. As set forth by 

these Acts, the SNF LRMP, as amended by the SNFPA in 2004, set specific S&Gs which are to 

be followed during project level planning and implementation.

By the inclusion of design criteria as part of all action alternatives to minimize or eliminate 

significant environmental effects from proposed management actions as well as the inclusion of 

S&Gs from the SNF-LRMP and SNFPA ROD (USDA-FS 2004b) used to design this project, this 

project would comply with this act.

Soil Productivity 

Soil resource management is achieved by maintaining soil productivity using Regional Soil 

Quality Standard and Guidelines and management direction provided in the LRMP (USDA-FS 

1992). The Geology/Soils section, in Chapter 3, analyzes the existing soil productivity and effects 

of alternatives on soil productivity. 

Management Indicator Species (MIS)

The bioregional scale monitoring strategy for the SNF MIS is found in the Sierra Nevada Forests 

Management Indicator Species Amendment (SNF MIS Amendment) Record of Decision (ROD) 

of 2007. Bioregional scale habitat monitoring is identified for all twelve of the terrestrial MIS. In 

addition, bioregional scale population monitoring, in the form of distribution population 

monitoring, is identified for all of the terrestrial MIS except for the greater sage-grouse. For 

aquatic macro invertebrates, the bioregional scale monitoring identified is Index of Biological 

Integrity and Habitat. The current bioregional status and trend of populations and/or habitat for 

each of the MIS is discussed in the Sierra Nevada Forests Bioregional Management Indicator 

Species (SNF Bioregional MIS) Report (USDA-FS 2008).

Other S&Gs, especially those dealing with Water Quality

BMPs would be applied to all action alternatives and are listed in Appendix B of this document. 

Design criteria listed in Chapter 2 incorporate additional protection measures to minimize and/or 

eliminate impacts to water quality. 

Executive Orders 

The following executive orders provide direction to Federal agencies that apply to the proposed 

action and alternatives:

Indian Sacred Sites, Executive Order 13007 of May 24, 1996, applies to the proposed action 

alternatives because of historic and prehistoric uses known in the area. This is specifically 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 284 Chapter 3

addressed in Chapter 3 under Heritage Resources and Tribal Relations. All project alternatives 

comply with this order.

Protection and Enhancement of the Cultural Environment, Executive Order 11593 of May 

13, 1971, directs Federal agencies to inventory cultural resources under their jurisdiction, to 

nominate to the National Register of Historic Places all Federally owned properties that meet the 

criteria, to use due caution until the inventory and nomination processes are completed, and to 

assure that Federal plans and programs contribute to preservation and enhancement of nonFederally owned properties. 

Cultural resource design criteria are established for all action alternatives and are based on 

stipulations within the Sierran PA. All alternatives would be in compliance with historic 

preservation law, policy and regulation, as this project meets the stipulations of the Sierran PA.

Invasive Species, Executive Order 13112 of February 3, 1999, applies to the proposed action 

alternatives. A risk of introducing invasive species does exist. Measures need to be in place to 

prevent the spread of these species. The proposed action alternatives comply by providing 

measures to prevent the introduction and spread of invasive species.

Recreational Fisheries, Executive Order 12962 of June 6, 1995, applies to the proposed action 

alternatives. Action alternatives comply with this order by implementing Best Management 

Practices and other design criteria and correcting existing resource problems. These design 

criteria are detailed in Chapter 2 and the list of specific Best Management Practices associated 

with this project are included in Appendix B of this document. 

Migratory Birds, Executive Order 13186 of January 10, 2001. Under the National Forest 

Management Act (NFMA), the Forest Service is directed to “provide for diversity of plant and 

animal communities based on the suitability and capability of the specific land area in order to 

meet overall multiple-use objectives (P.L. 94-588, Sec 6 (g) (3) (B)).” The January 2000 USDA 

Forest Service (FS) Landbird Conservation Strategic Plan, followed by Executive Order 13186 in 

2001, in addition to the Partners in Flight (PIF) specific habitat Conservation Plans for birds and 

the January 2004 PIF North American Landbird Conservation Plan all reference goals and 

objectives for integrating bird conservation into forest management and planning.

In late 2008, a Memorandum of Understanding (MOU) between the USDA Forest Service

and the USFWS to Promote the Conservation of Migratory Birds was signed. The intent of 

the MOU is to strengthen migratory bird conservation through enhanced collaboration and 

cooperation between the Forest Service and the USFWS as well as other Federal, State, tribal 

and local governments. Within the National Forests, conservation of migratory birds focuses 

on providing a diversity of habitat conditions at multiple spatial scales and ensuring that bird 

conservation is addressed when planning for land management activities. 

The SNF is proposing to manage lands on the BLRD that are located in the Willow Creek and 

Fresno River watersheds. Proposed management is intended to implement direction contained 

within the SNF-LRMP (LRMP, USDA-FS 1992) as amended by the SNFPA ROD (USDA-FS 

2004b). Opportunities to promote conservation of migratory birds and their habitats in the project 

area were considered during development and design of the project (MOU Section C: items 1 and 

11 and Section D: items 1 and 3). 

Within this project area special considerations have been given to maintaining higher levels of 

biodiversity through actions such as delineating OFLs surrounding perennial streams (see DEIS 

and BE/BA for a description of OFLs). Higher levels of biodiversity and heterogeneity have also 

been planned for by marking retention groups of large diameter trees. These tree groups are 

composed of a cluster of three or more trees, 30-inch dbh or greater, with touching crowns, and 

would benefit those species which utilize dense groupings of large trees. Another project design 

measure which would maintain biodiversity is the identification of retention areas around large 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 285 Chapter 3

oaks within treatment units. Two to three large oaks per acre were identified and marked with 

paint. These oaks would retain a zone of no activity measuring 35 feet, or dripline circumference 

around the oak (whichever is greater). The delineation of OFLs, retention of large tree groups, 

and oak no treatment zones would ensure a heterogeneous post treatment landscape resulting in 

the continued accessibility of both hiding cover and prey availability within these areas of 

biodiversity. 

Likely impacts to habitats and select migratory bird populations resulting from the Greys 

Mountain Project have been assessed in detail within the project MIS report and impacts to select 

TES birds and their habitats have been analyzed in the project BA and/or BE. 

The project would not adversely impact migratory landbird species or their associated habitats. 

Potential impacts to migratory species would be minimized through the adherence of LRMP 

S&Gs as well as Design Criteria common to All Action Alternatives. These define the retention 

levels for snags/down woody debris, activities occurring within riparian management areas which 

include SMZs, OFLs, how to minimize ground disturbance and maintenance of canopy cover. 

The project is designed to improve habitat conditions through the acceleration of latesuccessional habitat characteristics, while still maintaining current functional habitat. Specific 

project design criteria include: canopy cover would be maintained at 50 to 60% or greater where 

available; ground disturbance would be limited to those guidelines with the LRMP as amended; 

vegetation species diversity and composition would be maintained; management activities would

be limited in designated riparian management areas; and retention of snags and downed logs 

would be retained at levels defined in the Design Criteria Common to All Action Alternatives. 

All riparian management areas within the project have been identified and buffers established. In 

addition, no operations would occur during the wet weather season. 

Floodplain Management, Executive Order 11988 of May 24, 1977, does not apply because of 

exclusions and buffers that are in place through design criteria for the action alternatives and are 

found in detail in Chapter 2.

Protection of Wetlands, Executive Order 11990 of May 24, 1977, does not apply because of 

exclusions and buffers that are in place through design criteria for the action alternatives and are 

found in detail in Chapter 2.

Environmental Justice, Executive Order 12898 of February 11, 1994, applies to the proposed 

action alternatives. Compliance has been attempted by making this document understandable and 

accessible.

Use of Off-Road Vehicles, Executive Order 11644, February 8, 1972, does not apply to this 

proposal. No off road use is being proposed nor existing use changed in this document.

Special Area Designations

The selected alternative would need to comply with laws, regulations and policies that pertain to 

the following special areas.

Research Natural Areas

No research natural areas are located in the project area. This project would comply with 

applicable laws, regulations and policies for research natural areas.

Inventoried Roadless Areas

No Inventoried Roadless Areas are located in the project area. This project would comply with 

applicable laws, regulations and policies for Inventoried Roadless Areas.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 286 Chapter 3

Wilderness Areas

No Congressionally-designated wilderness areas are located in the project area. This project 

would comply with applicable laws, regulations and policies for wilderness areas.

Wild and Scenic Rivers

No Congressionally-designated wild and scenic rivers occur in the project planning area.

Municipal Watersheds (FSM 2540)

No municipal watersheds occur in the project planning area.

Other Required Disclosures

NEPA at 40 CFR 1502.25(a) directs “to the fullest extent possible, agencies shall prepare draft 

environmental impact statements concurrently with and integrated with...other environmental 

review laws and executive orders.”

Species surveys, review of recent literature, and professional judgment have been incorporated 

into determinations of possible effects on species. Surveys provide information on species 

presence and habitat on a local scale. An element of uncertainty exists for effects on species with 

distributions beyond the project or Sierra N.F. boundaries. The Pacific fisher and YT are Forest 

Service sensitive species that have also been designated by the USFWS as candidate species for 

listing under the ESA. A candidate species is determined by the USFWS Service through a 12-

month finding as warranted for listing. The listing process is precluded by other priorities. The 

Sierra N.F. requested and received technical advice from the USFWS to address uncertainty 

related to these candidate species. Their advice is integrated extensively throughout the 

Terrestrial and Aquatic Species sections of Chapter 3 as well as in the design criteria for all action 

alternatives.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 287 Chapter 4

Chapter 4. Consultation and Coordination

Preparers and Contributors __________________

The Forest Service consulted the following individuals, Federal, State, and local agencies, tribes 

and non-Forest Service persons during the development of this environmental document:

ID Team Members

Burt Stalter, District Fuels Specialist; Interdisciplinary (ID) Team Leader

Gloria Smith, District Fuels Specialist; Fire/Fuels Analysis, Core Team Member

David Smith, District Silviculturist/California State Registered Professional Forester; 

Vegetation/Silvicultural Analysis; Core Team Member

Anae Otto, District Wildlife Biologist-Terrestrial; Biological Assessment/Biological Evaluation 

for Terrestrial Wildlife; Core Team Member

Katherine Napier, Forester; Data Collection/Economic Analysis; Core Team Member

Denise Tolmie, Forest Fuels Officer; 

Phillip Strand, Fisheries Biologist; Aquatics-Riparian Analysis; ID Team Member

Keith A. Stone, Hydrologist; Hydrology Analysis; ID Team Member

Joanna Clines, Forest Botanist; Botanical Biological Assessment/Biological Evaluation/Noxious 

Weed/Invasive Species Analysis; ID Team Member

Erin Potter/Marie Mogge, District Archeologist; Archeology Analysis; ID Team Member

Andy Hosford, District Engineer; Transportation Analysis; ID Team Member

Alan Gallegos/Kellen Takenaka, Soils; /Soils Analysis; ID Team Member

Karen Nooney, District Lands/Special Uses; Special Uses Analysis; ID Team Member

Linda McPhail, Recreation Specialist; ID Team Member

Judi Tapia, NEPA Coordinator and Technical Reviewer

Federal, State, and Local Agencies

Although no formal or informal consultation was required for this project, personnel 

communications with Federal, State and Local Agencies including, but not limited to; USFWS, 

California Department Fish and Game, and Cal-Fire. 

Tribes

North Fork Mono Rancheria; Picayune Rancheria of the Chukchansi Indians; Mariposa Indian 

Council; Mono Nation; California Indian Basketweavers Association.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 288 Chapter 4

Distribution of the Environmental Impact 

Statement _________________________________

This draft environmental impact statement has been distributed to individuals who specifically 

requested a copy of the document. In addition, copies have been sent to the following Federal 

agencies, Federally-recognized tribes, State and local governments, and organizations: 

 Advisory Panel on Historic Preservation

 USDA-Animal and Plant Health Inspection Service

 USDA-Natural Resources Conservation Service

 USDA-National Agricultural Library

 National Oceanic and Atmospheric Administration

 National Marine Fisheries Service

 South Pacific Division-US Army Engineer

 Region 9-Environmental Protection Agency

 US Department of the Interior

 US Coast Guard

 Western Pacific Region-Federal Aviation Administration

 US Department of Energy

 Federal Highway Administration

 USFWS

 California Department of Fish and Game

 North Fork Mono Rancheria

 Picayune Rancheria of the Chukchansi Indians

 Mono Nation

 Madera County Board of Supervisors

 San Joaquin Valley Air Pollution Control District

 High Sierra Chapter of Society of American Foresters

 Eastern Madera Fire Safe Council

 Coarsegold Resource Conservation District

 Sierra Forest Legacy

 National Chapter and Tehipite Chapter-Sierra Club

 ,John Muir Project

 California Indian Basketweavers Association

 Regional Water Quality Control Board

 Willow Creek Collaborative
Sierra National Forest – 289 Glossary

Glossary

Adaptive Management: A type of natural resource management that implies making decisions 

as part of an on-going process. Monitoring the results of actions provides information that may 

indicate the need to change a course of action. Scientific findings and the needs of society may 

also indicate the need to adapt resource management to new information.

Aggregation: The smallest homogeneous unit recognized when describing vegetation. Different 

management is required than surrounding vegetation. Due to its small size, it is not a mapping or 

record keeping unit. Several aggregations can make up a stand.

Air Shed: A geographical area that shares the same air mass due to topography, meteorology, 

and climate.

Analysis Area: A collection of land area, not necessarily contiguous, sufficiently similar in 

character that they can be treated as if they were identical.

Aspect: A position facing a particular direction, usually expressed as a compass direction in 

degrees or cardinal directions.

Bark Beetle: A member of the family Scolytidae (Coleoptera). Adults and larvae tunnel in the 

cambial region (either in the bark only or in the bark and xylem) of living, dying and recently 

dead or felled trees and utilize these areas for food and shelter.

Basal Area: The area of the cross section of a tree trunk near its base, usually 41⁄2 feet above the 

ground. Basal area is a way to measure how much of a site is occupied by trees. The term basal 

area is often used to describe the collective basal area of trees per acre.

Baseline: Starting point for analysis of environmental consequences. A baseline may be 

conditions at a point in time or collected over a specified period of years.

Best Management Practices (BMPs): Practices determined to be the most effective and 

practicable means of controlling pollutants at levels compatible with environmental quality goals. 

BMPs were conceptualized in the 1972 FUS Federal Water Pollution Control Act. BMPs as 

defined in the USDA Forest Service Soil and Water Conservation Handbook.

Biomass thin: Used in this document to describe the cutting of vegetation (conifers) that may or 

may not have a market value, but are removed from site after cutting. For this document this is 

considered a conifer approximately 4-10 inches in diameter.

Breast Height (as referred to as dbh): A standard height from ground level, generally 4.5 feet 

for recording diameter, circumference or basal area of a tree. 

Broadcast Burn: A type of prescribed fire allowed to burn over a designated area within defined 

boundaries to achieve land management objectives.

Buffer: A land area designated to block or absorb unwanted impacts to the area inside the buffer.

Bulk Density: The weight per unit volume of a measured material. Bulk density of plants is 

measured at a specified moisture tension.

California Wildlife Habitat Relationship System (CWHR): A wildlife information and 

predictive system for mammals, reptiles, and amphibians. This system is considered a state-ofthe-art information system for California’s wildlife. The system provides the most widely used 

habitat relationship models for California’s terrestrial vertebrate species. CWHR is operated and 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 290 Glossary

maintained by the California Department of Fish and Game, in cooperation with the California 

Interagency Wildlife Task Group (CIWTG).

Canopy: Foliar cover in the forest stand consisting of one or several layers.

Chaparral: Dense growth of mostly small-leaved evergreen shrubs. Found in the foothills of 

California.

Classified Roads: Roads wholly or partially within or adjacent to National Forest System lands 

that are determined to be needed for motor vehicle access including State roads, County roads, 

privately owned roads, National Forest Transportation System roads, and roads authorized by the 

Forest Service that are intended for long-term use.

Clump: An isolated, generally dense, group of trees.

Codominant: Tree species in a forest that are about equally numerous and exert the greatest 

influence.

Cohort: A group of trees developing after a single disturbance, commonly consisting of trees of 

similar age. A considerable range of tree ages of seedling or sprout origin and trees that predate 

the disturbance can be included.

Commercial thin: Used in this document to describe the cutting and removal from site of 

vegetation (conifers) that typically has a market value. For this document this is considered a 

conifer over approximately 10 inches in diameter.

Corridor: Elements of the landscape that connect similar areas. Streamside vegetation may 

create a corridor of willows and hardwoods between meadows where wildlife feed.

Cover: Any feature that conceals wildlife or fish. Cover may be dead or live vegetation, boulders, 

or undercut streambanks. Animals use cover to rest, feed, and escape from predators.

Crown: The upper part of a tree that carries the main branch system and foliage.

Crown Closure: The point at which the vertical projections of a crown’s perimeter within a 

canopy touches.

Crown Density: The amount and compactness of foliage for trees or shrubs.

Crown Fire –A fire that advances from top to top of trees or scrubs more or less independent of a 

surface fire. Crown fires are sometimes classed as running or dependent to distinguish the degree 

of independence from the surface fire.

Crown Ratio: The ratio of live crown of a tree in relation to total height. Normally expressed as 

a percentage. Used in silviculture as a measure indicating tree vigor.

Cumulative Effects: Combined effects resulting from sequential actions on a given area.

Damaged (Ecosystem): The acute or obvious changes in an ecosystem.

Degraded (Ecosystem): The subtle or gradual change that reduces ecological integrity and 

health.

Den Tree: A tree that contains a weather tight cavity for wildlife.

Defensible fuels profile(s), Defensible Fuel Profile Zone(s), DFPZ(s): A strategically located 

strip(s) of land where the vegetation has been modified to a less dense fuel type. These are 

typically located along ridgetops and roads and are areas where fire fighters would make a stand 

to contain a fire. The width is based on potential fire behavior based on available fuels, weather 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 291 Glossary

and wind, and topography. They are not designed to stop an oncoming wildfire by themselves, 

but rather to provide a safe location to facilitate fire suppression efforts and provide an anchor 

point for prescribed burning projects. The DFPZ strategy initially treats a lower proportion of the 

landscape; treatments are located to protect specific values and are typically placed in wildland 

urban intermix areas. After a network of DFPZs is established, area fuel treatments (SPLATs) can 

be placed to enhance DFPZ effectiveness and increase the likelihood that the overall landscape 

strategy would reduce wildfire intensity and size.

Destroyed (Ecosystem): Severe degradation or damage removes all macroscopic life and 

drastically alters the physical environment as well. 

Diameter Class: Intervals into which a range of diameters of tree stems or logs may be divided 

for classification or use.

Disturbance: A force that results in changes in the structure and composition through natural 

events such as wind, fire, flood, avalanche, or mortality caused by insect or disease outbreaks or 

human events (e.g. timber harvest).

Duff: Organic material covering the forest floor (includes fresh litter from plants and older, well 

developed humus).

Ecological Restoration: The process of assisting the recovery of resilience and adaptive capacity 

of ecosystems that have been degraded, damaged, or destroyed. 

Ecosystem: An arrangement of living and non-living things and the forces that move among 

them. Living things include plants and animals. Non-living parts of ecosystems may be rocks and 

minerals. Weather and wildfire are two of the forces that act within the ecosystems.

Elevation: Vertical distance of measure displayed in feet above sea level.

Endangered Species: A plant or animal that is in danger of extinction throughout all or a 

significant portion of its range. Endangered species are identified by the Secretary of the Interior 

in accordance with the Endangered Species Act of 1973.

Endemic Species: Plants or animals that occur naturally in a certain region and whose 

distribution is relatively limited to a particular locality.

Environmental Effects: Includes ecological (such as the effects on natural resources and on the 

components, structures, and functioning of affected ecosystems), aesthetic, historic, cultural, 

economic, social, or health whether direct (which are caused by action and occur at the same time 

and place), indirect (which are caused by the action and are later in time or farther removed in 

distance, but are still reasonably foreseeable), or cumulative (results from the incremental impact 

of the action when added to other past, present or reasonably foreseeable future actions). 

Environmental Impact Statement (EIS): A document prepared by a Federal agency in which

anticipated environmental effects of a planned course of action or development are evaluated. 

Federal statute (Section 102 of the National Environmental Policy Act of 1969) requires that such 

statements be prepared. An impact statement includes: (1) the environmental impact of the 

proposed action, (2) any adverse impacts which cannot be avoided by the action, (3) alternatives 

courses of actions, (4) relationships between local short-term use of the human environment and 

the maintenance and enhancement of long-term productivity, and (5) a description of the 

irreversible and irretrievable commitment of resources which would occur if the action were 

accomplished.
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Ephemeral Stream: A stream or portion of a stream that flows only in direct response to 

precipitation, receiving little or no water from springs and no long continued supply from snow or 

other sources and whose channel is at all times above the water table.

Erosion: The wearing away of land surface by rain, running water, wind, ice, gravity, or other 

natural agents including gravitational creep and tillage.

Feasibility: Capability and suitability for specific use. 

Fire Behavior: The over-arching means by which to describe how an ignited fire reacts to the 

influences of fuels, topography and weather when combined together. Typical terms used when 

describing fire behavior include rate of spread (how fast a fire travels over a given distance in a 

given period of time); flame height (as measured in feet from ground through middle of flame); 

intensity (BTUs given off from flaming front); fire type (surface vs. crown) to name a few. 

Computer based models are used to predict fire behavior for given environmental and fuel 

conditions.

Flow: The movement of a stream of water or other mobile substances from place to place. The 

movement of water and the moving water itself. The volume of water passing a given point per 

unit of time.

Forage: All browse and non-woody plants that are eaten by wildlife.

Forb: A grouping or category of herbaceous plants which are not included in grass, shrub or tree 

groupings, generally smaller flowering plants. Forbs contain little or no woody material.

Forest: An ecosystem characterized by a more or less dense and extensive tree cover, often 

consisting of stands of varying in characteristics such as species composition, structure, age class, 

and associated processes. Commonly includes meadows, streams, fish and wildlife.

Forest Health: The perceived condition of a forest derived from concerns about such factors as 

its age, structure, composition, function and vigor, presence of unusual levels of insects or 

disease, and resilience to disturbance. Individual and cultural viewpoints, land management 

objectives, spatial and temporal scales, the relative health of the stands that make up the forest, 

and the appearance of the forest at a point which influences the perception and interpretation of 

forest health.

Forest Plan: Also referred to as a Land and Resource Management Plan (LRMP). A signed 

document that is the source of management direction for an individual National Forest that 

specifies activity and output levels for a period of 10-15 years. Management direction in the 

Forest Plan is based on issues identified at the time of Plan development.

Forestry: The profession embracing the science, art and practice of creating, managing, using 

and conserving forests and associated resources for human benefit and in a sustainable manner to 

meet desired goals, needs and values.

Forest Type: A category of forest usually defined by its vegetation, particularly its dominant 

vegetation as based on percentage cover of trees.

Fragmentation: The process by which a landscape is broken into small islands of forest within a 

mosaic of other forms of land use or ownership.

Frequency: 1. biometrics: the number of occurrences of a given type of event of the number of 

members of a population falling into a specified class; 2. ecology: the number of individuals in a 

community. 
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Fuelbreak: A wide strip or block of land on which the native vegetation has been modified so 

that fires burning into it can be more readily suppressed. Usually strategically build in 

conjunction with a roadway (for access) and along ridgelines. Terms like shaded fuelbreak is used 

to differentiate the amount or type of vegetation that is removed to create the fuelbreak. 

Fuel Model – A fuel model is a set of numerical values that describe the fuel inputs for 

Rothermel’s mathematical model that predicts surface fire spread.

Geographic Information System (GIS): A system of computer maps with corresponding sitespecific information that can be electronically combined to provide reports and maps.

Habitat: The place where an animal, plant or population normally lives and develops.

Habitat capability: The ability of a land area or plant community to support a given species of 

wildlife.

Headcuts: Land erosion at the head of a stream, creek, or river.

Headwater: The source of a stream. The upper tributaries of a drainage basin.

Herb: A non-woody, vascular plant.

Herbaceous: A class of vegetation dominated by no-woody plants known as herbs.

Horizon (soil): A layer of soil approximately parallel to the land surface and differing from 

adjacent genetically related layers in physical, chemical and biological properties or 

characteristics such as color, structure, texture, consistency, kinds and number of organisms 

present, degree of acidity or alkalinity.

Indigenous: Native to a specified area or region.

Indirect Effects: Effects that are caused by an action and occur at a later time, or at another 

location, yet are reasonably foreseeable in the future.

Insect: A member of the class Insecta characterized by a body segmented into three distinct 

regions (head, thorax, abdomen), by a head with one pair of antennae, by a thorax with three 

segments each with a pair of legs, and usually one or two pairs of thoracic wings.

Interdisciplinary Team (IDT): A group of specialists assembled to solve a problem or perform a 

task.

Invasive Plants: Plant species that are introduced into an area in which they did not evolve and 

in which they usually have few or no natural enemies to limit their reproduction and spread. 

These species can cause environmental harm by significantly changing ecosystem composition, 

structure, or processes and can cause economic harm or harm to human health.

Ladder fuels or fuel ladders: Arrangement of vegetation (trees, brush, etc.) that provides 

vertical continuity from the forest floor to the crowns of overstory trees. Example would be 

similar to steps on a ladder.

Land and Resource Management Plan (LRMP): See Forest Plan

Landscape: A large land area composed of interacting ecosystems that are repeated due to 

factors such as geology, soils, climate and human impacts. Landscapes are often used for coarse 

grain analysis.

Maintenance: The work of keeping something in proper condition or standard.
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Masticate or Mastication: Means by which vegetation is mechanically “mowed” into small 

pieces and changed from a vertical to horizontal arrangement.

Management Indicator Species (MIS): Animals or plants identified in Forest Land and 

Resource Management Plans (LRMPs or forest plans) developed under the 1982 Planning Rule, 

that are selected because their population changes are thought to indicate the effects of Forest 

Service management activities.

Mechanical Methods: Utilization of machinery such as bulldozers and skidders for tractor 

logging; helicopter logging, skyline cable logging, mechanical harvesters and 

shredders/masticators.

Merchantable: Having the size, quality and condition suitable for marketing under a given 

economic condition.

Mitigation: Actions taken to avoid, minimize or rectify the impact of a land management 

activity.

Model: A representation of reality used to describe, analyze or understand a particular concept. A 

model may be a relatively simple qualitative description of a system or organization or a highly 

abstract set of mathematical equations. A model has limits to its effectiveness and is used as one 

of several tools to analyze a problem.

Mortality: Trees dying from natural causes, usually by size class in relation to sequential 

inventories or subsequent to incidents such as storms, wildfire or insect and disease epidemics.

Mosaic: A pattern of vegetation in which two or more kinds of communities are interspersed in 

patches, such as clumps of shrubs with grassland between.

National Environmental Policy Act (NEPA): Congress passed in 1969 to encourage productive 

and enjoyable harmony between people and their environment. One of the major tenets of NEPA 

is its emphasis on public disclosure of possible environmental effects of any major action on 

public lands. Section 102 of NEPA requires a statement of possible environmental effects to be 

released to the public and other agencies for review and comment.

Native Species: Indigenous species normally found as part of a particular ecosystem.

Natural Fuel: Term used to describe vegetation, live or dead, in a given area that is not 

associated with being created by management activities. It is usually described in terms of natural 

fuel accumulations or build-up from naturally falling leaves, branches and/or logs from fallen 

snags. 

Notice of Intent (NOI): A notice printed in the Federal Register announcing that an 

Environmental Impact Statement would be prepared. The NOI must describe the proposed action 

and possible alternatives, describe the proposed agency scoping process and provide a contact 

person for further information.

Noxious Weeds (Plants): An undesirable, non-native plant that is difficult to control and is on 

either the California Department of Food and Agriculture Noxious Weed list or the California 

Invasive Plant Council Inventory of invasive plants in California. 

Old-growth (forest): Old forests often containing several canopy layers, variety in tree sizes and 

species; and standing and dead woody materials.

Overstocked: Used in this document to describe stocking levels in excess of that desired for a 

given resource objective.
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Project Activity Level - PAL is a scientifically-based “decision support process” to provide a 

fire precautionary system for industrial operations on National Forest lands in California. Its goal 

is to balance the reduction in the ignition risk of large damaging wildfires with the 

accomplishment of resource (forest projects) management activities.

Patch: An area of homogeneous vegetation, in structure and composition.

Pathogen: A parasitic organism directly capable of causing disease.

Perennial Stream: A stream that has running water on a year-round basis under normal climatic 

conditions.

Pre-commercial thin: Used in this document to describe the cutting of vegetation (conifers) that 

does not typically have a market value and not removed from site after cutting. For this document 

this is considered a conifer approximately 4-9 inches in diameter.

Prescribed burning (fire): With a given range environmental condition (air temperature, fuel 

moisture, windspeed and direction, etc.) and approved plan, a fire that is management ignited to 

meet specific resource management objectives. This can include dozer/hand pile; understory and 

broadcast burning.

Rate of Spread: The relative speed with which a fire increases in size usually expressed in chains 

(66 feet) per hour.

Reclamation: The stabilization of the terrain, assurance of public safety, aesthetic improvement, 

and usually a return of the land to what, within the regional context, is considered to be a useful 

purpose.

Record of Decision (ROD): An official document in which a deciding official states the chosen 

activity (alternative) that would be implemented from a prepared EIS.

Reforestation: The restocking of an area with forest trees, by either natural or artificial means, 

such as planting.

Regeneration: The renewal of a tree crop by either natural or artificial means. The term is also 

used to refer to the young crop itself.

Residual: A tree or snag remaining after an intermediate of partial cutting of a stand.

Resilience: The ability of an ecosystem to maintain diversity, integrity and ecological processes 

following a disturbance.

Resistance: The ability of a community to avoid alteration of its present state by a disturbance. 

The ability of plants to avoid, suppress, prevent, overcome, or tolerate insect or pathogen attack.

Responsible Official: The Federal employee who has the delegated authority to make and 

implement a decision on a proposed action. 

Riparian Area: The area along a watercourse or around a lake or pond.

Riparian Ecosystem: The ecosystems around or next to water areas that support unique 

vegetation and animal communities as a result of the influence of water.

Riparian Conservation Areas (RCAs): These are land allocations that are managed to maintain 

or restore the structure and function of aquatic, riparian and meadow ecosystems. The intent of 

management direction for RCAs is to (1) preserve, enhance, and restore habitat for riparian-and 

aquatic-dependent species; (2) ensure that water quality is maintained or restored; (3) enhance 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 296 Glossary

habitat conservation for species associated with the transition zone between upslope and riparian 

areas; and (4) provide greater connectivity within the watershed.

Risk: The relative probability of any of several alternative outcomes as determined or estimated 

by a decision maker when the outcome of an event or series of events is not known.

Road Maintenance: The ongoing upkeep of a road necessary to retain or restore the road to the 

approved road management objectives.

Road Reconstruction: Activities that result in road realignment or road improvement.

Sample: A part of a population selected and examined as a representative of the whole.

Sediment (sedimentation): Solid materials, both mineral and organic, in suspension or 

transported by water, gravity, ice or air; may be moved and deposited away from their original 

position and eventually would settle to the bottom.

Sensitive Species: Plant or animal species which are susceptible to habitat changes or impacts 

from activities. The official designation is made by the USDA Forest Service at the Regional 

level and is not part of the designation of threatened or Endangered Species made by the U.S. 

Fish and Wildlife Service.

Shade tolerant: When used to describe a conifer, the trees prefer to grow in the shade.

Silvicultural System: The cultivation of forest; the result is a forest of a distinct form. 

Silvicultural systems are classified according to harvest and regeneration methods and the type of 

forest that results.

Silviculture: The art and science that promotes the growth of single trees and the forest as a 

biological unit.

Simulation: An operations research technique that represents physical, natural, social and 

economic systems by models in order to study the factors affecting the system and to aid decision 

making.

Site: The area in which a plant or a stand grows, considered in terms of its environment, 

particularly as this determines the type and quality of the vegetation the area can carry.

Site Preparation: Removing unwanted vegetation, slash, roots and stones from a site before 

reforestation. Naturally occurring wildfire, as well as prescribed fire can prepare a site for natural 

regeneration.

Skid Road (skid trail): A road access cut through the woods for skidding of logs.

Skidder: A self-propelled machine (cable, clam-bunk or grapple) used for dragging trees or logs.

Skidding: Hauling logs by sliding, not on wheels, from stump to a collection point.

Slash: Residue left on the ground after timber cutting or left after a storm, fire or other event. 

Slash includes unused logs, uprooted stumps, broken or uprooted stems, branches, bark, etc.

Snag: A standing dead tree. Snags are important as habitat for a variety of wildlife species and 

their prey.

Soil Compaction: Reduction of soil volume. The weight of heavy equipment, for example, on 

soils can compact the soil and thereby change it in some ways, such as in its ability to absorb 

water.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

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Species: The main category of taxonomic classification into which genera are subdivided, 

comprising a group of similar interbreeding, individuals sharing a common morphology, 

physiology and reproductive process.

Stand: A group of trees that occupies a specific area and is similar in species, age, and condition.

Stand density: A quantitative measure of stocking expressed either absolutely in terms of 

number of trees, basal area, or volume per unit area or relative to some standard condition. A 

measure of the degree of crowding of trees within stocked areas commonly expressed by various 

growing space ratios.

Stand Structure: The physical and temporal distribution of plants in a stand. Silviculture the 

horizontal and vertical distribution of components of a forest stand including the height, diameter, 

crown layers and stems of trees, shrubs, herbaceous understory, snags and down woody material.

Standards and Guidelines: Direction outlined in the Forest Land and Resource Management 

Plan (LRMP) for specific aspects of project planning and analysis.

Stocking: An indication of growing-space occupancy relative to a pre-established standard.

Strategically Placed Landscape Area Treatments: Wildland fire modification strategy (created 

from research conducted by Dr. Mark Finney (1999)) by which a fire is forced to go around areas 

where fuels have been reduced or otherwise modified. The treated areas function as “speed 

bumps” on the landscape to slow the spread and reduce the intensity of oncoming fires and 

thereby reduce damage to both treated and untreated areas.

Streamside Management Zones (SMZs): Management Zones established to protect and 

maintain water quality, site productivity, channel stability, wildlife habitat, and riparian

vegetation.

Structure: Sizes, shapes and/or ages of the plants and animals in an area.

Surface Fuels: Vegetation, either dead or live, that is on the surface, which includes dead 

branches, blowdown timber, leaves, and low vegetation, as contrasted with crown fuels.

Thinning from below: A silvicultural technique by which cutting is done in an immature stand 

of trees to accelerate growth of the remaining trees or to improve the form of the remaining trees. 

From below describes the incremental cutting of trees based on its position in the stand. First 

starting with suppressed, then intermediates, then codominants to reach a desired or prescribed 

basal area for the stand.

Threatened Species: Plant or animal species likely to become endangered throughout all or part 

of their range in the foreseeable future. Designated by the U.S. Fish and Wildlife Service under 

the Endangered Species Act of 1973.

Understory: The trees and woody shrubs growing beneath the overstory in a stand of trees.

Viability: The ability of a population of a plant or animal species to persist for some specified 

time into the future. Viable populations are populations that are regarded as having the estimated 

numbers and distribution of reproductive individuals to ensure that its continued existence is well 

distributed in a given area.

Watershed: The entire region drained by a waterway (or into a lake or reservoir). More 

specifically, a watershed is an area of land above a given point on a stream that contributes water 

to the streamflow at the point.
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Weed: A valueless, troublesome or noxious plant often exotic, growing wild especially on 

growing profusely. A plant growing where it is not wanted.

Wildfire: Any wildland fire that is not a prescribed fire.

Wildland: Land other than that dedicated for other uses such as agriculture, urban, mining or 

parks.

Wildland Urban Intermix (WUI): The line, area, or zone where structures and other human 

development meet or intermingle with undeveloped wildland or vegetative fuels.

Wildfire Intensity: Describes the buildup of heat within a fire, both in amount and in rate of 

transmission-a function of heat release. Usually described as low, moderate or high intensity fires.

Wildlife: All non-domesticated animal life.

Woodland: A forested area; a plant community in which, in contrast to a typical forest, the trees 

are often small, characteristically short-boled relative to their crown depth and forming an open 

canopy with the intervening area being occupied by lower vegetation, commonly grass
Sierra National Forest – 299 Literature Cited 

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Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

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Index

aquatic ................................. 42, 284, 296

California spotted owl................ xi, 2, 10

conifer iii, x, 38, 133, 290, 291, 296, 297

crowns....................................... 285, 294

cultural resources...................... 283, 285

desired conditions ............................... 10

disease ... x, 282, 292, 293, 295, 296, 414

ecosystem.......... x, 1, 293, 294, 295, 296

endangered ................................ 283, 298

fuels......iii, x, xi, 1, 7, 10, 31, 61, 79, 90, 

173, 291, 293, 294, 298, 299, 308, 310

Management Indicator Species 148, 284, 

295

MIS .. 131, 132, 133, 134, 135, 136, 284, 

286, 295

Pacific fisher ............................ xi, 2, 287

plants.... 71, 79, 290, 292, 293, 294, 295, 

296, 298

prescribed burning ...............iii, 283, 292

riparian ...................... 286, 296, 298, 301

sensitive....................................... 79, 287

soil.... 34, 35, 89, 90, 282, 284, 294, 297, 

307

SPLATs......................................... x, 292

stand density........... xi, 31, 173, 192, 282

thinning ...................... xi, 31, 34, 48, 173

threatened.................................. 283, 297

wildfires ......................... x, xi, 6, 53, 362

WUI................................ xi, 1, 6, 10, 299
Sierra National Forest – 313 Appendix C 

Appendices

Appendix A – Map Package for Greys Mountain

Project ____________________________________

See Map Package
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 314 Appendix B

Appendix B – Best Management Practices 

Associated with Greys Mountain Project ________

BMP Name, Objective, and 

Direction Application to the Greys Mountain Project

BMP 1-1 Timber Sale Planning 

Process: To incorporate water 

quality and hydrologic 

considerations into the timber sale 

planning process.

Implemented through the Riparian Conservation Objectives/Forest 

Plan Consistency report, specification of operational BMPs, 

Environmental Analysis including interdisciplinary team office and 

field discussions, and incorporation of water quality protection 

measures in the Timber Sale Contract for the GRERP EIS.

BMP 1-4 Use of Sale Area Maps 

(SAM) and/or Project Maps for 

Designating Water Quality 

Protection Needs: To ensure 

recognition and protection of 

areas related to water quality 

protection delineated on a SAM 

or project map. 

The sale administrator and purchaser will review these areas on the 

ground prior to commencement of ground disturbing activities. 

Examples of water quality protection features that will be designated 

on the project map include:

1)Location of stream courses and riparian zones to be protected, 

including the width of the protection zone for each area.

2)Wetlands (meadows, lakes, springs, etc.) and other sensitive 

areas (such as shallow soils) to be protected. 

3)Boundaries of harvest units, specified roads and roads where 

hauling activities are prohibited or restricted, areas of different 

skidding and/or yarding methods, including post-harvest fuels 

treatments, and water sources available for purchaser’s use.

BMP 1-5 Limiting the Operating 

Period of Timber Sale Activities: 

To ensure that the purchasers 

conduct their operations, 

including erosion control work, 

road maintenance, and so forth, in 

a timely manner, within the time 

frame specified in the Timber 

Sale Contract.

The purchaser’s contract operation period will be limited to contractspecified periods when adverse environmental effects are not likely. 

The Sale Administrator will close down operations due to rainy 

periods, high water, or other adverse operating conditions in order to 

protect resources.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 315 Appendix B

BMP Name, Objective, and 

Direction Application to the Greys Mountain Project

BMP 1-8 Streamside 

Management Zone Designation: 

To designate a zone along 

riparian areas, streams and 

wetlands that will minimize 

potential for adverse effects from 

adjacent management activities. 

Management activities within 

these zones are designed to 

improve riparian values. 

Streamside management zones (SMZs ) have been supplemented 

with RMAs and RCAs (USDA 2004b) as described in the Design 

Measures section of the EIS. 

Within SMZs, the constraints defined in Sierra Supplement No. 1 

(USDA Forest Service, 1989) apply. This includes no self-propelled 

ground based equipment, a minimum groundcover of 50%, and 

shade canopy may not be modified in a way that affects stream 

temperature. 

Modifications to these guidelines are possible where site-specific 

needs exist if the action is reviewed by a hydrologist or fisheries 

biologist.

BMP 1-9 Determining Tractor 

Loggable Ground: To minimize 

erosion and sedimentation 

resulting from ground disturbance 

of tractor logging systems. 

Limit ground skidding and machine piling with tractors to slopes 

less than 35%. Endlining can be used to remove logs from steeper 

slopes. Ground disturbance on areas of shallow soils, notably soils 

adjacent and abutting to rock outcrops, will be avoided. 

BMP 1-10 Tractor Skidding 

Design: By designing skidding 

patterns to best fit the terrain, the 

volume, velocity, concentration, 

and direction of runoff water can 

be controlled in a manner that 

will minimize erosion and 

sedimentation.

The sale administrator and purchaser will designate all skid trails 

prior to ground disturbing activities. If uncertainty arises regarding 

potential resource impacts of skid trail location, consult with an 

earth science specialist (i.e., hydrologist, aquatic biologist, or soil 

scientist). 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 316 Appendix B

BMP Name, Objective, and 

Direction Application to the Greys Mountain Project

BMP 1-12 Log Landing Location: 

To locate new landings in such a 

way as to avoid watershed 

impacts and associated water 

quality degradation 

The following criteria are to be used by the Sale Administrator when 

evaluating landings:

1. The cleared or excavated size of landings will not exceed that 

needed for safe and efficient skidding and loading operations. 

Trees considered dangerous will be removed around landings to 

meet the safety requirements of OSHA.

2. Selected landing locations will involve the least amount of 

excavation and fill possible. Landings must be located outside 

of SMZs.

3. Locate landings near ridges away from headwater swales in 

areas that will allow skidding without crossing stream channels, 

violating SMZs, or causing direct deposit of soil and debris to a 

stream. 

4. Locate landings where the least number of skid roads will be 

required, and sidecast can be stabilized without entering 

drainages or affecting other sensitive areas. Keep the number of 

skid trails entering a landing to a minimum.

5. Position landings such that the skid road approach will be nearly 

level as feasible, to promote safety and to protect soil from 

erosion.

6. Avoid excessive fills associated with landings constructed on 

old landslide benches. 

7. Construct stable landing fills or improve existing landings by 

using appropriate compaction and drainage specifications. 

In some cases, using an existing landing located within an RCA or 

CAR is preferable to constructing a new landing outside of it. These 

situations will be reviewed on a site-by-site basis by an earth science 

specialist (aquatics, hydrology, geology, or soils). 

BMP 1-13 Erosion Prevention 

and Control Measures during 

Timber Sale Operations: To 

ensure that the purchasers’ 

operations will be conducted 

reasonably to minimize soil 

erosion.

Timber purchaser responsibilities for erosion control will be set forth 

in the Timber Sale Contract. Equipment will not be operated when 

ground conditions are such that excessive damage will result. The 

kinds and intensity of control work required of the purchaser will be 

adjusted by the sale administrator to ground and weather conditions 

with emphasis on controlling overland runoff, erosion, and 

sedimentation. 

Erosion control work required by the contract will be kept current. 

At certain times of the year this means daily, if precipitation is likely 

or weekly when precipitation is predicted for the weekend. Erosion 

prevention measures must be applied no later than October 1 and 

immediately upon completion of activity begun after November 1. 

If the purchaser fails to perform seasonal erosion control work prior 

to any seasonal period of precipitation or runoff, the Forest Service 

may temporarily assume responsibility, complete the work, and use 

any unencumbered deposits as payment for the work.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 317 Appendix B

BMP Name, Objective, and 

Direction Application to the Greys Mountain Project

BMP 1-16 Log Landing Erosion 

Protection and Control: To reduce 

the impacts of erosion and 

subsequent sedimentation 

associated with log landings by 

use of mitigating measures. 

Landings will be properly cross-ditched, ripped (if soils are 

compacted), re-contoured (as necessary), and mulched after use and 

before the winter precipitation period, whichever comes first. Excess 

material not needed for erosion control can be piled and burned. 

Upon completion of the project, consult with the hydrologist or soil 

scientist to determine the need for additional soil protection 

measures.

BMP 1-17 Erosion Control of 

Skid Trails: To protect water 

quality by minimizing erosion 

and sedimentation derived from 

skid trails. 

Erosion control measures will be installed on all skid trails, tractor 

roads, and temporary roads. Erosion control measures include, but 

are not limited to, cross ditches (water bars), organic mulch, and 

ripping. 

Cross ditches will be spaced according to the guidelines below, 

maintained in a functioning condition, and placed in locations where 

drainage would naturally occur (i.e., swales). The level of 

maintenance will be contingent upon existing or predicted weather 

patterns as determined by the Sale Administer (see BMP 1-13).

 Minimum Cross Drain Spacing 

% Slope Maximum Spacing

0 - 15 125 feet

15 - 35 45 feet

BMP 1-18 Meadow Protection 

during Timber Harvesting: To 

avoid damage to the ground 

cover, soil, and hydrologic 

function of meadows.

Mechanical equipment is not permitted in meadows. Additionally, 

the SNF has implemented a 100’ protection buffer around meadows 

that are equipment exclusion zones. Access is not permitted in 

meadows or the 100’ buffer unless specifically authorized by an 

aquatic biologist and/or hydrologist.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 318 Appendix B

BMP Name, Objective, and 

Direction Application to the Greys Mountain Project

BMP 1-19 Streamcourse and 

Aquatic Protection: The 

objectives of this BMP are:

 To conduct management 

actions within these 

areas in a manner that 

maintains or improves 

riparian and aquatic 

values. 

 To provide unobstructed 

passage of stormflows. 

 To control sediment and 

other pollutants entering 

streamcourses.

 To restore the natural 

course of any stream as 

soon as practicable, 

where diversion of the 

stream has resulted from 

timber management 

activities. 

a)The location and method of crossings on Class IV and V streams 

must be agreed to by the sale administrator (SA) prior to 

construction. 

b)Stream crossings on Class I – III streams must be approved by 

the hydrologist and/or aquatic biologist. 

c)Damage to stream banks and channels will be repaired to the 

extent practicable. 

d)All sale-generated debris will be removed from streamcourses, 

unless otherwise agreed to by the SA, and in an agreed upon 

manner that will cause the least disturbance. 

e)Felled trees will not be pulled across perennial or intermittent 

stream channels without prior approval by the hydrologist and/or 

aquatic biologist. 

f) Methods for protecting water quality while utilizing tractor skid 

trail design in stream course areas where harvest is approved 

include: (1) end lining, (2) falling to the lead, and (3) utilizing 

specialized equipment with low ground pressure such as feller 

buncher harvester. 

g)Water bars or other erosion control structures will be located so 

as to disperse concentrated flows and filter out suspended 

sediments prior to entry into streamcourse. 

h)Material from temporary road construction and skid trail 

streamcourse crossings will be removed and streambanks restored 

to the extent practicable. 

i) Special slash treatment site preparation activities will be 

prescribed in sensitive areas to facilitate slash disposal without use 

of mechanized equipment. 

j) Project-related bare soil areas (e.g. skid trails, landings, 

temporary roads, etc.) will be covered with existing native 

vegetation mulch, organic debris, or certified weed free straw to at 

least 50%, well distributed cover, and cross-ditched per BMP 1-17 

requirements.

BMP 1-20 Erosion Control 

Structure Maintenance: To 

ensure that constructed erosion 

control structures are stabilized 

and working

During the period of the timber sale contract, the purchaser will 

provide maintenance of soil erosion control structures contracted by 

the purchaser until they become stabilized, but not more than one 

year after their construction. If the purchaser fails to do seasonal 

maintenance work, the Forest Service may assume the responsibility 

and charge the purchaser accordingly. The Forest Service sale 

administrator is responsible for ensuring erosion control 

maintenance work is completed.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 319 Appendix B

BMP Name, Objective, and 

Direction Application to the Greys Mountain Project

BMP 1-21 Acceptance of Timber 

Sale Erosion Control Measures 

before Sale Closure: To ensure 

the adequacy of required erosion 

control work on timber sales. 

The sale administrator must inspect erosion control measures to 

ensure their adequacy prior to accepting closure on the unit and/or 

sale. 

The effectiveness of erosion control measures will be evaluated 

using BMPEP protocols (see Monitoring Plan) after the sale area has 

been through one or more wet seasons. This evaluation is to ensure 

that erosion control treatments are in good repair and functioning as 

designed before releasing the purchaser from contract responsibility. 

The purchaser is responsible for repairing erosion control treatments 

that fail to meet criteria in the Timber Sale Contract, as determined 

by the Sale Administer, for up to one year past closure of the sale. 

BMP 1-22 Slash Treatment in 

Sensitive Areas: To maintain or 

improve water quality by 

protecting sensitive areas from 

degradation which would likely 

result from using mechanized 

equipment for slash disposal. 

All burn piles made with mechanical equipment must be located 

outside of the SMZ.

Hand piles will be kept at least 20 feet away from all streams, 

meadows, springs, seeps, and other sensitive aquatic areas. 

BMP 2-1 General guidelines for 

the Location and Design of 

Roads: To locate and design 

roads with minimal resource 

damage. 

The following considerations are incorporated into the planning 

process of road location and design. These measures are 

preventative, apply to all transportation activities, and indirectly 

protect water quality:

a) Transportation facilities will be developed and operated to 

best meet the resource management objectives with the 

least adverse effect on environmental values. 

b) The location, design, and construction of roads will include 

the use of the IDT. 

c) Sensitive areas such as wetlands, inner gorges, and unstable 

ground will be avoided to the extent practicable.

d) Stream crossings will be designed to provide the most cost 

efficient drainage facility consistent with resource 

protection, facility needs, and legal obligations. 

BMP 2-2 Erosion Control Plan: 

To mitigate and control erosion 

through effective planning prior 

to initiation of construction. 

Any new construction would be subject to erosion control measures 

as per an IDT approved plan that may include but not be limited to 

waterbar installation, sediment fencing, culvert installation and 

armoring, placement of straw waddles, approved straw cover and/or 

slash and any other method necessary to mitigate erosion and 

sediment routing in the project subdrainage(s).
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 320 Appendix B

BMP Name, Objective, and 

Direction Application to the Greys Mountain Project

BMP 2-3 Timing of Construction 

Activities: To minimize erosion 

by conducting operations during 

minimal runoff periods and when 

soils are dry and less prone to 

compaction. 

Ground-disturbing activities will occur when soils are dry. In some 

cases soils may never dry sufficiently. Ground-disturbing work that 

occurs off of existing roads will occur during the dry season and will 

reduce ground disturbance as much as possible.

BMP 2-5 Road Slope 

Stabilization Construction 

Practices: To reduce 

sedimentation by minimizing 

erosion from road slopes and 

slope failure along roads.

An adequate soils and geologic investigation will be conducted 

when finalizing new road construction designs for: correct cut and 

fill steepness based on the angle of repose for the type of material; 

methods to handle surface runoff; and necessary compaction 

standards and surfacing needs.

BMP 2-7 Control of Road 

Drainage: To minimize the 

erosive effects of water 

concentrated on roads, to disperse 

runoff from road surfaces, to 

lessen sediment yield from roaded 

areas, and to minimize erosion of 

the road prism. 

Newly constructed or reconstructed roads will be designed to reduce 

hydrologic connectivity and soil erosion wherever feasible. The sale 

administrator or other Forest Service representative will ensure that 

roads are adequately maintained during project implementation to 

ensure that road drainage features function as designed.

BMP 2-9 Timely Erosion Control 

Measures on Incomplete Roads 

and Stream Crossing Projects: To 

minimize erosion and 

sedimentation from disturbed 

ground on incomplete projects. 

Erosion control must be completed before the rainy season (usually 

October). Preventative measures for timely erosion control include:

Removal of temporary culverts, culvert plugs, diversion dams, or 

elevated stream crossings.

Installation of temporary culverts, side drains, flumes, cross drains, 

diversion ditches, energy dissipaters, dips, sediment basins, berms, 

debris racks, or other facilities needed to control erosion. 

Removal of debris, obstructions, and spoil material from channels 

and floodplains. 

Planting vegetation, mulching, and/or covering exposed surfaces 

with jute mates or other protective material.

BMP 2-10 Construction of Stable 

Embankments: To construct 

embankments with materials and 

methods which minimize the 

possibility of failure and 

subsequent water quality 

degradation. 

Roadways will be designed and constructed as stable and durable 

earthwork structures with adequate strength to support the treadway, 

shoulders, subgrade and road traffic loads.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 321 Appendix B

BMP Name, Objective, and 

Direction Application to the Greys Mountain Project

BMP 2-11 Control of Sidecast 

Material During Construction and 

Maintenance: To minimize 

sediment production originating 

from sidecast material during 

road construction or maintenance.

Sidecasting is not permitted within SMZs. 

Waste areas must be located where excess material can be deposited 

and stabilized.

BMP 2-12 Servicing and 

refueling equipment: To prevent 

pollutants such as fuels, 

lubricants, bitumen’s and other 

harmful materials from being 

discharged into or near rivers, 

streams and impoundments, or 

into natural or man-made 

channels. 

Storage of hazardous materials (including fuels) and servicing and 

refueling of equipment will be conducted at pre-designated locations 

outside of RCAs and CARs. If fueling and/or storage of hazardous 

materials are needed within RCAs or CARs, those sites must be 

reviewed and approved by the District Hydrologist or Aquatic 

Biologist. Additional protection measures, such as containment 

devices, may be necessary. 

BMP 2-13 Control of 

Construction and Maintenance 

Activities Adjacent to SMZs: To 

protect water quality by 

controlling construction and 

maintenance actions within and 

adjacent to SMZs so that SMZ 

functions are not impaired. 

Construction and maintenance fills, sidecast, and end-hauled 

materials will be kept out of SMZs except at designated crossing 

sites to minimize the effect to the aquatic environment. 

BMP 2-14 Controlling InChannel Excavation: To 

minimize stream channel 

disturbances and related sediment 

production.

There will be no in-channel or streambank excavation during any 

phase of project activities unless authorized by the district 

hydrologist or aquatic biologist.

BMP 2-16 Stream Crossings on 

Temporary Roads and Skid 

Trails: 

Mechanical equipment crossing of perennial and intermittent 

(generally class I – III) streams is not permitted unless approved by

the district hydrologist or aquatic biologist. Ephemeral streams 

(stream class IV and V) may be crossed at designated locations as 

agreed upon by the sale administrator and purchaser. Designate skid 

trails to avoid stream crossings and SMZs wherever possible. 

Designated crossings must be as perpendicular to the channel as 

possible and avoid sensitive soils and riparian vegetation damage. 

Stream banks must be repaired upon completion of the project.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 322 Appendix B

BMP Name, Objective, and 

Direction Application to the Greys Mountain Project

BMP 2-19 Disposal of Right-ofWay and Roadside Debris: To 

ensure that organic debris 

generated during road 

construction is kept out of 

streams so that channels and 

downstream facilities are not 

obstructed. 

If slash generated by road work is disposed of within SMZs, it will 

be piled and burned or chipped. Material may also be removed from 

the SMZ for disposal.

BMP 2-21 Water Source 

Development Consistent with 

Water Quality Protection: To 

supply water for roads and fire 

protection while maintaining 

existing water quality.

Water drafting will not occur in streams when the base discharge is 

less than 1.5 cfs, and will not draft more than 50% of the ambient 

discharge over 1.5 cfs. New drafting sites would be approved by the 

District Hydrologist or Fisheries/Aquatic Biologist and located to 

minimize sediment and maintain riparian resources, channel 

condition, meadow integrity, and aquatic species viability and 

habitat. Approaches will be as near perpendicular to the stream as 

possible and will be gravel surfaced or otherwise stabilized. 

If water-drafting is required, pumps with low entry velocity and 

suction strainers with screens less than 2 mm in size (1/8 in.) will be 

used.

BMP 2-22 Maintenance of Roads: 

To maintain roads in a manner 

that provides for water quality 

protection by minimizing rutting, 

failures, sidecasting, and 

blockage of drainage facilities, all 

of which can cause erosion, 

sedimentation, and deteriorating 

watershed conditions.

Roads needed for project activities will be brought to current 

engineering standards of alignment, drainage, and grade before use, 

and will be maintained through the life of the project. Roads will be 

inspected at least annually to determine what work, if any, is needed 

to keep ditches, culverts, and other drainage facilities functional and 

the road stable. 

BMP 2-23 Road Surface 

Treatment to Prevent Loss of 

Materials: 

Surface stabilization will be considered where grades exceed 12% or 

road is within riparian conservation areas.

BMP 2-24 Traffic Control During 

Wet Periods: To reduce road 

surface disturbance and the 

rutting of roads, and to minimize 

sediment washing from disturbed 

road surfaces.

On roads not designated for all weather or winter haul, heavy 

equipment operations will be limited until the period after the soil 

has dried in the top 12 inches in the spring.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 323 Appendix B

BMP Name, Objective, and 

Direction Application to the Greys Mountain Project

BMP 2-26 Obliteration or 

Decommissioning of Roads: To 

reduce sediment generated from 

temporary roads, unneeded 

system and non-system roads by 

obliterating or decommissioning 

them at the completion of the 

intended use.

Temporary roads will be obliterated after serving their intended 

purpose for this project. This includes: (1) road effectively 

barricaded; (2) road effectively drained by measures such as recontouring or outsloping to return surface to near natural hydrologic 

function; (3) a well distributed mulch or organic cover provides at 

least 50% cover, or road surface is re-vegetated using local native 

species; (4) sideslopes are reshaped and stabilized to match the 

natural contour (as necessary); and (5) stream crossings are removed 

and natural channel geometry is restored. 

If non-local mulch is used (such as straw), it must be approved by 

the Forest Service botanist as weed free. 

BMP 6-1 Fire and Fuel 

Management Activities: To 

reduce public and private losses 

and environmental impacts which 

result from wildfires and/or 

subsequent flooding and erosion 

by reducing or managing the 

frequency, intensity and extent of 

wildfire. 

The project action alternatives are designed to achieve the desired 

conditions of BMP 6-1. 

BMP 6-2 Consideration of Water 

Quality in Formulating Fire 

Prescriptions: To provide for 

water quality protection while 

achieving the management 

objectives through the use of 

prescribed fire. 

Prescribed burning is planned at the minimum intensity and severity 

necessary to achieve management objectives, and each Burn Plan 

will incorporate all relevant design measures from this EIS. 

BMP 6-3 Protection of Water 

Quality from Prescribed fire 

Effects: To maintain soil 

productivity, minimize erosion, 

and minimize ash, sediment, 

nutrients, and debris from 

entering water bodies.

Fires will be allowed to back into riparian vegetation, but direct 

lighting within riparian vegetation will not occur. 

All fire lines within RCAs and CARs will be water barred per BMP 

1-17 spacing requirements. Fire lines within RCA (i.e., 150 ft., 

seasonal streams, and 300 ft. perennial streams, springs, and 

meadows) will be designed and constructed to reduce sediment entry 

into channels. Fire lines in RCAs will cross perpendicular to streams 

and follow the natural landscape contour as much as possible. Fire 

lines within the SMZ will be hand cut. Waterbars will be placed on 

either side of each stream crossing to prevent or reduce sediment 

entry into streams. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 324 Appendix B

BMP Name, Objective, and 

Direction Application to the Greys Mountain Project

BMP 6-5 Repair or Stabilization 

of Fire Suppression Related 

Watershed Damage: To stabilize 

all areas that have had their 

erosion potential significantly 

increased, or their drainage 

pattern altered by suppression 

related activities.

In the event of a wildfire, protection of resources would be evaluated 

under the Burned Area Emergency Response, assessment and 

treatment Implementation protocol.

BMP 6-6 Emergency 

Rehabilitation of Watersheds 

Following Wildfires: To 

minimize as far as practicable: 1.) 

loss of soil and onsite 

productivity; 2.) overland flow, 

channel obstruction and 

instability; 3.) threats to life and 

property both on-site and off-site

In the event of a wildfire, protection of resources would be evaluated 

under the Burned Area Emergency Response, assessment and 

treatment Implementation protocol. 

BMP 7-3 Protection of Wetlands: 

To avoid adverse water quality 

impacts associated with 

destruction, disturbance, or 

modification of wetlands.

Ground disturbing activities will not occur in wetlands or meadows. 

BMP 7-4 Oil and Hazardous 

Substance Spill Contingency Plan 

and Spill Prevention Containment 

and Countermeasure (SPCC) 

Plan: To prevent contamination of 

water from accidental spills.

A spill contingency plan and spill prevention and countermeasure 

plan (SPCC) must be prepared if hazardous materials (including 

fuels and oils) stored on the Sierra National Forest exceed 1320 

gallons, or if a single container exceeds 660 gallons.

The plan will at a minimum include: the types and amounts of 

hazardous materials located in the project area, pre-project identified 

locations for hazardous materials storage and fueling/maintenance 

activities (must be located outside of RCA and CAR unless prior 

approval by District Hydrologist or Aquatic Biologist is obtained), 

methods for containment of hazardous materials and contents of onsite emergency spill kit, and a contingency plan (including contact 

names with phone numbers) to implement in the event of a spill. 

The SPCC plan must be approved by the Forest Service prior to 

project implementation.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 325 Appendix B

Stream Crossing Design Measures

Traditionally, live stream crossings for skid trails or temporary roads, were constructed by 

excavating the crossing, placing a culvert in the stream, and filling around the pipe with fill dirt. 

When the project was complete, the culvert and fill dirt were removed, usually with the bulldozer. 

This practice caused excessive sediment input into the stream, along with much disturbance of the 

stream banks. Rehabilitation work consisted of placing waterbars on each bank of the stream 

along with grass-seed and straw. The grass-seed/straw combo was placed from stream bank to 

the first waterbar ditch, on each bank, depending on slope gradient.

Cut-to-Length (CTL) machines changed the way operations were conducted in the woods. The 

harvester/tree processor establishes their route of travel (forwarding trails) through the unit. The 

harvester cuts trees down, delimbs and produces logs along these trails, all the while leaving the 

resulting limbs and tree tops (slash) in the trails as a “slash mat” for ground cover. The forwarder 

follows the harvester, driving over the “slash mat” to pick up the logs and returns to the landing. 

This procedure works well when abundant material is available in the stands; 

The placement and removal of the log fill is accomplished with the harvester, which can grasp the 

processed logs with its cutting-head, feed wheels and limb knives. This allows the logs to be 

lifted into and out of position, much like a crane or boom. This not only reduces or eliminates the 

amount of soil disturbance and stream sediment loading, but the amount of the distubed area is 

greatly reduced.

For perennial streams, a minimum of an 18” culvert should be used with the slash and small logs 

(4-8” dbh) to build the crossing. Culvert sizing should be such that a 25 year flood event could 

pass with no static head development upstream of the culvert. It would be best to consult the 

district hydrologist and roads engineer for proper watershed analysis and culvert sizing prior to 

construction. 

Inspection of the channel before and after the construction of the crossing will need to be done by 

the district hydrologist to determine if any restoration is required. Any stream disturbnace will 

have to be restoraed to pre-disturbace conditions. No fill material (i.e., soil) should be used in the 

crossing.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 326 Appendix B

During

After
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 327 Appendix B

After

Before
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 328 Appendix B

Restoration Methodology: Vertical Instabilities

Vertical instabilities such as headcuts can be arrested in place and inhibited from further 

headward propagation into a meadow or watershed, which will mitigate further erosion, 

but do little to restore the water table to its previous elevation. A restoration method 

known as “plug-and-pond” (which plugs the channel downstream of the headcut and 

eventually backwaters the headcut) has been employed with great success in some 

meadows. Plug-and-Pond is effective at preventing erosion and restoring the ground 

water table in highly incised and degraded meadows; however, this method is most 

effective and cost-efficient in low-gradient meadows less than 2% (Dave Rosgen, 

personal communication, 2009, 2010,). The meadows in the project area have gradients 

over 4%, and thus are not suitable candidates for plug-and-pond. Instead,, design 

structures such as rock step pools or log-and-fabric step-falls would be used to mitigate 

further erosion of a headcut. 

Rock Step-Pool 

Rock step-pools mimic natural channels that have gradients greater than 10% (e.g., 

Rosgen “A” channels), and are designed to dissipate energy by preventing water from 

obtaining excess velocity. This design is employed if the height of the drop (i.e., headcut) 

is greater than the bank full channel depth (Figure 25). 

Materials will include appropriately sized rock (i.e., D84 or greater based on reference 

reach characteristics of nearby A or B channels), jute fabric, and local native vegetation 

(sod, native willow, etc.). Traditional use of impervious geotextile material in headcut 

repair is not recommended because it prevents re-vegetation and stabilization of the rock 

and also has a tendency to channel overland and base flow behind the facing rock, further 

eroding the head and sidewalls of the headcut. WIN site condition data collected in the 

summer of 2009 showed most restoration structures utilizing this type of geotextile 

material had failed; the WIN sites that had successfully withstood large flood events used 

large rock, no geotextile fabric, and had completely re-vegetated. In lieu of non-porous 

geotextile material, coarse jute fabric is recommended where the substrate is non 

cohesive and easily erodible. This type of jute will hold moisture; allow plants to take 

root and provide mulch, prevent most fines for washing away, and will eventually 

biodegrade. In highly cohesive clay-rich soils, no fabric is recommended; proper sizing 

and placement of rock and re-vegetation will be effective at preventing further erosion. 

Rock step pools will require quarry rock to be transported and cached near the restoration 

site (unless there is sufficient loose rock in situ) and hauled to the site via power wheel 

barrow. This has the potential to cause temporary surface disturbance. Slash (from the 

vegetation treatments), ply wood, and/or weed cloth will be placed along ingress-egress 

routes to mitigate these impacts. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 329 Appendix B

Figure 25. Step-pools built into two narrow headcuts at the toe of Summit Meadow, Sierra 

National Forest.

. 

Log-and-Fabric Step-Falls

If accessibility to a restoration site has the potential for significant ground disturbance 

(i.e., requires closed roads to be re-opened, or results in excessive length of rock haul 

routes through meadows, etc.), then materials in situ can be used. Since part of each 

restoration design will include the removal of encroaching conifers like lodgepole pine, 

small logs (4” - 10” dbh) will be readily available. These can be used to build a log-andfabric step falls for headcut restoration. These structures have been found to be effective 

in wet meadow environments where the wood is submerged and abundant vegetation has 

become established to hold the lip of the headwall (Figure 26). Materials will include 

logs cut to four to eight foot lengths (4” to 10” dbh), jute fabric, stakes, 2” fencing 

staples, smooth fencing wire, and native sod clumps.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 330 Appendix B

Figure 26. . Log-and Fabric Step-Falls used for headcut mitigation, Johnson Meadow, 

Sierra National Forest.

Rock Arch Dam, Filter Dam, and Weir Grade-Control Structures

For knick points or grade control along a channel reach, a rock arch structure can provide 

a step-falls scour pool function, and when installed in series, can be used to check 

velocity and dissipate energy along straightened stream reaches. A filter dam is used to 

raise the bed of a gully by trapping suspended load, and some wash load in the interstices 

of the larger rock. Like rock arc and filter dams, weirs provide grade control and can be 

constructed of a variety of materials. 

Sod Plugs

Water typically moves through meadows as sheet flow, swale flow, or channelized flow 

in stable E channels. Changes in peak flow from increased hydrologic connectivity in the 

watershed can concentrate flow in meadows, causing the incision of swales, existing 

natural channels, and cow trails. Returning (incised) channelized flow back into overland 

flow will promote localized ground water mounding and the overall elevation of the 

water table in the meadow. This can be achieved by filling in small (<2’x2’) incised 

channels with native fill, sod, weed-free rice straw, sod, native logs and slash, or a 

combination of all these. If these channels no longer act as conduits through the meadow, 

then during peak flow events, water will move over the surface of the meadow as 

opposed to being channeled through the meadow, greatly increasing the residence time of 

the water within the meadow system.

Restoration Methodology: Lateral Instabilities

Vanes, Cross-Vanes and J-Hooks

In order to stabilize denuded unstable channel banks, it is often necessary to reduce the 

near bank shear stress to allow for vegetative recovery, in addition to other bank 

stabilization efforts. This is especially true for the outside of meander bends where shear 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 331 Appendix B

stress is highest. There are many in-stream structures that provide bank protection, and 

the designs specified here use both rock and in situ wood material. Many of these 

restoration structures are also used in the induced meandering method of channel 

restoration (described below). Vanes act as deflectors and can divert high velocity flow 

away from a cutbank or the outside of a meander bend. The vane functions by moving 

the zone of maximum velocity outward from the bank, protecting the adjacent bank and 

creating a point bar, but producing erosion on the opposite bank. Vanes can be 

constructed from a variety of materials, with post-vane design being the most adaptable 

to applications in a forest or near a meadow. Cross-Vanes decrease near bank shear stress 

and concentrate flow into the thalweg. Cross-Vanes are multifunctional in that they 

provide grade control, reduce bank erosion, create a stable width-to-depth ratio, maintain 

sediment transport capacity, and sediment competence. Like Cross-Vanes, J-Hooks serve 

the same purpose, but are typically employed for only one channel bank, usually on the 

outside of a meander bend.

Induced Meandering (Baffles, Vanes, and Weirs)

Deeply Incised and straightened channels may be too degraded to cost-effectively employ 

grade control or bank stabilization. Many of these channels are in the early stages of 

evolution from a G-type to an F-type channel, where the belt width becomes sufficient to 

allow meanders, point bars and flood plains to begin formation for the given gradient. It 

is often useful to give the this natural channel evolution a gentle “push” in the right 

direction by inducing meanders to develop. The restoration design involves placing a 

series of in-stream structures (weirs, vanes and baffles) to control and divert flow to 

increase or decrease lateral erosion at critical points in the channel. The objective is to 

widen the channel (belt width) to facilitate the development of meanders and eventually 

alter that meander geometry appropriate for the reach. This will also help develop flood 

plains and point bars, each of which is essential for the proper functioning of the channel. 

This method is not suited for high bed load streams and/or streams that do not have the 

competence to efficiently move the sediment derived from the channel banks.
Sierra National Forest – 332 Appendix C 

Appendix C---Soils and Geology 

Greys Mountain Project Meadows

Figure 27. Greys Mountain Project selected meadows for conifer encroachment
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 333 Appendix C

Greys Mountain Project Soil Transects

Figure 28. Greys Mountain Project soil transects
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 334 Appendix C

Meadow Encroachment Classification

Level 0

Unable to determine. Approximate extent of encroachment unable to be 

determined using aerial photography due to poor image quality, lack of reliable 

reference points, or missing photo(s).

Level 1 Increasing area. An increase in meadow or meadow ecotone area has 

occurred.

Level 2

0%. No encroachment as indicated by no visible evidence of new growth in 

the meadow or meadow ecotone area. In addition, there is no discernible 

decrease in tree height from an established tree line outside the meadow to 

shorter new growth within the meadow or meadow ecotone.

Level 3

Minimal encroachment (1-5%). Tree encroachment only occupies 1-5% of 

the non-encroached 1940/1944 meadow or meadow ecotone area. New 

growth is denoted by trees visible in the meadow or meadow ecotone that 

formerly did not exist. This encroachment may be accompanied by a 

discernible change in tree height from a taller, established tree line outside 

the meadow transitioning to shorter new growth in the meadow or meadow 

ecotone.

Level 4

Moderate encroachment (6-15%). The visually estimated area of tree 

encroachment is 6-15% of the non-encroached 1940/1944 meadow or meadow 

ecotone area. New growth is denoted by trees visible in locations once barren of 

conifer vegetation. This encroachment may be accompanied by a discernible 

change in tree height from a taller, established tree line outside the meadow 

transitioning to shorter new growth in the meadow or meadow ecotone.

Level 5

Extensive encroachment (16-35%). The visually estimated area of tree 

encroachment is 16-35% of the non-encroached 1940/1944 meadow or 

meadow ecotone area. This encroachment may be accompanied by a 

discernible change in tree height from a taller, established tree line outside 

the meadow transitioning to shorter new growth in the meadow or meadow 

ecotone.

Level 6

Severe encroachment (36-60%). The visually estimated area of tree 

encroachment is 36-60% of the non-encroached 1940/1944 meadow or 

meadow ecotone area. This encroachment may be accompanied by a 

discernible change in tree height from a taller, established tree line outside 

the meadow transitioning to shorter new growth in the meadow or meadow 

ecotone.

Level 7

Extreme encroachment (61-100%). The visually estimated area of tree 

encroachment is 61-100% of the non-encroached 1940/1944 meadow or 

meadow ecotone area. This encroachment may be accompanied by a 

discernible change in tree height from a taller, established tree line outside 

the meadow transitioning to shorter new growth in
Sierra National Forest – 335 Appendix C 

Soil Transect & Meadow Summaries

Table 61. Soil disturbance class by percent present for each soil transect completed

Soil Transect

Soil Disturbance Class

Class 0 Class 1 Class 2 Class 3

GM T1 100.00% 0.00% 0.00% 0.00%

GM T11A 97.00% 3.00% 0.00% 0.00%

GM T11B 100.00% 0.00% 0.00% 0.00%

GM T12 100.00% 0.00% 0.00% 0.00%

GM T18 100.00% 0.00% 0.00% 0.00%

GM T28 97.00% 3.00% 0.00% 0.00%

GM T29 100.00% 0.00% 0.00% 0.00%

GM T30 93.00% 3.00% 3.00% 0.00%

GM T32 100.00% 0.00% 0.00% 0.00%

GM T35 97.00% 3.00% 0.00% 0.00%

GM Rx6 100.00% 0.00% 0.00% 0.00%

Table 62. Forest floor summary

Forest Floor Summary

GM T1 GM T11A GM T11B GM T12 GM T18 GM T28

Mean: 4.4 Mean: 3.97 Mean: 4.13 Mean: 5.07 Mean: 7.3 Mean: 4.8

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

3.70 5.10 3.11 4.82 3.19 5.08 4.17 5.97 6.37 8.23 3.95 5.65

GM T29 GM T30 GM T32 GM T35 GM Rx6 Mean: 4.80

Mean: 3.7 Mean: 3.97 Mean: 5.23 Mean: 5.8 Mean: 4.47

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

3.22 4.18 3.42 4.52 4.45 6.02 4.80 6.80 3.71 5.22

Table 63. Forest slope summary

Forest Slope Summary

GM T1 GM T11A GM T11B GM T12 GM T18 GM T28

Mean: 17.1 Mean: 26.57 Mean: 12.2 Mean: Mean: 22.97 Mean: 16.27

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

15.19 19.01 23.80 29.34 10.83 13.57 21.08 24.85 14.08 18.46

GM T29 GM T30 GM T32 GM T35 GM Rx6 Mean: 16.65

Mean: 12.43 Mean: 7.83 Mean: 14.97 Mean: 18.9 Mean: 17.3

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

10.94 13.92 6.49 9.17 11.72 18.21 17.49 20.31 15.66 18.94
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 336 Appendix C

Table 64. Large woody debris (LWD) summary

Large Woody Debris (LWD)

Soil Transect Points/Transect Points/Acre

GM T1 9 22.5

GM T11A 16 40

GM T11B N/A N/A

GM T12 13 32.5

GM T18 28 70

GM T28 11 27.5

GM T29 9 22.5

GM T30 8 20

GM T32 9 22.5

GM T35 17 42.5

GM Rx6 13 32.5

Average LWD Points/Acre 33.25

Table 65. Summary of meadow encroachment for the selected meadows in the Greys 

Mountain Project area

Meadow Encroachment

Meadow Area in 1944 

(Acres)

Area in 2008 

(Acres)

Change in Area 

(Acres)

Percent Change in 

Area

Clas

s

504M13

2 1.55 1.10 0.45 28.96% 5

504M29

3 6.32 4.3 2.02 31.95% 5

504M21

1 4.98 3.64 1.34 26.87% 5

504M21

2 1.16 0.46 0.70 60.19% 6

503M7 11.84 8.09 3.75 31.69% 5

504M23

3 2.57 2.89 -0.32 -12.57% 1
Sierra National Forest – 337 Appendix C 

Soil Transect Visual Indicators Confidence Intervals

Table 66. Soil transect data for T units 1, 11, 12, 18 and 28

Confidence Interval: 80 & ME: 10

GM T1 GM T11A GM T11B GM T12 GM T18 GM T28

Confidence Interval Confidence Interval Confidence Interval Confidence Interval Confidence Interval Confidence Interval

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Forest floor Impacted? 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Live Plant? 13.43% 33.23% 0.83% 12.51% 7.94% 25.39% 10.64% 29.36% 0.83% 12.51% 5.38% 21.29%

Invasive Plant? 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Fine Woody? <7 cm 59.27% 80.73% 22.30% 44.37% 41.66% 65.01% 38.30% 61.70% 38.30% 61.70% 45.07% 68.27%

Coarse Woody? >7cm 0.83% 12.51% 0.83% 12.51% 0.83% 12.51% 0.00% 7.53% 0.83% 12.51% 0.00% 0.00%

Bare Soil? 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Rock? 0.00% 0.00% 0.00% 7.53% 0.00% 0.00% 22.30% 44.37% 0.00% 0.00% 0.00% 0.00%

Topsoil displacement? 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Erosion?, comment! 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Rutting? <5cm 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Rutting? 5-10cm 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Rutting? >10cm 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Burning light 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Burning moderate 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Burning severe 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Compaction? 0-10 cm 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Compaction? 10-30 cm 0.00% 0.00% 0.00% 7.53% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Compaction? >30cm 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Platy/Massive/Puddled structure 

0-10 cm 0.00% 0.00% 0.00% 7.53% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Platy/Massive/Puddled structure 

10-30 cm 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Platy/Massive/Puddled structure 

>30 cm 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 338 Appendix C

Table 67. Soil transect data for T units 29, 30, 32, 35, and 36

Confidence Interval: 80 & ME: 10

GM T29 GM T30 GM T32 GM T35 GM Rx6

Confidence Interval Confidence Interval Confidence Interval Confidence Interval Confidence Interval

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Lower 

Bound

Upper 

Bound

Forest floor Impacted? 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Live Plant? 7.94% 25.39% 25.39% 47.95% 45.07% 68.27% 5.38% 21.29% 22.30% 44.37%

Invasive Plant? 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 7.53%

Fine Woody? <7 cm 45.07% 68.27% 16.32% 37.02% 25.39% 47.95% 45.07% 68.27% 10.64% 29.36%

Coarse Woody? >7cm 0.00% 7.53% 0.00% 7.53% 0.00% 0.00% 0.83% 12.51% 0.00% 0.00%

Bare Soil? 0.00% 0.00% 2.98% 17.02% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Rock? 0.83% 12.51% 0.00% 7.53% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Topsoil displacement? 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Erosion?, comment! 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Rutting? <5cm 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Rutting? 5-10cm 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Rutting? >10cm 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Burning light 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Burning moderate 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Burning severe 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Compaction? 0-10 cm 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Compaction? 10-30 cm 0.00% 7.53% 0.00% 7.53% 0.00% 0.00% 0.00% 7.53% 0.00% 0.00%

Compaction? >30cm 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Platy/Massive/Puddled structure 0-

10 cm 0.00% 7.53% 0.00% 7.53% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Platy/Massive/Puddled structure 10-

30 cm 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Platy/Massive/Puddled structure >30 

cm 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%
Sierra National Forest – 339 Appendix D 

Appendix D – Data Tables for Greys Mountain Project

Greys Mt. Plot Data Summary Table 

Existing and Proposed Action Conditions

The Greys Mt. plot data summary table displays plot data collected within the proposed treatment 

areas displayed on the Greys Mt. EIS map. Variable plots were taken using a 30 Basal Area 

Factor prism for trees 10 inches dbh and larger. Only trees 10 inches dbh and larger were 

included in these tables. Plots were placed evenly across proposed treatment areas. Since these 

plots covered all the area within most treatment polygons and due to the wide variability of 

vegetation present, plots representing non treatment aggregations are present as a part of this 

sample. These non treatment plots would tend to lower the overall average existing basal area in 

these stands. The data presented here is an average of all the plots within a treatment area. Plot 

conditions varied widely from a basal area low of 90 ft2 to 520 ft2 per acre. Fixed plot data 

recorded variations in trees 2 inches dbh and larger per acre ranging from 15 trees to hundreds per 

acre. In some plots no small trees were captured in the sample while in others hundreds per acre 

were. Several plots represent “groupings of conifers with increased BA retention (20-30” dbh)”

similar to those retained in the Cedar Valley, Sugar Pine, and Fish Camp project areas. The 

column labeled “No. Plots” displays the number of plots within each grouping. 

Between 1881 and 1892 a mill in the Soquel area operated by the Madera Flume and Trading 

Company harvested timber within the project area. The majority of the Greys Mt. project area 

was heavily railroad logged between 1926 and 1927. Logs were processed at the mill at Sugar 

Pine. The 1944 aerial photos provide a graphic display of the extent of that activity. Scattered 

older trees were left following logging. The vast majority of conifers present today were 

seedlings and saplings present in the understory that survived the logging entry. Several 

plantations within the project area were planted in the late 1960s at the tail end of a concerted 

effort to reforest understocked areas. A number of additional conifer plantations were created 

between the 1980s and early 1990s. Approximately 1450 acres of plantations are present within 

the project area. Stands proposed for treatment average 90 to 110 years of age. Overall average 

site quality sampled is a Dunning 1. 

Plot data indicates that stands proposed for thinning consist mostly of pine and mixed conifer 

cover. Stands heavy to white fir are found in only a few small areas. Since these stands 

originated from advance reproduction present in the understory during the railroad logging era, 

they are heavy to shade tolerant, more fire prone, species of incense cedar and white fir. 

The mean diameter shown for these plots was taken from data runs utilizing the plot data 

collected. The leave mean diameter was taken from the projected leave basal area and projected 

number of leave trees per acre 10 inches dbh and larger. (Generally, mean leave diameters will 

be somewhat lower when leave trees less than 10 inches dbh are included in the calculation. It is 

very doubtful that any unit will have an 8 inch or larger increase in average diameter following 

treatment.) Since this data is a representative sample of aggregations found in the stands, it is not 

intended to imply that any particular unit averages a particular diameter, basal area or crown 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 340 Appendix D

closure. As can be seen from the data sampled, the average diameter following treatment will be 

larger than before due to the removal of many small trees per acre across treatment units.

The plot data and summaries shown provide insight into the variability of the vegetation present 

within the proposed treatment areas. During collection of the plot data, trees that might be 

selected for removal under the proposed thinning prescription for that species composition were 

noted. From that data, potential leave and cut basal area leave and cut tree sizes and numbers and 

existing and post harvest crown closures were determined. On a number of plots, for various 

reasons, leave basal area exceeds targets for that species composition. 

Legend for Greys Mt. Plot Data Summary Tables

Location:

Number corresponds to the Treatment Area Number on Project Map where the majority of these aggregations 

are present. (Each treatment area has more than one aggregation. Stocking levels, crown closures,

and diameters within treatment areas vary by the aggregation present.)

(MC) represents an area that is considered a Mixed Conifer dominated stand

(PP) pine dominated stands 

(WF) represents an area that is considered a White Fir dominated stand

Species Composition:

PP Ponderosa Pine

SP Sugar Pine

WF White Fir

IC Incense Cedar

OK Oak

Crown Closure:

Given in percent.

CWHR relationship for crown closure designation

P 25-39%

M 40-59%

D 60% +

Desired Basal Area for comparison is:

Pine dominated wild Stands = 150-180 ft2/acre

Mixed Conifer (MC) dominated Stands = 210 ft2/acre

White Fir (WF) dominated Stands = 240 ft2/acre 

For Alternative 3 a surrogate of 10 inches dbh was used to display the changes that would 

occur based on only removing ladder fuels in wild stands. 

Since trees to be removed in wild stands would be either intermediate or suppressed, overall

crown closures following treatment will not significantly change. Since no trees 10 inches and larger would 

be removed under this alternative, density management would not take place. Post treatment basal areas and 

trees per acre would remain essentially the same as before treatment.
Sierra National Forest – 341 Appendix D 

Table 68. Conifer Plot Data Tables

Location Species Composition Age Site Trees 10" & larger Basal Area 10" & larger Crown Closure Mean

Leave 

Mean 

Dia No.

PP SP IC WF OK Total

Cut 

10-

15

Cut

16-19

Cut 

20-

25

Cut

26-29

Lv

20-

29

Tot 

Lv Total Cut 

10-19

Cut

20-25

Cu

26-

29

Lv

20-

29

Tot 

Lv Before After Dia Dia Plots

1 6 6 33 55 0 80 1 81 14 9 12 4 36 42 266 30 30 17 180 189 61(D) 50(M) 24.5 28.7 7

2 25 8 35 17 15 108 3 93 9 0 1 1 33 82 200 7 4 4 119 185 79(D) 78(D) 15.6 20.3 8

3 24 42 11 23 0 84 3 92 2 0 0 0 30 90 211 3 0 0 146 208 74(D) 73(D) 15.9 20.6 9

4 16 15 33 34 2 81 1 68 17 12 6 0 30 33 217 37 19 0 157 161 71(D) 64(D) 20.8 29.9 8

5 3 12 26 53 6 81 2 52 0 3 7 1 27 41 170 5 20 5 120 140 56(M) 51(M) 22.9 25.0 6

6 79

7 47 6 22 15 10 89 2 55 0 2 4 2 33 47 188 4 11 7 142 165 62(D) 59(D) 23.8 25.4 8

8 38 16 20 17 9 82 3 105 20 3 1 0 26 81 192 22 3 0 99 167 74(D) 70(D) 15.8 19.4 18

9 14 7 33 41 5 93 2 124 32 8 8 2 38 74 278 43 20 8 160 207 79(D) 71(D) 17.3 22.7 18

10 22 10 20 43 5 77 2 82 4 0 1 0 20 77 150 4 4 0 75 142 70(D) 69(D) 17.1 20.2 8

11 0 0 0 100 0 68 2 77 0 0 0 0 37 77 225 0 0 0 175 225 68(D) 68(D) 19.5 19.5 8

12 0 25 0 75 0 83 3 86 3 4 4 0 23 74 199 11 11 0 123 176 57(M) 52(M) 18 20.9 6

13 0 8 83 9 0 65

14 0 5 0 95 0 91 2 138 33 12 3 1 30 89 260 50 10 3 140 197 77(D) 69(D) 16.8 20.1 9

Rx15 13 15 25 32 15 94 3 60 0 0 0 0 32 60 199 0 0 0 166 199 67(D) 67(D) 20.4 20.4 8

16 22 13 36 25 4 101 1 120 25 13 9 1 44 72 294 46 22 6 184 220 77(D) 67(D) 19.2 23.7 19

Note: The data displayed above represents an average of the vegetation present within a particular treatment area. Due to variability of the vegetation present,

Other aggregations are also present within treatment areas. Refer to the description and legend pages for more detailed explanations. (Data not run for units 6 and 13).

(A number of aggregations combine to form a stand.) (Rx 15 light underburn 

only)
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 342 Appendix D

Location Species Composition Age Site Trees 10" & larger Basal Area 10" & larger

Crown 

Closure Mean

Leave 

Mean No.

PP SP IC WF OK Total Cut 

10-15

Cut 

16-19

Cut 

20-25

Cut 

26-29

Lv 

20-29

Tot 

Lv Total Cut 

10-19

Cut 

20-25

Cut

26-29

Lv 

20-29

Tot 

Lv Before After Dia Dia Plots

17 30 10 30 26 4 94 3 75 11 4 1 0 26 58 190 20 3 0 124 167 72(D) 69(D) 20.3 23.0 8

18 30 5 31 24 10 80 2 79 0 0 0 0 36 79 205 0 0 0 150 205 77(D) 77(D) 19.5 19.5 6

19 2 22 40 12 24 76 3 104 12 3 4 1 29 84 250 15 10 5 150 220 88(D) 86(D) 17.8 21.9 6

20 0 5 41 45 9 68 1 75 11 2 0 1 34 61 207 15 0 5 160 197 70(D) 67(D) 19.2 20.2 6

21 31 17 15 32 5 85 1 79 17 5 2 1 33 54 197 22 4 4 146 167 67(D) 62(D) 18.2 23.8 7

Rx22 53 6 25 14 2 86 1 77 0 0 0 0 61 77 255 0 0 0 230 255 72(D) 72(D) 24 24.0 6

Rx23 13 13 37 13 24 121 1 72 0 0 0 0 32 72 190 25 0 0 140 190 69(D) 69(D) 21.5 21.5 6

Rx24 66 5 5 5 19 156 2 47 0 0 0 0 42 47 210 0 0 0 200 210 73(D) 73(D) 26.7 26.7 3

26 4 0 29 67 0 79 1 155 54 0 34 0 40 67 360 45 90 0 190 225 75(D) 61(D) 16.9 24.8 2

27 11 5 17 66 0 88 1 125 46 13 23 4 39 39 383 68 64 18 233 233 72(D) 60(D) 22 33.1 8

28 0 6 47 47 0 98 1 111 43 5 19 2 43 43 380 50 60 10 260 260 75(D) 61(D) 23 33.2 3

29 1 1 47 51 0 91 1 119 24 13 13 2 42 67 313 43 34 9 193 227 70(D) 60(D) 20.2 24.9 7

30 5 2 33 58 2 97 1 122 34 21 2 4 35 61 285 70 5 15 165 195 73(D) 61(D) 18.7 24.2 6

31 & 32 0 38 11 51 0 90 1 89 14 18 7 4 31 46 314 44 18 16 219 235 76(D) 67(D) 22.4 30.6 13

33 3 14 32 50 1 92 1 105 25 9 6 1 39 64 273 33 15 5 188 220 70(D) 61(D) 20.6 25.1 18

34 12 9 47 29 3 92 1 105 21 27 17 2 38 38 340 70 50 10 210 210 71(D) 60(D) 23.6 31.8 3

35 2 36 24 38 0 109 1 117 29 24 0 0 47 64 334 64 0 0 270 270 75(D) 72(D) 20.2 27.8 8

37PAC 1 4 37 58 0 93 1 134 42 20 0 0 72 72 401 75 0 0 326 326 80(D) 76(D) 23 28.8 8

37 1 4 37 58 0 93 1 134 42 20 17 3 52 52 401 75 40 12 274 274 80(D) 72(D) 23 31.1 8

38 2 26 31 41 0 82 1 102 30 18 13 1 33 40 312 57 37 3 200 212 75(D) 62(D) 22 31.2 9

39 56 6 34 4 0 82 2 89 0 3 0 0 32 76 196 5 0 0 125 191 68(D) 67(D) 18 21.4 6

Note: The data displayed above represents an average of the vegetation present within a particular treatment area. Due to variability of the vegetation present,

other aggregations are also present within treatment areas. Refer to the description and legend pages for more detailed explanations.

T33 & T37 have numerous larger tree groups. (A number of aggregations combine to form a stand.) (T18 changed to light underburn only) (Rx 22, 23 & 24 light underburn only)
Sierra National Forest – 343 Appendix E 

Appendix E – Proposed Treatment Acres 

Table 69 Proposed Treatment Acres by Area and Method

Treatment 

#

Commercial 

Thinning

Commercial 

Thinning in 

Fuelbreak

Commercial 

Thinning 

Total Acres

Potential 

Precommercial 

Thinning by 

Mastication or 

Hand thin w/Dozer 

Piling

Mastication

Prescribed 

Burning 

(Post 

Thinning)

Prescribed 

Burning 

Only 

Treatment

Precommercial 

Thinning 

w/Hand Piling

Meadow 

Conifer 

Removal

Reforestation Noxious 

Weed 

Eradication

Analyzes

Area 

Total

T-1 34 34 7 41 41

T-2 76 76 21 97 97

T-3 25 25 27 52

T-4 117 117 19 136 136

T-5 1 5 6 6 6

T-6 27 27 147 174

T-7 13 13 13 13

T-8 137 58 195 75 270 270

T-9 147 147 87 234 234

T-10 38 38 52 90 90

T-11 0 48 48

T-12 15 15 26 41

T-13 2 2 1 3

T-14 34 34 13 47

T-16 124 86 210 65 275 275

T-17 22 22 32 54 54

T-19 15 15 9 24

T-20 31 31 31

T-21 7 26 33 6 39 39

T-26 9 19 28 28 28

T-27 20 20 25 45

T-28 19 19 19

T-29 29 29 5 34

T-30 16 16 3 19 19

T-31 43 43 10 53 53

T-32 29 29 5 34 34

T-33 133 133 116 249 249

T-34 4 4 12 16

T-35 34 34 11 45 45

T-37 48 48 13 61

T-38 47 47 47 94 94

T-39 45 45 45 45

Nonstocked 

Areas 

(Within T 

Areas)

50 50

Subtotal 1341 194 1535 882 1822 50 2467

FX-9 97 97

Subtotal 97 97
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 344 Appendix E

Treatment # Commercial 

Thinning

Commercial 

Thinning in 

Fuelbreak

Commercial 

Thinning Total 

Acres

Potential 

Precommercial 

Thinning Mastication or 

Hand thin w/Dozer 

Piling

Mastication

Prescribed 

Burning (Post 

Thinning)

Prescribed 

Burning Only 

Treatment

Precommercial 

Thinning w/Hand 

Piling

Meadow 

Conifer 

Removal

Reforestation

Noxious 

Weed 

Eradication

Analyzes

Area Total

T-18 30 30

RX-1 133 133

RX-2 91 91

RX-3 43 43

RX-4 49 49

RX-5 13 13

RX-6 12 12

RX-7 35 35

RX-15 35 35

RX-22 30 30

RX-23 11 11

RX-24 17 17

Subtotal 499 499

H-1 13 13

H-2 15 15 15

H-3 10 10 10

H-4 8 8 8

H-5 29 29

H-6 15 15

H-7 10 10

H-8 (Progeny) 24 24

Subtotal 33 124 124

M-1 33 33

M-2 92 92

M-3 23 23

M-4 120 120

M-5 26 26

M-6 24 24

Subtotal 318 318

Mdw 503M7 3 3

Mdw 503M8 0.9 0.9

Mdw 504M132 1.2 1.2

Mdw 504M198 2.4 2.4

Mdw 504M208 0.1 0.1

Mdw 504M209 0.9 0.9

Mdw 504M293 2 2

Subtotal 10.5 10.5

Chilkoot CG 5 5

Greys Mountain CG 17 17

Texas Flat CG 9 9

Subtotal 31 31

Project Wide (As needed) 10 10

Subtotal 10 10

Grand Total 1372 194 1566 882 318 1855 ** 596 124 10.5 50 10 3556.5

** The acreage burned will be over the same thinned acreage so this will not be double counted in the grand total of the acres. Only the bold numbers were summed for total. Estimated commercial 

thinning acreages do not include SMZs, archaeological sites, large tree groups and other aggregations where commercial thinning will not occur within potential treatment areas. 30 percent of the 

estimated commercial thinning acreage may require post harvest precommercial thinning and dozer spot pile of slash concentrations.
Sierra National Forest – 345 Appendix F 

Appendix F -- Acronyms

• BLRD = Bass Lake Ranger District, Sierra National Forest

• CA = California

• CAR = Critical Aquatic Refuge

• CO = County

• CWHR = California Department of Fish and Game’s California Wildlife Habitat 

Relationships program

• Elev = Elevation

• HSRD = High Sierra Ranger District, Sierra National Forest

• HUC = Hydrologic Unit Code (watershed delineations)

• Mi = Mile

• NF = National Forest

• SJ = San Joaquin

• SJR = San Joaquin River

• Tribs = Tributaries

• USDI = US Department of Interior, Fish and Wildlife Service
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 346 Appendix G 

Appendix G – Response to Public Comments

• Numbering is not sequential in some cases as some comments were consolidated after initial comment identification and numbering. No comments have 

been deleted. 

Sierra Forest Products Kirby Molen 1/16/12

Comment

Number

Comment Comment 

Topic

General Response

SFPKM-1 I would strongly suggest that bids for the 

removal of the timber under a timber sale 

contract be conducted as an oral auction.

NEPA 

The commenter requests that an oral auction process be used for timber sale 

contracting. Forest Service Manual (FSM) 2431.41 directs the Forest to use sealed 

bids and therefore it is against Forest Service policy to utilize an oral auction process. 

FSM 2400TimberManagement, Chapter 2430 – Commercial Timber Sales, R5 

Supplement 2400-2010-4 Effective 12/21/2010 page 9 of 14, “2431.41 – Bidding 

Method Use sealed bidding methods for all competitive sales.”

Additionally the Project may be an Integrated Resources Timber Contract, 2400-13, 

for which the Forest Service does not have ”public bid openings”(sealed bid or oral 

auction), instead the Forest Service solicits proposals from the public. FSH 2409.19 

Renewable Resources Handbook, Chapter 60 – Stewardship Contracting, 2409.19-

2008-7.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 347 Appendix G 

Sierra Forest Products Larry Duysen 1/26/12

Comment

Number

Comment Comment 

Topic

General Response

SFPLD-1

Our only additional comment is to 

encourage a thorough economic analysis 

of stand treatment and road reconstruction 

options to insure the project has the 

highest possible economic viability.

Timber

The commenter requests that a thorough economic analysis be displayed in the FEIS. 

Forest Service policy on economic analysis includes:

• FSM 2420.3 – Policy – “1. Except for Region 10, Regions shall use the 

transaction evidence appraisal method as the primary timber appraisal 

method. Region 10 shall use the appraisal method approved by the Chief.”

• FSH 2409.22 – Timber Appraisal Handbook – This handbook outlines 

procedures for TEAs to determine fair market value of timber by comparing 

recently sold sales to the sale being appraised.

• FSH 2409.18 Ch. 20 – Financial and Economic Analysis at Gate 1 (Timber 

Sale Planning)

• FSH 1909.17 – Economic and Social Analysis Handbook CH 10 – Evaluating 

Economic Efficiency

• FSM 1970.3 - Economic efficiency evaluations are required for project 

selection, functional planning, integrated planning, and budget preparation 

The DEIS economic analysis was conducted using National and Regional standards 

for valuation. An updated R5 Transactional Evidence Appraisal (TEA) was used to 

estimate the values, realizing that base indices may change by time of sale. A final 

TEA will be generated before the sale is advertised depicting the most current rates.

The R5 TEA adjusts sale value by appraisal items including, but not limited to:: 

Project Activity Levels (*PAL ) Fire Protection, Stump-To-Truck costs per ccf, haul 

cost, construction of landings, road reconstruction, road maintenance (pre, during, and 

post-haul), estimated temporary roads, or any other special work item. The appraisal 

considers the use of mechanized equipment to harvest standing timber.

*Project Activity Level - PAL is a scientifically-based “decision support process” to 

provide a fire precautionary system for industrial operations on National Forest lands 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 348 Appendix G 

in California. Its goal is to balance the reduction in the ignition risk of large damaging 

wildfires with the accomplishment of resource (forest projects) management 

activities.

Average per mile road reconstruction costs were used based on similar past project 

costs. Other costs include erosion control, landing construction, and slash work.

In using the procedures for the R5 TEA, the economics analysis is in compliance with 

the policies stated above.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 349 Appendix G 

Sierra Club – Tehipite Chapter- Richard Kangas 1/27/12

Comment

Number

Comment Comment 

Topic

General Response

SC-1

We believe the two parts are distinct 

enough that they should be separated and 

planned under separate environmental 

impact statements. For that reason we 

will present comments in two separate 

sections.

NEPA 

The commenter requests that the EIS be split into two EISs since there are distinct 

actions being analyzed. 40 CFR 1508.25 (a)(3) states “Similar actions, which when 

viewed with other reasonably foreseeable or proposed agency actions, have 

similarities that provide a basis for evaluating their environmental consequences 

together, such as common timing or geography. An agency may wish to analyze 

these actions in the same impact statement. “ The WIN site restoration and the 

ecological health treatments are planned in the same “geography” and as funds allow 

could be performed in the same timeframe. The SNF views meadow restoration as a 

component of ecological restoration of the Greys Mountain Project area and therefore 

meadow restoration is part of the purpose and need for the Project. Thus, combining 

these treatments into one EIS is allowable under NEPA regulations and has been 

found to be warranted by the SNF due to geographic and timeframe similarities and to 

fully meet the ecological restoration goals of the Project.

SC-2

Cattle frequently cause such problems. 

Tree removal, step pools, and “plug and 

pond” (sic) (usually called pond and plug) 

are mentioned as possible remedies. We 

suggest that cattle be removed from the 

meadows so that bank chiseling by their 

hooves is ended.

Range

The suggestion that cattle be removed from the meadows is outside the scope of the 

proposed action since authorization of cattle grazing in the Project area is not part of 

the proposed action. Standard and guidelines for grazing are implemented under 

previous decisions for the Soquel and Central Camp allotments. Localized areas 

where in-channel watershed restoration activities occur would be temporarily 

excluded from grazing for up to a two year period as stated in Chapter 2 Design 

Criteria Common to all Alternatives of the FEIS.

SC-3

On p. 4 in one paragraph the DEIS says 

that meadows were degraded by past land 

use activities, BUT in the very next 

paragraph is written that such degradation 

Hydrology

The inconsistency has been corrected in the FEIS (Chapter 1, Existing Condition 

section).
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 350 Appendix G 

is by natural disturbance. That 

contradiction needs to be cleared up.

SC-4

At the DEIS stage there should already be 

a definitive plan for that meadow work. 

BUT THERE IS NOT. This meadow 

work is not well defined in the GMERP 

DEIS. 

Hydrology

The SNF has developed a definitive plan for meadow restoration which was included 

in the DEIS. Meadow restoration plans are detailed in the Chapter 2 “Meadow 

Restoration Plans” section of both the DEIS and FEIS.

SC-5

Meadow work is too complicated and 

significant to be involved in this already 

large and complex DEIS document. 

Meadow work should be removed from 

this DEIS and written completely in a 

separate environmental impact statement 

(EIS).

NEPA 

The commenter requests that the EIS be split into two EISs since there are distinct 

actions being analyzed. 40 CFR 1508.25 (a)(3) states “Similar actions, which when 

viewed with other reasonably foreseeable or proposed agency actions, have 

similarities that provide a basis for evaluating their environmental consequences 

together, such as common timing or geography. An agency may wish to analyze 

these actions in the same impact statement. “ The WIN site restoration and the 

ecological health treatments are planned in the same “geography” and as funds allow

could be performed in the same timeframe. The SNF views meadow restoration as a 

component of ecological restoration of the Greys Mountain Project area and therefore 

meadow restoration is part of the purpose and need for the Project. Thus, combining 

these treatments into one EIS is allowable under NEPA regulations and has been 

found to be warranted by the SNF due to geographic and timeframe similarities and to 

fully meet the ecological restoration goals of the Project.

SC-6

On p. 20 there are references to Appendix 

C for Log-and-Fabric Step Falls and for 

rock step pool structures. That is an error. 

That is currently in Appendix B – Best 

Management Practices Associated with 

Greys Mountain Project. 

Document 

Concerns This error has been noted and has been corrected in the FEIS.

SC-7

We suggest that pp 315 to 318 of 

NEPA 

Please see the response to SC-1 and SC-5 above. Based on the SNF’s decision to 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 351 Appendix G 

Appendix B should be removed and put 

into a separate new EIS for the meadow 

projects.

analyze the entire project as a whole to ecologically restore portions of the Greys 

Mountain Project area, the referenced pages of Appendix B will remain as part of the 

FEIS.

SC-8 Again, it is unclear in this DEIS what 

methods will be employed for the 

meadow restoration. 

Hydrology Specific restoration methodologies are detailed in the Chapter 2 “Restoration 

Methodology” section. The effects of all these techniques have been analyzed in the 

DEIS.

SC-9

On p. 315 of the current Appendix B this 

DEIS shows that plug and pond (sic) will 

not work well on meadows with gradients 

> 2% and that meadow gradients in this 

Project are mostly > 4%. The implication 

is that pond and plug will not be used. 

STILL, POND AND PLUG IS NOT 

RULED OUT. Another problem here is 

that there is no reference citation for those 

2% and 4% figures. 

Hydrology

The referenced statement has been revised to indicate that Plug and Pond 

methodology would not be used on the Project meadows.

A reference for meadow gradient thresholds for the Plug and Pond methodology has 

been added.

SC-10

Correct and complete reference citations 

and reference listing are required for 

clarity and scientific veracity. The 

current DEIS is thus neither clear nor 

scientifically founded on this point as 

required by the National Environmental 

Policy Act of 1969 (NEPA) and the 

National Forest Management Act of 1976 

(NFMA).

NEPA 

The SNF acknowledges that some reference citations and reference listings were 

omitted from the DEIS. Citations and reference listings have been added to the 

document where appropriate. A draft and comment system is designed to identify 

these omissions and correct them prior to a final decision being made. 

It is the SNF’s intent to show consideration of the best available science and insure 

the scientific integrity of the discussions and analyses in the Project EIS. 

Specifically, the Project EIS identifies methods used, references scientific sources 

relied on, discusses responsible opposing views, and discloses incomplete or 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 352 Appendix G 

unavailable information, as required under 40 CFR, 1502.9 (b), 1502.22, 1502.24.

The document and the project record references all scientific information considered: 

papers, reports, literature reviews, review citations, peer reviews, science consistency 

reviews, results of ground-based observations, and so on. 

As appropriate citations are included in the FEIS and the FEIS required components 

to document that the analysis is based on the best available science, FEIS is compliant 

with NEPA and NFMA.

SC-11

All the while there is (p. 203) “the need to 

restore both the structure and processes 

of old forest habitat ecosystems as a longterm strategy (sic) and with short-term 

goals (sic) of reducing the adverse effect 

of wildfire and reducing stand 

susceptibility to insects/pathogens, 

competition and drought-related tree 

mortality through density management. 

Note: The words “strategy” and “goals” 

should be reversed in this usage.

Silviculture

The words “strategy” and “goals” have been reversed in the FEIS as the commenter 

suggested.

SC-12

On p. 205 is written “For this proposed 

project, forested stands would meet 

stocking (as measured by percent of 

“normal” for the given site) and the 

associated density levels (as measured by 

basal area for a given site) that would 

maintain or improve growth rates, would 

Silviculture

The following definition of “Stand Density” is given on page 283 of the DEIS: “A 

quantitative measure of stocking expressed either absolutely in terms of number of 

trees, basal area, or volume per unit area or relative to some stand condition. A 

measure of the degree of crowding of trees within stocked areas commonly expressed 

by various growing space ratios.” Stand densities are a function of numbers and sizes 

of trees present. As stated throughout the DEIS, thinning from below would be 

utilized to obtain prescribed stocking levels. On page 210 of the DEIS it is stated: 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 353 Appendix G 

increase resistance to mortality agents 

(insects/pathogens/fire/drought) and 

would provide the potential to begin the 

perpetuation of both the structure and 

processes of old forest habitat ecosystems. 

This desired condition incorporates both 

short and long-term goals, but is focused 

on the need for continued maintenance of 

stands that are healthy and sustainable.”

That statement is to provide support for 

the removal of larger trees (stated 

elsewhere as up to 30-inch diameters) as 

product, while the long-term goal is to 

restore “old forest habitat ecosystems”. 

That is contradictory.

“Except where retained for wildlife purposes (see wildlife design criteria for 

descriptions), suppressed, intermediate, damaged and diseased then finally 

codominant trees, in order of removal, would be harvested until the prescribed 

stocking level has been reached. This is known as thinning from below as directed in 

the SNF LRMP as amended by the 2004 ROD and recommended in the North, et al, 

2009 paper.” On page 208, DEIS, it is stated that “Cochran and Barrett (1995) 

concluded that mortality in high (ponderosa pine) stand densities may be severe and 

individual tree sizes would be lower than in stands managed at lower densities. They 

stated: ‘thinning from below to low densities would speed up the development of 

large trees in second growth stands.’” “Thinning to the proposed basal areas would 

result in increased diameter growth and crown expansion on the remaining trees as the 

residual trees respond to reduced competition. Since increased diameter growth 

would occur over fewer stems per acre, substantial increases in diameter would result. 

Repeated thinning would result in larger diameter, taller, healthier crowned trees over 

much shorter time frames than in unthinned stands.” (DEIS, p211) Additional 

references of (Emmington, 1983)(Oliver, 1996) have been added to this section of the 

FEIS. On page 209 of the DEIS it is stated that Cochran and Barrett’s, 1999, 

“conclusions stated that density management (in second-growth ponderosa pine 

stands) ‘is necessary to speed development of mid and late seral size and density 

conditions.’” As stated in the DEIS, the stands present within the project boundaries 

are second growth—the result of early 1900s railroad logging. The larger trees being 

proposed for removal through this project are young, second growth trees that are 

smaller than those remaining in the stand. Inter-tree competition does not cease to 

exist when a particular diameter tree has been reached. As stated previously, this 

project would thin from below. The smaller diameter trees would be removed while 

leaving the larger in the stand. To meet the desired stocking levels following 

treatment, excess trees of varying diameters, up to 30 inches dbh, would be removed. 

Thinning will accelerate the growth of the remaining trees by freeing more water and 

nutrients for the residual stand to utilize. Increased growth and vigor will accelerate 

the development of larger diameter trees, one of the characteristics of old forest 

habitat.

SC-14*

Careful monitoring during and after 

implementation should be designed to 

NEPA 

The comment requests that pre- and post-implementation monitoring be planned to 

assure long-term goals are achieved. The SNF, through normal land management 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 354 Appendix G 

assure that the long-term goal is being 

achieved from the outset.

practices, makes determinations of goal attainment once the Project is completed via 

numerous trips to the Project site. These Project site visits are not normally 

characterized as monitoring however they serve the purpose of determining if short 

and long-term goals are attained.

• FSH 1909.15 Section 54 states “Agencies may provide for monitoring to 

assure that their decisions are carried out and should do so in important 

cases.” (Emphasis added).

The DEIS contains the appropriate Project monitoring needed as determined by the 

IDT in consideration of the scoping comments which can be found in the “Monitoring 

Plan” Section toward the end of Chapter 2. The Project effects have been analyzed 

based on the level of monitoring described in the DEIS. 

SC-15

We see that in the DEIS it is NOT (not 

among those listed above) proposed that 

very large, high quality timber will be 

restored to the ecosystem. We believe it 

should be. We believe that such 

restoration could be required under the 

Multiple-Use and Sustained-Yield Act of 

1960 or other laws.

Silviculture

Page 8 of the DEIS, under Proposed Action, states that the Project will be

“encouraging growth of larger dbh trees.” It further states: “Commercial and 

precommercial thinning treatments will allow leave trees to increase in growth in both 

height and diameter.” Thinning to achieve larger diameter trees is an objective of this 

Project as described as a part of the response to SC-12: “Since increased diameter 

growth would occur over fewer stems per acre, substantial increases in diameter 

would result. Repeated thinning would result in larger diameter, taller, healthier 

crowned trees over much shorter time frames than in unthinned stands.” (DEIS, 

p211). Through Project thinning practices, as explained above, very large, high 

quality timber would be restored to the ecosystem as the commenter agrees should 

occur.

SC-16

On p. 6, under the 4th bullet for Purpose 

and Need, the term “absence of fire” 

should read “suppression of fire”. 

Document 

Concerns The commenter recommends a change be made in the wording of the purpose and 

need statement changing “from absence of fire” to “suppression of fire.”
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 355 Appendix G 

The recommended change has been made to the FEIS. 

SC-17

At the bottom of p. 15 under Alternative 2 

– Proposed Action, the first landscape 

objective is written as requiring “unevenaged thinning”. We believe this should be 

changed to uneven-aged leave trees in 

proportion to Sierra Nevada forest history. 

This is supposed to be a landscape 

objective, NOT a treatment technique.

Silviculture

Under Alternative 2 – Proposed Action, the words “uneven aged” will be deleted as 

suggested. This section has been reworded to the following “...trees through 

thinning.” The objective is to increase the percentage of shade intolerant species 

(pines and oaks) by reducing the numbers of tolerant species (fir and incense cedar). 

Thinning would provide more growing space and sunlight for these shade intolerant 

species.

SC-18

On p. 16 under Alternative Description it 

is emphasized that 6,140 acres of the 

9,600 acre area will not be treated in the 

Project. We would like to see a statement 

as to when treatments to those acres have 

already been applied or will (future 

planning) likely be applied in the future. 

That would help to provide required 

accounting of cumulative impacts. For 

this purpose, please PROVIDE a map in 

Appendix A showing previous 

overlapping project areas, including any 

parts of these 9,600 acres. Also please 

PROVIDE a map showing the locations 

of historic (pre-Forest Service-planned) 

logging in the vicinity of these 9,600 

acres. The current Council on 

Environmental Quality (CEQ) guidelines 

(CEQ Memorandum of June 24, 2005, see 

p.57 of DEIS) for cumulative impacts 

provide a moving baseline. We do not 

believe that is legitimate. Even with that 

NEPA 

The commenter is concerned that the document does not adequately address 

cumulative effects particularly related to past actions as well as the proposed 

treatment of the acreage not proposed for treatment in this Project.

To address the second issue first, the SNF has no reasonably foreseeable projects to 

treat the untreated Project areas. The Project was designed to treat areas most 

amendable to the restoration of ecological health. Other factors such as the steepness 

of the terrain, accessibility for equipment to treat and the need for treatment were 

considered in the design of the Project. As these factors are not likely to change for 

many years to come, it is unlikely that the Forest will choose to do additional 

treatments in this area. Unless future projects are reasonably foreseeable they are not 

required to be factored into Project cumulative impact analysis.

As stated in the FEIS, “In order to understand the contribution of past actions to the 

cumulative effects of the proposed action and alternatives, this analysis relies on 

current environmental conditions as a proxy for the impacts of past actions. This is 

because existing conditions reflect the aggregate impact of all prior human actions 

and natural events that have affected the environment and might contribute to 

cumulative effects. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 356 Appendix G 

CEQ interpretation, we need to know of 

past projects in the area and of future 

project plans in the area. The Sierra 

National Forest will need to consider 

those, along with the present plan, in 

order to complete cumulative impacts 

analysis. 

This cumulative effects analysis does not attempt to quantify the effects of past 

human actions by adding up all prior actions on an action-by-action basis. There are 

several reasons for not taking this approach. First, a catalog and analysis of all past 

actions would be impractical to compile and unduly costly to obtain. Current 

conditions have been impacted by innumerable actions over the last century (and 

beyond), and trying to isolate the individual actions that continue to have residual 

impacts would be nearly impossible. Second, providing the details of past actions on 

an individual basis would not be useful to predict the cumulative effects of the 

proposed action or alternatives. In fact, focusing on individual actions would be less 

accurate than looking at existing conditions, because there is limited information on 

the environmental impacts of individual past actions, and one cannot reasonably 

identify each and every action over the last century that has contributed to current 

conditions. Additionally, focusing on the impacts of past human actions risks 

ignoring the important residual effects of past natural events, which may contribute to 

cumulative effects just as much as human actions. By looking at current conditions, 

we are sure to capture all the residual effects of past human actions and natural 

events, regardless of which particular action or event contributed those effects. Third, 

public scoping for this project did not identify any public interest or need for detailed 

information on individual past actions. Finally, the Council on Environmental 

Quality issued an interpretive memorandum on June 24, 2005 regarding analysis of 

past actions, which states, “agencies can conduct an adequate cumulative effects 

analysis by focusing on the current aggregate effects of past actions without delving 

into the historical details of individual past actions.” For these reasons, the analysis 

of past actions in this section is based on current environmental conditions.” A list of 

reasonably foreseeable future actions as well as current actions can be found in DEIS 

Table 8 found in the beginning of Chapter 3. Current and reasonably foreseeable 

future actions along with the current condition (serving as a proxy for past actions) 

were appropriately taken into consideration in the cumulative effects analysis. A map 

was drafted that displays the historic logging to 1931. This map was drafted to help 

graphically illustrate one of the main reasons for what created the existing forest 

conditions within the Project area. See map 19 in Appendix A.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 357 Appendix G 

SC-19

In Appendix A, Map 10 shows fires that 

occurred in the vicinity of the Project over 

the last 100 years or so. Please also 

PROVIDE a map in Appendix A showing 

locations and dates of fire starts that have 

been suppressed in the vicinity of the 

9,600 acres since 1900. That will help us 

understand the likelihood of fire in the 

Project area.

Document 

Concerns The commenter requests that a map be created to illustrate fire ignitions within the 

Project boundary. The requested map has been included in the FEIS (see Map 18 in 

Appendix A) showing the historic numbers of fire starts in the Project area.

SC-20

On p. 202, regarding tree ring studies, the 

DEIS refers to Ferrell (1996) in making a 

comparison of moisture in the 20th 

Century with that in the 19th and 18th

Centuries and with that now in the early 

21st Century. It is claimed that the 20th

Century, especially before the 1970’s was 

moister than the other times. Ferrell did 

not do a study on tree ring analysis nor 

climate change. His work was on pests 

and pathogens. In this Ferrell (1996) 

paper, he cited others (Fritts and Gordon, 

1980 and Fritts, Lofgren, and Gordon, 

1079) who had done studies with tree ring 

data. It would be better if those studies 

and perhaps more recent research papers 

were also cited in the DEIS.

Silviculture

The commenter states that Ferrell (1996) did not do a study on tree ring analysis nor 

climate change. His work was on pests and pathogens. The commenter further asks 

if other studies cited by Ferrell should be cited and possibly more recent research 

papers should also be cited. Several research papers, listed below, state that the 20th

Century was relatively moist. The FEIS, SNFPA Chapter 3, 2004, it is further stated 

that: “the period since 1890 has been one of moisture surplus.” 

Ferrell’s paper referenced the role drought and weather plays in relation to pests and 

pathogens. In this reference he stated that the 20th century was relatively moist 

compared to the prior two centuries. 

In the Sierra Nevada Ecosystem Project (SNEP), 1996, report Scott Stine stated “The 

period 1937-86 has been the third –wettest half century interval of the past 1,000 or 

more years.” These conclusions were made from studies of a combination of tree 

rings and lake levels. 

Graumlich (1991) stated that “the high precipitation levels of mid-20th century have 

occurred only three times in the previous 1000-yr record.” In Chapter 3, 2004 FEIS, 

it is further stated that: “the period since 1890 has been one of moisture surplus.”

These studies, covering up to 1000 years of precipitation levels, have led the Sierra to 

conclude that the 20th Century was relatively moist in comparison to previous time 

periods. The availability of this additional moisture and exclusion of fire provided 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 358 Appendix G 

conditions conducive to establishment of stand densities above what would normally 

be expected. A number of research papers have predicted that extended periods of 

moisture stress are likely in the future (Dettinger, 2004)(Stewart, et al., 2005)(van 

Mantgem, 2009)(SNFPA, 2004, ROD), Knowles, et al., 2006)(North, 2009). 

Maintaining resilient stands that can cope with the various effects resulting from the 

predicted continuing increases in temperatures and resultant extended periods of soil 

moisture stress, disclosed in the Climatic Shifts section of the DEIS, p. 202-203, is an 

objective of this Project. Obtaining more recent studies of past moisture levels to 

confirm or deny this conclusion was deemed not to be needed. The following was 

added to the Basal Area Stocking Levels section of the FEIS for clarity: These 

“normal” stocking levels were calculated during the abnormally wet 20th Century 

(SNFPA, 2004) and are likely too dense to be maintained during the predicted longer, 

hotter, more moisture stressed summer seasons that are predicted to occur as 

described in the Climate Shifts section. 

SC-21 NEVERTHELESS, we wonder if it is 

possible that after massive logging from 

the late 1800’s and into the first third of 

the 20th Century, there was less inter-tree 

competition for water and thus tree rings 

were wider until the overcrowding 

(brought on by fire suppression) of today.

Silviculture Although it is difficult to isolate the causes of the observations and the Sierra agrees 

less inter-tree competition results in more water availability, several researchers, 

identified above, have concluded from both tree ring and lake level data that climate 

patterns in the 20th Century were relatively moist compared to past centuries.

.

SC-22

We suppose that “undisturbed” likely 

includes fire-suppressed. Could not 

reintroduction of fire thin forests and thus 

allay such fears of “noncatastrophic” 

mortality rates? (Please note: HERE the 

word “noncatastrophic” seems to imply 

Silviculture

The commenter asks if reintroduction of fire alone could adequately thin forests and 

prevent noncatastrophic tree mortality rates. Reintroduction of fire vs. thinning will 

be covered further in other responses (SC-29, SC-30) however it is important to 

understand the relationship between fire exclusion and tree mortality rates and the 

basis for the DEIS’s use of the term “noncatastrophic” in relation to tree mortality 

rates. In the van Mantgem (2009) report, he states: “we therefore conclude that fire 

exclusion is an unlikely cause of the observed increases in mortality rates.” He 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 359 Appendix G 

that fire is catastrophic. further states: “regional warming may be the dominant contributor to the increase in 

tree mortality rates.” In a 2007 report van Mantgem states: “it is unlikely that 

increased mortality rate simply reflects a response to crowded understory conditions 

that have developed in the absence of fire in these historically fire-prone forests 

(Parsons & DeBenedetti (1979).” He further states: “we have provided the first 

demonstration of long-term chronic changes in demographic rates in otherwise 

undisturbed old-growth temperate forests, and have linked those changes to a possible 

climatic driver.” The report also states: “Our work contributes to a growing body of 

evidence indicating that ongoing environmental changes may be driving both chronic 

and acute changes in forests worldwide.” The term “noncatastrophic” was taken 

directly from van Mantgem’s report. It could be referring to a number of different 

events, not just fire (i.e. flood, insect attacks, etc.) as catastrophic. The Forest Service 

cannot speculate as to the researcher’s exact definition of this term. As stated 

previously, van Mantgem concludes that regional warming is triggering this mortality. 

His and other research papers point to climate change. His conclusions state that 

“mortality rates could presage substantial changes in forest structure, composition, 

and function, and in some cases could be symptomatic of forests that are stressed and 

vulnerable to abrupt dieback.” It is important to understand that the Project is needed 

and designed for many reasons, an important one of which is to “promote resilience to 

changing environmental conditions resulting from insects, disease, wildfire, and 

drought” (p. xi, DEIS) in the light of changing weather conditions and the resulting 

tree mortality as well as the consequences of predicted climate change. 

SC-23

In the next two sentences on p. 203 

(reference to Skinner and Stephens 

(2004)) it is predicted that the number of 

fire starts and the number of more intense 

fires will increase because of the current 

projections (i.e., predictions) of warming 

climate. AGAIN, in Appendix A, please 

provide a map showing locations of fire 

starts by date since 1900 for the Project 

vicinity.

Document 

Concerns The commenter requests that a map be created to illustrate fire ignitions within the 

Project boundary. The requested map has been included in the FEIS (see Map 18 in 

Appendix A) showing the historic numbers of fire starts in the Project area. Please 

also see response to comment SC-19.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 360 Appendix G 

SC-24

We suggest the natural solution to 

overcrowding is FIRE. Fire should be 

used more frequently and in more places 

as a natural and less expensive 

management tool. The National Parks in 

areas surrounding the Sierra National 

Forest have found fire use to meet their 

needs at a much lower cost.

Document 

Concerns The commenter suggests that fire should be used more frequently as the solution to 

overcrowding vegetation because it is cheaper and a natural process. The SNF agrees 

with the commenter. The proposed Project has planned to utilize prescribed fire as a 

treatment tool on approximately 2,451 acres. The restoration of fire as a natural 

process within this Project is a high priority but the existing conditions of fuel loading 

and vegetation density would create fire intensity and effects that would not meet the 

following purpose and need for this Project if fire alone was utilized:

• Improve resiliency in stands that are currently overstocked and are becoming 

more susceptible to attack from insects, diseases, drought conditions, and/or 

wildfire.

• Reduce the potential for undesirable damage from high intensity fire behavior 

to historical sites which are over grown with dense conifers and high fuels 

loads.

• Protect human communities from moderate/high intensity wild fires as well 

as minimize the spread of wildfires that might originate in urban areas into 

the forested lands created by unnaturally high levels of fuel ladders and dead 

and downed fuels. 

The reason that the first purpose and need bullet would not be achieved with fire only 

to reduce vegetation is that commercial thinning needs to be undertaken in portions of 

the approximately 90-110 year old young growth stands to reduce competition and 

provide room for crown expansion by removing the more poorly growing trees, 

excess trees, and fuel ladders from these stands before competition results in much 

additional reduction in growth or competition, insect, disease, drought or fire related 

mortality increases. Studies have shown that active management through thinning is 

critical to maintaining healthy trees that are less susceptible to mountain pine beetle 

attack. (DEIS p 207 my old version) Several studies have shown that thinning from 

below not only reduces ladder fuels and the risk of torching, but by reducing stand 

density tree vigor is improved and risk to bark beetle attack reduced (Fitzgerald, 

2005). By reducing competition through thinning, mistletoe infected residual trees 

would experience increased height growth thus slowing the upwards spread of 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 361 Appendix G 

mistletoe into tree crowns (Ferrell, 1996). By increasing tree vigor, diseased trees 

would be better able to withstand the effects of drought or insect attack. These 

purposes cannot be met through fire alone because by utilizing mechanical treatments, 

as in Alternative 2, stand structures are modified quickly and more precisely than with 

prescribed fire alone (North, 2009). Fire/Fuels Report. The reason that the third 

purpose and need bullet would not be achieved with fire only to reduce vegetation 

since the analysis shows that if a fire was to start in an area where these surface fuels 

have not been reduced, fire behavior would be increased (as represented by Fuel 

Model SB2). Under Project alternatives, mechanical treatments are effective in 

breaking up the horizontal and vertical continuity of live fuels in the lower canopy 

layers and/or in effect pre-treating the stands to more readily allow prescribed fire to 

be introduced subsequently. The SNF agrees that silvicultural cuttings can only 

partially substitute for fire (Weatherspoon, 1996) however Project mechanical 

treatments allow increased potential to utilize prescribed fire as either a maintenance 

treatment and/or in conjunction with mechanical treatments as a follow-up process to 

achieve forest resilience. Under the Project alternatives, prescribed fire, whether 

burning of piles and/or broadcast burns can be implemented with less risk of escape, 

with a broader range of acceptable conditions and in some cases less impacts to air 

quality (Weatherspoon, 1996). Fire/ Fuels Report. The Project allows increased 

potential to utilize prescribed fire as either a maintenance treatment and/or in 

conjunction with mechanical treatments as a follow-up process to achieve forest 

resilience. 

It is the SNF’s intention to use fire as a tool to restore Forest ecosystems as frequently 

as the conditions appropriately allow.

SC-25

To promote the long-term desire to restore 

old forest habitat ecosystems (paragraph 

above) most quickly, we must leave all 

those oldest trees AND many of the 

largest (old-cohorts) from the 90 -110 

year age class. Thereby, we believe NO 

TREES greater than 20 inches dbh 

should be removed. We also believe that 

Silviculture

The commenter states that it is important to retain all trees greater than 20 inches dbh 

to promote the long-term desire to restore old forest habitat. The DEIS displays the 

need to thin from below in these young second growth stands in order to obtain large, 

more fire resistant trees. The Project DEIS, p208, states the following: “Cochran and 

Barrett (1995) concluded that mortality in high (ponderosa pine) stand densities may 

be severe and individual tree sizes would be lower than in stands managed at lower 

densities. They stated: “thinning from below to low densities would speed up the 

development of large trees in second growth stands.” They further stated that “once 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 362 Appendix G 

fire must be reintroduced soon. stands reach commercial size, thinning to maintain low stand densities would be 

necessary to reduce the probability of serious problems with mountain pine beetles 

and perhaps western pine beetles (Dendroctonus brevicomis Le Conte).” In a followup paper, Cochran and Barrett (1999) concluded that mechanical thinning would 

result in greater stand and individual tree growth than would occur through bark 

beetle mortality that resulted in the same overall stand density. The conclusions 

stated that density management (in second-growth ponderosa pine stands) ‘is 

necessary to speed development of mid and late seral size and density conditions.’” 

Responses to SC-12 and SC-15 further describe the benefits of thinning from below 

in order to obtain larger diameter trees in a shorter period of time. Thinning from 

below generally leaves the largest trees in the stand. In addition, the DEIS p. 37 

describes the retention of 500 to 700 groups of dense larger diameter trees where 

trees 20 inches dbh and larger are retained in the group

SC-26 

On p. 203 of the DEIS Meyer (1938) is 

cited for stocking levels. The DEIS goes 

on to imply that stocking level figures in 

use (from Meyer) are wrong since they 

“were calculated during the abnormally 

wet 20th Century....” AGAIN, we suggest 

the “abnormal moistness” discussed in 

terms of tree ring width for the 20th

Century might have been due to decreased 

competition following tree removal in 

massive logging. 

Silviculture

The commenter is concerned that the Forest has inaccurately concluded that the last 

100 years were abnormally wet. The response to SC-20 describes Ferrell’s previously 

referenced paper as well as Stine’s report in the SNEP 1996 report, Graumlich (1991), 

and Chapter 3, SNFPA, 2004 FEIS stating that the 20th Century was one of abnormal 

wetness which was not related to decreased competition.

SC-27

The DEIS continues in the next sentence 

on p. 203: “Fairly recent studies have 

indicated that the exclusion of fire may 

Silviculture

The commenter notes that some citations have been omitted supporting DEIS 

conclusions. Citations have been added to the FEIS. (Kilgore,1979)(Parsons, 

1979)(Bouldin, 1999)(Fitzgerald, 2005)(Taylor, 2006)(North, 2009) 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 363 Appendix G 

have also resulted in normal basal area 

densities in excess of what would have 

been found during previous centuries.” 

(Yet, NO CITATIONS are given for the 

studies to support this idea.) 

SC-28

As we understand it, larger trees 

contribute much more basal area than do 

saplings. The historically larger number 

of large boles in previous centuries would 

have amounted to a much larger basal 

area per acre while undergrowth of 

saplings apparently was reduced by 

recurring fire.

Silviculture

The commenter states that larger trees contribute more to basal area than saplings and 

that because there were historically more large trees there would have historically 

been a greater basal area. Although it is correct that larger trees contribute more basal 

area per tree than saplings, the presettlement ponderosa pine forest structure was 

typified by open, park-like stands of large-diameter trees with few seedlings and 

saplings in the understory (Fitzgerald, 2005). Fitzgerald goes on to state that today 

there are above normal fuels accumulations and abundant tree regeneration. The 

overall basal area per acre in these open stands would generally be less than many of 

those found today.

North (2009) stated that reconstruction studies suggest that frequently burned forests 

had very low tree densities. He states that one study by Lieberg in 1902 found 

northern California forests to only be at 35 percent of their potential.

As previously stated, reconstruction studies suggest that presettlement pine dominated 

forests were more open, park like, and did not fully occupy the site. Although these 

shade intolerant trees were larger with more basal area per tree than most of those 

present today, the number per acre were low. Frequent low intensity fires minimized 

the growth of reproduction within most of the stand. The exclusion of fire and more 

moist conditions during the 20th Century have favored survival of an overabundance 

of more shade tolerant, fire susceptible fir and incense cedar. 

SC-29

We believe it would be better to introduce 

fire to thin out overcrowded younger 

stands. This would also remove lower 

Fuels 

The commenter suggests that fire would be a better thinning strategy than 15 – 20 

year thinning cycles. A thinning entry in 15 to 20 years is described as the probable 

next treatment in these stands. Entries beyond that probable treatment are not 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 364 Appendix G 

limbs to promote development of higher 

quality timber. Fire introduction right 

away would start progress toward the 

long-term goal sooner. Perpetual thinning 

every 15-20 years as suggested on p. 204 

would perpetuate the short-term strategies 

and slow development of the desired old 

forest habitat ecosystems.

described and may, or may not, be perpetual thinning every 15-20 years. Future 

treatments beyond the probable next entry are outside the scope of this document.

In the summary section of the Greys DEIS it is stated: “The ecological restoration 

goals of the Greys Mountain Project is multi-faceted and includes the following: (1) 

increase forest resilience to insects, disease, and drought through prescribed fire and 

mechanical thinning treatments...” 

The SNFPA 2004 describes the use of thinning from below as the primary 

silvicultural prescription to utilize in managing stand densities to provide resiliency 

and sustainability during drought conditions and climate variations (DEIS, p 205). 

Density management by thinning from below is proposed to be implemented as a part 

of the Greys Project.

Weatherspoon (SNEP, 1996) stated: “it is important to understand that the 

reintroduction of fire alone cannot restore millions of acres of degraded Sierra Nevada 

forests. Silvicultural techniques are needed in addition to or in lieu of fire in many 

areas to move conditions away from dense forests dominated by small trees and 

containing excessive fuels toward more open forests dominated by large trees.” 

Fitzgerald, 2005, states that prescribed burning is limited as a first entry fuels 

treatment because of heavy accumulations of surface and ladder fuels. His report 

recommends that other mechanical methods such as thinning, mowing, etc. are 

needed prior to burning. 

Research studies demonstrate that while prescribed fire is an important tool for 

reducing tree densities in the smaller size classes, the combination of understory 

thinning followed by prescribed burning is more effective at achieving ecological 

restoration objectives (such as reducing small-diameter tree densities, retaining 

greater densities of large-diameter trees, and increasing stand heterogeneity) than 

prescribed fire alone (Stephens et al. 2009, North et al. 2009, Evans et al. 2011). In 

addition, prescribed fire may not be an effective fuel treatment in coniferous forests of 

California unless sites are selected with an elevated fire hazard prior to treatment 

(Valliant et al. 2009). In the long-term, reintroduction of wildland fire would be the 

most effective restoration strategy following initial treatments using both mechanical 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 365 Appendix G 

and prescribed fire treatments.

SC-30 

On p. 205, the DEIS calls for thinning 

from below so leave trees could continue 

with more rapid growth. We suggest, 

again, that fire is cheaper and propels to 

the long-term desire more quickly.

Silviculture

The commenter suggests that fire would be a better strategy for achieving long term 

goals. Please refer to the response to SC-29. Weatherspoon’s SNEP 1996 report also 

states: “if fire alone were used, several sequential entries with prescribed fire would 

probably be necessary, especially in densely stocked stands with heavy fuel 

concentrations, before the desired forest conditions would be approached.” 

Agee, 2005, states that initial fires will create fuels by killing understory trees which 

may return to or exceed pre-burn levels within a decade. To accomplish a reentry 

burn to treat these new fuels, fuel loadings will need to be heavy enough to carry the 

fire and consume standing dead boles. A longer period of time will be needed to 

complete this by burning only than the proposed thinning treatments. 

Weatherspoon further states that thinning may significantly speed the movement 

toward desired forest stand structure and composition. 

As a part of the restoration effort and increasing stand heterogeneity, thinning as 

proposed is designed to retain shade intolerant ponderosa pine and sugar pine where 

healthy pines are present. Where these choices are available, shade tolerant incense 

cedar and fir would be priority for removal. Competition around selected oaks would 

be reduced through removal of competing conifers. Thinning through the use of fire 

is not very selective. Trees planned to be retained may be killed while those planned 

for removal may be retained. Reducing stand densities to the desired level would 

require a much hotter fire than proposed. The likelihood of loss of pines and oaks 

would be high. High mortality rates in smaller diameter trees would result in greatly 

reducing or eliminating hiding cover. Risk of escape would be substantially greater, 

prescribed burning costs would greatly increase as additional suppression forces 

would need to be present to ensure containment. Days available to accomplish these 

types of fire effects would be very limited due to approved smoke management burn 

days, availability of suppression forces, and other factors. Use of fire is not 

necessarily cheaper or faster than the proposed action. 

SC-31 Silviculture
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 366 Appendix G 

On p. 206 is stated: “Wide swings in 

climatic conditions as has been 

experienced over the past thirty years 

would continue to place increased stress 

on these untreated stands.” This 

statement shows misunderstanding of 

climate determination. To determine

climate, analysis considers 30 years of 

weather, NOT 30 years of climate 

changes. This misunderstanding appears 

several times in the DEIS.

The commenter asks that the FEIS use the term climate or climatic correctly. The 

wording in the FEIS has been changed. There is evidence for increased variability in 

select climate variables within the Sierra National Forest, such as increased variation 

in annual precipitation at Huntington Lake over the past 85 years of climate records 

(Western Regional Climate Center 2010). Temperature records in the SNF indicates a 

general warming trend (especially increasing mean minimum temp), especially over 

the past 30 years, that may be decreasing the diurnal temperature range (WWRC 

2010, LaDochy et al. 2007). 

In this particular sentence, it should state wide swings in weather, not climate. 

Although the conditions stated in this paragraph such as drought and rising 

temperatures are considered to be due to climate changes. The word “climatic” has 

been corrected to “weather”.

SC-32

Furthermore, on p. 4 of the DEIS climate 

analyses are alluded to for “past 

centuries” and for the “past 30 years”. 

We would like to see the analyses and 

their data sets. Please provide references 

citations and/or website links for those.

Silviculture

The commenter requests to have the FEIS include references for climate analyses. 

Ferrell’s 1996 paper referenced the role drought and weather plays in relation to pests 

and pathogens. In this reference he stated that the 20th century was relatively moist 

compared to the prior two centuries. In the Sierra Nevada Ecosystem Project (SNEP), 

1996, report Scott Stine stated “The period 1937-86 has been the third –wettest half 

century interval of the past 1,000 or more years.”

Graumlich (1991) stated that “the high precipitation levels of mid-20th century have 

occurred only three times in the previous 1000-yr record.” In Chapter 3, SNFPA, 

2004 FEIS, it is further stated that: “the period since 1890 has been one of moisture 

surplus.”

SC-33

On p. 206 of the DEIS, No Action implies 

no change from current direction. That 

implies continued fire suppression (and 

perhaps continued current logging 

strategies as well). Fire should be 

Silviculture 

& Fuels The commenter suggests that fire would be a better strategy for achieving long term 

goals and suggests that a fire-use only alternative be developed. Under the No Action 

alternative, nothing would be done. Management would not occur. The present fire 

suppression efforts would continue as directed under the LRMP. Until a new LRMP 

which includes a different approach to fire suppression is adopted, the current 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 367 Appendix G 

reintroduced to speed the process to 

achieve the long-term goal to restore old 

forest ecosystem habitats. A fire-use 

Alternative should be developed.

suppression policies remain in effect.

Research studies demonstrate that while prescribed fire is an important tool for 

reducing tree densities in the smaller size classes, the combination of understory 

thinning followed by prescribed burning is more effective at achieving ecological 

restoration objectives (such as reducing small-diameter tree densities, retaining 

greater densities of large-diameter trees, and increasing stand heterogeneity) than 

prescribed fire alone (Stephens et al. 2009, North et al. 2009, Evans et al. 2011). In 

addition, prescribed fire may not be an effective fuel treatment in coniferous forests of 

California unless sites are selected with an elevated fire hazard prior to treatment 

(Valliant et al. 2009). In the long-term, reintroduction of wildland fire will be the 

most effective restoration strategy following initial treatments using both mechanical 

and prescribed fire treatments. 

Additionally the DEIS addresses an alternative that would use landscape scale fires to 

manage fuels and vegetation instead of logging in the Chapter 2 section “Alternatives 

Considered but Eliminated from Detailed Study”. This alternative was eliminated 

because the use of prescribed fire alone would not meet the purpose and need for this 

project. On favorable terrain structural restoration needs would need to be completed 

mechanically with a follow-up with prescribed fire. Prescribed fire only treatments 

are planned for areas that are too steep for mechanical treatments and would link 

together treated areas to provide fuels modifications to help limit wildfire spread over 

large areas. The Project would treat over 2451 acres with prescribed fire.

SC-34 

On p. 207 of the DEIS, Alternative 2, the 

Proposed Action includes logging and 

prescribed burning and masticating. Will 

fire suppression then continue again after 

those treatments? We need to reintroduce 

fire as the continuing management 

strategy.

Silviculture 

& Fuels The commenter would like to know if fire suppression will continue after the Project 

and suggests that reintroduction of fire is a valuable management strategy. The 

present fire suppression efforts would continue as directed under the LRMP. Until a 

new LRMP, which includes a different approach to fire suppression, is adopted the 

current suppression policies remain in effect.

Research studies demonstrate that while prescribed fire is an important tool for 

reducing tree densities in the smaller size classes, the combination of understory 

thinning followed by prescribed burning is more effective at achieving ecological 

restoration objectives (such as reducing small-diameter tree densities, retaining 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 368 Appendix G 

greater densities of large-diameter trees, and increasing stand heterogeneity) than 

prescribed fire alone (Stephens et al. 2009, North et al. 2009, Evans et al. 2011). In 

addition, prescribed fire may not be an effective fuel treatment in coniferous forests of 

California unless sites are selected with an elevated fire hazard prior to treatment 

(Valliant et al. 2009). In the long-term, reintroduction of wildland fire will be the 

most effective restoration strategy following initial treatments using both mechanical 

and prescribed fire treatments.

SC-35

On p. 207, claims in the DEIS for Direct 

Effects, benefits of thinning are 

unfounded without citations to actual 

peer-reviewed reports. The writing is 

unclear. NEPA requires clarity.

NEPA /

Silviculture Please see comment SC-10 relating to lack of DEIS citations and NEPA sufficiency. 

Citations and reference listings have been added to the document where appropriate

As appropriate citations are included in the FEIS and the FEIS required components 

to document that the analysis is based on the best available science, FEIS is compliant 

with NEPA and NFMA. Numerous peer-reviewed reports substantiating the benefits 

of thinning are cited on pages 207 and 210 of the DEIS. (Feeney, 1998), (Fettig, 

2007), (Egan, 2010), (Fitzgerald, 2005), (Ferrell, 1996), (Cochran and Barrett, 1995), 

(Cochran and Barrett, 1999), (Oliver, 1995), (Sartwell, 1975), (Larrson, 1983), 

(Barrett, 1979), (Smith, 1962),(1986), (Emmingham, 1983), (Hurteau, 2009), (North, 

2009), (Long, 1985) DEIS p205, and (Long, 2005) DEIS p204. 

SC-36

All the claimed benefits (DEIS pp. 207-

211) for thinning from below sound good 

except that they are spiked with 

commercial thinning of trees up to 30 

inches dbh (Table 65, pp. 328-329), 

hardly simply thinning from below. We 

believe those large trees should remain in 

the forest. 

Silviculture

The commenter doubts that “thinning from below” included thinning trees up to 30 

inches dbh and states that large trees should remain in the Forest. The description of 

“thinning from below” is discussed under the response to SC-12. DEIS Table 65 

displays an estimate of tree sizes that may be removed where commercial thinning is 

conducted within various treatment areas within the Project area. 

A review of this information reveals the following:

Basal area: In most treatment areas where trees 20 inches dbh and larger are expected 

to be removed, approximately 3 to 4% of the basal area present in trees 20 inches and 

larger might be removed in the 26-29 inch dbh size classes. Another 10 to 16% of the 

existing basal area in trees 20 inches dbh and larger might be removed in the 20-25 

inch dbh size classes. Sampled data indicates that in all proposed treatment areas 

except 2 approximately 80 to 100% of the basal area of trees 20 inches and larger 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 369 Appendix G 

would remain in the stand following treatment. 

Trees per acre: In over 40% of the proposed treatment areas where commercial 

thinning is proposed, 0 to 2 trees per acre 20 inches dbh and larger are anticipated to 

be removed. 

As disclosed in the response to SC-25, there are also 500-700 groups of larger trees 

delineated within these treatment areas where no tree over 20 inches will be removed. 

In addition to the groups previously mentioned, Old Forest Linkage areas, 

archaeological sites, Stream Management Zones, rocky areas, etc. will also be 

vegetated with groups of trees where 20 inch dbh and larger trees have not been 

disturbed.

As described in SC-12, in “thinning from below”, trees remaining adjacent to these 

removal trees are generally larger than those being removed. Removal of these trees 

is needed to meet density management objectives. 

SC-37

On pp. 208-209 of the DEIS there is 

explanation for why reentry for thinning 

in 15 to 20 years was chosen. That 

explanation is without reference support. 

Such reentry for thinning would also 

allow more remaining larger trees to be 

extracted from above, not below.

Silviculture

The commenter identifies the need for citations for the stated reentry projections and 

believes that reentry would allow future extraction of large trees. Pages 203-206 of 

the DEIS describes the methodology for stand density management. Stand Density 

Index (SDI) as well as normal yield tables as well as their use are described. As 

mentioned in the comments, pages 208-209 provide an explanation on why the period 

of 15 to 20 years before reentry was chosen. As described in the DEIS a combination 

of basal area normal yield tables and SDI data were used to determine desired leave 

basal areas by species composition. Desired leave basal areas were determined by a 

Region 5 Certified Silviculturist/RPF. Figure 4 and Table 4 from Meyer (1938) and a 

figure from Smith (1962, 1986) displaying basal area thinning have been added to the 

FEIS Basal Area Stocking section to assist with clarity. . Standard professional 

methodology for determining residual basal areas was utilized. As previously 

disclosed, thinning is being done from below, not above. Leave trees are generally 

larger with more full crowns than those being removed. Trees proposed for removal, 

regardless of diameter, are in excess of the desired leave basal area.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 370 Appendix G 

SC-38

On p. 213 of the DEIS an explanation is 

needed for why mechanical treatments are 

not practical for Rx 1 and Rx 2 underburn 

units.

Silviculture 

& Fuels Mechanical treatments are not practical for Rx1 and Rx2 underburn units due to the 

location and slope present. Other than very expensive hand work, underburning is the 

only practical method available to tie treatment units together. To minimize ground 

disturbance, roads were used as the upper boundaries for the proposed burn units. 

The inability to use mechanical treatments in Rx 1 and Rx 2 due to the steep, broken 

ground has been clarified in the FEIS, Chapter 3

SC-39

Though we (Tehipite Chapter) have no 

doubt that denser stands would have more 

competition and water stress that could 

lead to insect and disease problems for the 

silviculturist (p. 214 of DEIS), we ALSO 

believe that such conditions in an 

unmanaged forest would lead to natural 

thinning. 

Silviculture

The commenter states that natural thinning results from more completion and water 

stress. Natural thinning does not meet the purpose and need of this project. It does 

not address the influence of drought and climatic variances on stand density and 

forest health. It does not meet the intent of the SNFPA 2004 ROD to undertake the 

following:

1) Density management necessary for healthy forests during drought conditions. 

Reduce mortality in dominant and codominant trees and tree density. 

2) Increase the frequency of large trees, increase structural diversity of 

vegetation, and improve continuity and distribution of old forest across the 

landscape.

3) retain the mix of mast producing species where they exist within a stand

4) promote shade intolerant pines (sugar and Ponderosa) and hardwoods

5) Actively restore fire-adapted ecosystems by making demonstrated progress in 

moving acres out of unnaturally dense conditions.

Natural thinning would favor retention of more fire prone shade tolerant fir and 

incense cedar. More densely stocked aggregations will put additional stress on all 

species, with or without, increased drought conditions. The stand density section of 

the DEIS, beginning on p203, points out the need to minimize exceeding the critical 

density threshold of stocking in pine aggregations. Depending on natural thinning to 

manage stocking will result in density levels exceeding this critical threshold resulting 

in a further reduction, rather than increase, in shade intolerant pine in the stand. 

Cochran and Barrett (1999) concluded that mechanical thinning would result in 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 371 Appendix G 

greater stand and individual tree growth than would occur through bark beetle 

mortality that resulted in the same overall stand density (DEIS p 208).

Natural thinning will shade out oaks and pines resulting in the retention of the more 

fire prone fir and incense cedar species and increase fuel loadings as trees die. 

SC-40

(Also, some reference citation errors need 

to be corrected on page 214.)

On p. 214 of the DEIS is stated: “Over 

the past 18 years, the district has planned 

and completed several projects, treating 

several thousand acres, similar to the 

proposed action. Canopy cover retention 

following harvest has met or exceeded 

expectations.” BUT the DEIS provides 

no reference citation to support that 

contention. 

Silviculture

The commenter states that references are needed on page 214 to support DEIS 

information. Canopy cover retention was reviewed through interpretation of aerial 

photos flown shortly after treatment and compared to aerial photos flown 6 or 7 years 

later. Photo interpretation was done by the Certified/RPF District Silviculturist. Field 

reviews confirmed the aerial photo work. Since the conclusion was based on 

professional judgment and not on research, no citations will be added.

SC-41

Furthermore, “expectations” are not 

explained here. For all the reader knows, 

the expectation was 0% in some treatment 

areas.

Silviculture

The commenter asks that the Forest’s “expectations” be disclosed. The expectation is 

that 50 to 60% canopy cover (where present prior to harvest) would be retained. This 

section has been clarified in the FEIS.

SC-42

On p. 215 of the DEIS, “several studies” 

are alluded to but not cited. In a 

following sentence Fettig (2008) is cited. 

It is unclear if those “several studies” 

were reviewed in Fettig (2008) or if the 

Fettig citation is for a separate idea.

Silviculture

The Fettig reference on p215 of the DEIS has been rewritten for the FEIS.

Several studies (Amman 1989; Bartos and Amman 1989; Schmid et al. 1992, 1995) 

have shown that in addition to increasing residual tree vigor, increasing temperatures 

and windspeeds are common in recently thinned stands. This may accelerate 

development of certain bark beetle species and force them to overwinter in stages that 

are more susceptible to freezing (Amman 1973, 1989) or cause turbulences that 

disrupt pheromone plumes used for recruiting conifer species during initial phases of 

host tree colonization (Thistle et al. 2004, 2005)(Fettig, 2008).
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 372 Appendix G 

SC-43

On pp. 214 to 215 of the DEIS there are a 

couple statements about plantations. 

Those statements make it unclear if that 

entire section is about only plantation 

stands or other stands as well. That needs 

to be clarified. Furthermore, such 

plantations are unnatural thickets 

promoted by silviculturists. The rest of 

the forest should not be treated the same 

way.

Silviculture

The plantation references have been clarified in the FEIS.

SC-44

There seems to be a lurch from p. 217 to 

p. 218 of the DEIS. Also, what is a 

“reference forest”?

Fuels

The Forest is unclear as to what the commenter meant by the phrase “a lurch” so not 

change was made in the document. “Reference forest” was incorrectly used and has 

been omitted from the FEIS.

SC-45

On p. 222 of the DEIS, WUI “sounds 

great”, but as we know larger, fire 

resistant trees will also be removed from 

the WUI. That should be stated. We, 

however, believe that such trees should be 

retained.

Fuels The commenter states that the FEIS should be clear that larger, fire resistant trees 

would be removed from WUI and large trees should be retained. Under the proposed 

action, the suppressed, intermediate and some co-dominates trees within a stand 

would be removed. The vegetation considered ladder fuels would be removed. 

Conifer species such as Ponderosa Pine and Sugar Pine, which are considered more 

fire resistant, would be favored to remain in a stand over shade tolerant and fire 

sensitive species, such as incense cedar and white fir. Incense cedar and white fir 

make up the largest percentage of conifers found in the understory of stands in the 

Greys Project area (based on sampled plot data) (DEIS page 237). The prioritization 

of tree selection has been fully disclosed in the DEIS. Retention of large trees has 

been addressed in comments SC-15, SC-25, SC-36 and SC-37.

SC-46 Fuels
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 373 Appendix G 

On p. 222 of the DEIS, references to 

Finney and Cohen (2003) and Cohen and 

Butler (1996) suggest that space around 

buildings with fuel reduction is crucial to 

prevent wildfire from igniting buildings. 

BUT the amount of space suggested by 

those authors in NOT stated. Over the 

years Cohen has stated that a 200-foot 

zone around buildings will virtually fireproof them if a fire resistant roof is 

installed and other fire-safe measures are 

taken. This is reviewed in a Forest 

Service video, “Protecting Your Home 

From Wildfire” that features Jack Cohen. 

Instead of promoting the 200-foot zone 

suggested by Cohen, the DEIS, on p. 222, 

provides an example from the 2011 

Wallow Fire (in Arizona). 

The commenter states that the Forest should address in the FEIS the amount of space 

on which fuel reduction is required around building to prevent wildfire from igniting 

buildings. We agree that amount of space suggested by Cohen of a 200–foot zone 

around buildings space is crucial. Though, Cohen and Butler also state that defensible 

space requires more vegetation fuel hazard reduction than fuels reductions required 

for preventing piloted wood ignitions.

Agency Wildland Urban Interface (WUI) fuel treatment largely do not address home 

ignitability but rather areas outside the home ignition zone. 

The Forest Service’s primary responsibility and objective for structure fire protection 

is to suppress wildfire before it reaches structure. (Forest Service Manual, 5137.02). 

Fuel treatment in the vicinity is expected to protect homes by creating conditions that 

enable successful fire suppression if a wildfire would to occur. Preventing WUI fire 

disasters require the problem be framed of home ignition potential. Because this 

principally involves the home ignition zone, the home ignition zone primarily falls 

within private ownership, the responsibility for preventing home ignition and 

installation of fire resistant roofs largely falls within the authority of the property 

owner (Cohen, 2008).

A method to reduce foreseeable hazards and increase the safety of suppression 

resources and activities can be accomplished in the combined efforts of strategically 

placed fuels treatment, as well as stewardship construction and landscaping completed 

by the land owner. This has proven effective during wildfire incidents including the 

Wallow Fire. Here, treatments served as a successful and effective ‘anchor point” and 

allow firefighters to safely attack the fire and enabled them to actively engage in fire 

suppression operation to protect homes and property. 

(page 222 & 223)

SC-47

In this, the DEIS alludes to half (1/2) mile 

wide fuel treatments above the 

community of Alpine (in Arizona) where 

crowning fire dropped from up in the 

trees to the surface level during the fire. 

Fuels

The commenter wonders if cooler temperatures and wetter elevations resulting in the 

“grounding” of fire rather than the previous fuels treatments. The “How Fuel 

Treatment Saved Home From The 2011 Wallow Fire” report describes that this 

wildfire fire burned when weather conditions were dry, relative humidity was low and 

high winds “red flag” conditions. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 374 Appendix G 

To us, this does not seem to have 

contributed to community protection. We 

would like to know if the fire settled to 

the ground solely because of previous 

thinning or if cooler and wetter higher 

elevations or aspects also had an effect, 

not just thinning. Alpine is at about 8,000 

feet in elevation. Mountains around there 

go to over 9,500 feet.

Report interview by Jim Aylor, Fire Management Officer, Alpine Fire District stated 

that “When the fire came over the ridge toward Alpine it sounded like a freight train. 

The smoke column was bent over making it difficult to see. Without the fuel 

treatment effects of reducing flame lengths and defensible space around most houses, 

we would have had to pull back our firefighters. Many of the houses would have 

caught fire and burned to the ground.”

Photos displayed in the report indicate that when the fire entered the White

Mountain Stewardship Fuel Treatment Area’s Alpine Wildland-Urban Interface Unit 

2. The fire transitioned from a crown fire to a surface fire—exhibiting far less burning 

intensity as it moved.

The report also states that as the main fire entered the 1⁄2 mile wide fuel treatments 

units located above the community of Alpine slowed this crowning fire by causing the 

blaze to dropped from up in the trees to the surface level. The fire rate of spread 

dramatically slowed and flame were low enough to allow firefighters to safely attack 

the fire and protect homes and property. (DEIS page 222 & 223). 

SC-48

On p. 223 of the DEIS under Desired 

Condition, the Southern Sierra Fisher 

Conservation Area is described for where 

fisher are present as having a minimum of 

60 % canopy cover in 50% of that forest 

area. No reference citation is given that 

explains why those number are used.

Fuels

The reference citation for the Southern Sierra Fisher Conservation Area (SNFPA 

ROD, 2004; page 41) is stated on DEIS page 223.

SC-49

On pp. 223-226 of the DEIS, 

methodologies for fire and fuels are 

covered. We have no doubt that these 

methodologies are based on best current 

natural science. BUT we believe this 

science is then trumped by economic 

NEPA 

The commenter shares concerns about the weighing of different resource factors and 

science versus economics. As stated in FSH 1909.15 Section 25.2 “CEQ 

requirements for a ROD are as follows: ....An agency may discuss preferences among 

alternatives based on relevant factors including economics and technical 

considerations and agency statutory missions.” The DEIS and FEIS appropriately 

display the effects of the alternatives. When the responsible official makes a decision 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 375 Appendix G 

decisions as seen in the economics section 

on pp 260-266 of the DEIS. 

his rationale for striking the balance between different factors is explained. This 

balancing of factors is not discussed in the environmental analysis. 

SC-50

A decision tree should be included in the 

FEIS and ROD for this GMERP Project 

to reveal rationales for treatment 

decisions. In particular we want to know 

why large trees (up to 30-inch dbh) will 

be logged while long-term desired 

condition is to restore old forest habitat 

ecosystems with significant numbers of 

larger fire-resistant trees.

NEPA 

As stated in the response to the previous comment, the ROD will articulate the factors 

weighed and balanced in coming to the final decision for this Project.

Please see the Forest Vegetation/Silviculture Section of the FEIS which discussed the 

desired conditions and how forest treatment meets the desired condition for Old 

Forest Habitat. 

Additionally the decision maker will consider an alternative (Alternative 3) that does 

not include the thinning of large trees. His decision will be based on the analysis of 

the purpose and need for action, the issues, the LRMP as amended and, current 

policies and regulations, the analysis of alternatives contained in the FEIS, public 

comments received, and other information in the project record.

SC-51

On p. 229, the DEIS suggests 

“successional setback” after fire “could 

pose negative consequences” and implies 

that reduces habitat heterogeneity. We 

believe that fire-induced successional 

setback also provides positive 

consequences by creating more 

heterogeneity of a different type and 

provides opportunities for renewed 

succession. Fires cause changes. Those 

changes contribute to heterogeneity.

Fuels

The commenter states that successional setback has positive consequences by creating 

more heterogeneity. It is true that fire in general causes change and these changes 

could contribute heterogeneity. The intensity of the fire causes differing effects to 

heterogeneity The DEIS on page 229) describes fire effects under existing conditions 

and the resulting negative consequences when crown fires and surface and ground 

fires with higher intensities occur if the no action alternative was selected. 

Crown fires remove much of the entire tree canopy in a particular area, essentially 

resetting the successional and growth processes of stand and forests. These fires 

typically, but not always kill or temporarily reduce the abundance of understory 

shrubs and trees. Crown fires have the largest immediate and long-term ecological 

effects and the greatest potential to threaten human settlements near wildland areas 

(Graham, R., et.al., 2004). For wildlife species dependent on diverse forested 

landscapes (heterogeneity) and old forest characteristics for habitat, this successional 

“set-back” could pose negative consequences. 

Although crown fires would be considered of higher consequence of negative effects, 

surface and ground fires with higher intensities similar to those predicted and 

anticipated in the no action alternative, can also have negative impacts. Areas where 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 376 Appendix G 

the ground cover is removed and severely burned will likely see decreased infiltration 

of water, increased surface runoff and peak flows, and the formation of pedestals, rills 

and gullies (Graham, R., et.al., 2004).

Depending on the setting (in particular topography and soil), perennial streams 

downstream from fires can be impacted by large volumes of sediment. Depending on 

the recovery of the hill slopes, these fire effects can be long lasting, and relatively 

little can be done to stop the problem. Large amounts of sediment can be delivered to 

reservoirs, reducing water storage capacity and potentially affecting fish and macro 

invertebrate habitat (Graham, R., et.al., 2004). (DEIS page 229) 

SC-52

We believe fire use could reduce risks. 

Such an Alternative should be developed 

and not just ignored. On p. 51 of the 

DEIS two fire-use alternatives were 

proposed, but eliminated. SURELY the

Forest Service could write a workable 

fire-use alternative like the National Park 

Service has for the nearby Sequoia and 

Kings Canyon National Parks.

Fuels

The commenter expresses concern that the two fire only alternatives were considered 

but eliminated from detailed study. It is true that on p. 51 of the DEIS two fire-use 

alternatives were proposed, but eliminated. These alternatives were eliminated 

because the use of fire alone would not meet the purpose and need of the project. 

Also the environmental conditions to produce the required fire behavior of a high 

severity fire effects (as one of these alternatives proposed) only occurs during the 

summer month’s within fire season and the fire behavior that would be associated 

with these conditions could not be easily kept within the planned treatment units by 

holding forces. The benefits would be far outweighed by the resource damage that 

would happen should an escape occur.

Additionally, air quality restrictions could make implementation in a timely manner 

very difficult. Therefore this alternative is ineffective as a method of meeting the need 

for ecological restoration particularly in terms of fire resiliency of the forest. 

Fire only alternatives do not meet the purpose and need for public health and safety.

SC-53

In the FEIS and ROD we would also like 

Fuels

The commenter would like the FEIS and ROD to address relationships between the 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 377 Appendix G 

to see relationships as to how the extent of 

clearcutting, masticating, and fire 

suppression in recent past decades are 

related to any recent, named high-severity 

fires in California. We also would like to 

see a list of historic high-severity fires in 

California by date. (We realize there is a 

difference between intense fire and severe 

fire effects.)

extent of clearcutting, masticating, and fire suppression in recent past decades to any 

recent, named high-severity fires in California as well as a list of “historic” fireseverity fires. Refer to Safford et al. (2009), which clearly demonstrate that fuel 

treatments substantially mitigated the negative effects of high-severity fire in the 

Angora Fire (2007).

Regarding the request for a list of “historic” fire-severity fires by date in California, 

refer to Miller and Safford (2008) for the USFS Region 5 Fire Severity Monitoring 

report. “Historic” fire severity information on the scale of the state of California does 

not exist prior to the 1980’s, since these remote-sensing data were not available 

before the availability of data-collecting satellites (pre-1984). See Miller et al. (2009) 

for related science publication of the Miller and Safford (2008) report.

SC-54

Table 55 on p. 262 of the DEIS shows 

that incense cedar and white fir have 

higher dollar values than do sugar pine 

and ponderosa pine per hundred cubic feet 

(ccf). Please explain those value 

differences. Please explain how those 

values were derived. Please provide 

reference citations. Those dollar 

differences seem to give incentive to the 

sale of pine over cedar and fir. ALSO, 

please add column headings to Table 55 

and to Table 56 so the reader does not 

have to second-guess the content.

Timber

The commenter asks for the following information:

1) Explain value differences and how those values were derived, 

2) Incentive to sell pine over fir, 

3) Table columns are confusing.

Forest Service policy on valuation and economics includes:

• FSM 2420.3 – Policy – “1. Except for Region 10, Regions shall use the 

transaction evidence appraisal method as the primary timber appraisal 

method. Region 10 shall use the appraisal method approved by the Chief.”

• FSH 2409.22 – Timber Appraisal Handbook – This handbook outlines 

procedures for TEAs to determine fair market value of timber by comparing 

recently sold sales to the sale being appraised.

• FSH 2409.18 – Ch 40 Sale Preparation

• 2409.22 CH 41 Appraisal

• SNFPA – S&G #12 : “Promote shade intolerant pines (sugar and Ponderosa) 

and hardwoods.”
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 378 Appendix G 

1) Timber is valued using the Forest Service Region 5 Transaction Evidence 

Appraisal program. This national software program estimates fair market 

value based on bid rates of past timber sale transactions (FSH 2409.18 – Ch 

40 Sale Preparation). It will also incorporate values that are made publicly 

available from the Western Wood Product Association (WWPA) to insure 

the accuracy of reporting current sale conditions (2409.22 CH 41 Appraisal). 

The objective of this process is to determine a fair market value for timber 

from National Forest lands (FSH 2409.18 CH 40). Tree species rates differ 

based on the product, use, and grade of timber on the market.

2) Fir and cedar do have higher per bid values, but the sale of these species is 

not related to increasing profit of the sale. “However, economics will not be 

a deciding factor for selecting any action alternative for the Greys Mountain 

Ecological Restoration Project. Instead, alternative selection will be based 

on the alternative that best accomplishes the purpose and need of the project 

(CH 3, Economics Section of DEIS, pg 260).” Rather, the estimated cut 

volume in Table 55 silvicultural prescriptions in which species preference of 

removing fir and cedar prior to pines was meant to reach desired stand 

conditions. “Where choices exist, more fire resistant pines would be favored 

over fir and incense cedar as leave trees” (Forest Vegetation/Silviculture 

Direct Effects, pg. 210) This measure follows Standard and Guideline #12 in 

the SNFPA in which pine species will be promoted to the extent possible. .

3) Table headings have been incorporated into Table 56 and Table 57 to 

alleviate confusion.

SC-55

It seems those species volumes should 

already be known. Those species timber 

volumes by treatment unit need to be 

Timber

The commenter states that timber volumes should be known by treatment unit.

• FSH 2409.18 – Timber Sale Preparation Handbook CH 20 (Sale planner must 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 379 Appendix G 

provided in the FEIS. We request that 

those unit by unit timber volumes for each 

species be sent to us now, or as soon as 

the trees are marked or those volumes are 

known. ALSO, please give more 

complete column headings in Table 65 so 

the reader does not have to second-guess 

the content.

collect information before developing timber sale. Sources of information 

could include compartment inventory of stand data).

We currently have estimates of volume on a per unit basis from common stand exam 

data taken during summer of 2011. The estimated cut volumes are projected from this 

data using a national program, but stand exams are commonly designed to be a less 

intense sample than the actual timber cruise volume during marking. 

No units have been marked at this time and cruise volumes will be much more 

accurate for your request. The final cruise volumes may not be available until July or 

August of 2012, the estimated deadline for marking. 

Column headings have been added to the said table to ease confusion.

SC-56

“Generally, for each million board feet of 

product removal, approximately 13 jobs 

are supported both directly and 

indirectly.” Note that the units of volume 

are millions of board feet (MMBF). Then 

in Tables 55 and 56 (pp. 262-265) the 

units for volume are in ccf (hundreds of 

cubic feet); while footnote 3 to those 

tables (pp. 265-266) uses MMBF 

harvested. Units MUST be consistent. 

Otherwise it makes no sense. If the 

information in the DEIS is unclear, it is a 

violation of NEPA. This MUST be 

corrected.

Timber

The commenter states that the unit measure in the referenced study must be the same 

as the units shown in the tables. Otherwise it is unclear.

Units in the referenced study are not consistent with the tables in the DEIS, therefore 

data showing how many board feet per species has been added to tables 56 and 57. 

The cubic feet tables will remain since that is the typical national forest standard for 

measurement and valuation.

SC-57

The list of ID Team members on p. 273 of 

Document 

Concerns The commenter requested identification of the ID team member who completed the 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 380 Appendix G 

the DEIS does not reveal which member 

served as the forest economist. Please 

provide that information in the ID Team 

member list.

economic analysis listed in Team Member list

The team member is currently listed as an ID team member in the FEIS.

SC-58

There is no conversion factor clearly 

defined for converting from ccf to MMBF 

in this DEIS. That conversion MUST be 

carefully explained. Please provide 

reference citations for the conversion 

factor. 

Timber

The commenter requests that the Forest define the conversion factor used in 

converting from ccf to MMBF.

The Forest Service policy on this is found in R5 TEA.

The conversion normally changes by species, but the economic analysis assumes a 

0.5370 conversion factor across all species. This conversion factor represents an 

average conversion from past timber sale data on the district. Typical range for 

conversion factors is around 0.5000 to 0.5500.

Total board foot volume was added to the Economic Analysis section of the EIS. 

. 

SC-59

Using the 100 jobs from Table 55 (p. 263) 

and the claimed 13 jobs per 1 MMBF 

from above, calculation yields a volume 

of approximately 7.7 MMBF. BUT a 

direct mathematical calculation from 

15,351 ccf (in Table 55) yields 

approximately 18.4 MMBF. The 

GMERP DEIS does not address that 

problem. It is time to explain it and not 

simply justify the confusion by ignoring 

this request.

Timber

The commenter asserts that there is a mathematical error in DEIS.

The Forest used the following paper to respond to the comment: Spelter, Henry. 

“Challenges in Converting Among Log Scaling Methods” USDA Forest Service 

http://www.fpl.fs.fed.us/documnts/fplrp/fplrp611.pdf 

Using the average conversion factor of 0.5370 for Greys Mountain, the total board 

foot volume equates to approximately 8.2 mmbf (15,351 X 0.5370 = 8.2439). This 

conversion factor is calculated in the Regional Transaction Evidence Appraisal 

Report. 

The calculations and methods in which board foot volume equations determine tree 

volume varies from cubic foot volume equations 

(http://www.fpl.fs.fed.us/documnts/fplrp/fplrp611.pdf). The board foot unit allows for 

saw kerf, slab, edgings, shrinkage, bark, or sawing method, unlike the cubic foot unit. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 381 Appendix G 

Therefore, the cubic foot unit includes that extra volume that the board foot equations 

generally omit from total volume.

The total number of jobs that are created equals around 108 jobs (8.2 mmbf 

multiplied by 13.2 = approximately 108) and since this is in fact an error in 

calculation, it will be changed in the table.

The Forest has changed the calculation in table to address this problem. Board foot 

volume tables have been included in the FEIS so it is easily referenced and reduces 

confusion.

SC-60 In the comments above we have noted a 

significant number of errors in citation of 

supporting references. There also are 

significant claims in the DEIS with no 

reference support at all. A simple word 

search of the DEIS and its list of 

Literature Cited reveals many more such 

errors. NFMA of 1976 requires use of 

best current research. NEPA requires 

clarity. 

With so many citation errors and 

omissions, there is significant doubt that 

science is applied appropriately 

throughout the DEIS. That makes the 

DEIS unclear. That MUST be corrected. 

When the FEIS and ROD are completed, 

please be sure to make citations complete 

and accurate. All literature cited must be 

in the list of Literature Cited. Any 

literature not cited must not appear in that 

list. Claims not scientifically supported 

NEPA 

Please see response to comment SC-10.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 382 Appendix G 

through correct citations will simply be 

opinions and cannot be verified.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 383 Appendix G 

Sierra Forest Legacy – Susan Britting – 1/29/12

Comment

Number

Comment Comment 

Topic

General Response

SFL-1

The project specific impacts to fishers and 

spotted owl combined with the extensive 

cumulative impacts from near 

simultaneous implementation of 

vegetation management on over 10,000 

acres leads us to find that the Proposed 

Action would jeopardize the persistence 

of California spotted owl and Pacific 

fisher.

Wildlife

The commenter states that the simultaneous implementation of vegetation 

management on over 10,000 acres (including the Proposed Action) would jeopardize 

the persistence of California spotted owl and Pacific fisher. The DEIS cumulative 

effects analysis has taken into consideration past, present and foreseeable vegetation 

management at small and large scales (FEIS Section Past, Present and Reasonably 

Foreseeable Actions pg 58 and the Terrestrial Wildlife BABE). Our analysis shows 

that the Proposed Action would not significantly reduce fisher habitat and therefore 

would not have significant negative effects on the short and long-term sustainability 

of fishers in the Project area, the Bass Lake Ranger District, Sierra National Forest, 

and the Southern Sierra Nevada fisher population area. Through our project design, 

planning, and analysis we have not found any reason to believe that would imperil the 

local fisher population nor the Southern Sierra Nevada fisher population as a whole. 

On the contrary, this management helps ensure fisher habitat, and the fisher 

population, would be sustained on this landscape for the future by implementing 

carefully planned forest management that reduces wildfire fuels and the potential for 

major and severe wildfire. If such fuels were not reduced, and wildfire did occur in or 

near the Project area, then such wildfire would most likely significantly impact the 

long-term sustainability of the fisher population. Our carefully planned forest 

management reduces wildland fuels while simultaneously retaining the key habitat 

components required by fisher, including retaining all large trees (>30 inches dbh); 

most mid-sized trees (20-30 inches dbh); all large snags (except for snags classified as 

hazardous to humans or structures); all black oaks; as well as many other components 

such as large coarse woody debris and large portions of the Project area with high 

vegetation density and overstory canopy cover.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 384 Appendix G 

SFL-2

Furthermore, the analysis for this project

and the decision that amended the forest 

plan for the Sierra National Forest (USDA 

Forest Service 2004a) relies on the 

implementation of adaptive management 

and monitoring to ensure that viable 

populations for California spotted owl and 

Pacific fisher are maintained. Because the 

Forest Service has failed to adequately 

fund and implement the adaptive 

management and monitoring programs 

required by the forest plan, population 

viability for these species cannot be 

assured, in violation of the National 

Forest Management Act (NFMA).

NEPA 

Over the past two decades the Forest Service has provided substantial funding for 

monitoring and research on California spotted owl and Pacific fisher, and we will 

continue to do so within limitations of a declining federal budget. We have funded 

spotted owl demography studies and additional adaptive management studies for the 

past 25 years, with generally increasing budgets. For FY12 and for several previous 

years, our funding for California spotted owl demography and adaptive management 

studies has exceeded $1.5 million per year, not including indirect funding provided by 

the USFS Pacific Southwest Research Station. Bioregional occupancy monitoring for 

Pacific fisher throughout their range in the southern Sierra was initiated in 2002 and 

continues, with no plans to discontinue. This monitoring has contributed to regional 

models and knowledge about viability of southern Sierra fisher. Since 2007 our 

contributions to SNAMP have remained constant at over $1.4 million a year, for a 

total of more than $8 million. Allocations from that total are made to the fisher study 

by the University of California Science Team (the Principal Investigators); most of 

the Forest Service contribution goes to fisher and California spotted owl studies. The 

Kings River Fisher Project, underway since 2007, has been funded at $700,000 per 

year. All told, we provide funding of about $2 million per year for fisher monitoring 

and research. Valuable information gained from all these projects is annually 

integrated into our project planning, as well as project design criteria for our 

vegetation management treatments. These instances are direct and valuable examples 

of adaptive management. 

This is an ideal time for us to conduct vegetation treatments within the range of fisher 

while we have intensive and valuable research occurring at the same time and place. 

The SNAMP fisher study area includes the Grey’s Mountain Project as well most of 

the treatments identified in Table 1 of the comment letter; other treatments are in the 

Kings River Fisher Project area. We can best test the effects of treatments on fisher 

now, while we have detailed monitoring and research that includes valuable baseline 

data. We continue to propose and implement projects such as the Grey’s Mountain 

Ecological Restoration Project because they represent opportunities for adaptive 

management studies.

SFL-3

We also object to the Greys Mountain 

NEPA 

There is no requirement that the project be governed by the 2001 Framework as the 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 385 Appendix G 

project to the extent that it deviates from 

the standards and

guidelines contained in the 2001 Record 

of Decision for the Sierra Nevada Forest 

Plan

Amendment (USDA Forest Service 2001) 

and implements the 2004 Record of 

Decision for the Sierra Nevada Forest 

Plan Amendment (“2004 ROD”; USDA 

Forest Service 2004a). In Sierra Nevada 

Forest Prot. Campaign v. Rey, 573 F. 

Supp. 2d 1316 (E.D. Cal. 2008), the court 

held that the Forest Service violated the 

National Environmental Policy Act 

(NEPA) in adopting the 2004 Framework 

by failing to consider any reasonable 

alternatives. Because the Forest Service 

violated NEPA in adopting the 2004 

Framework, logging projects that 

implement and rely upon the 2004 

Framework are also contrary to law [see 

e.g., Klamath Siskiyou Wildlands Ctr. v. 

Boody, 468 F.3d 549, 562 (9th Cir. 2006), 

Northwest Ecosystem Alliance v. Rey, 

2006 WL 44361, at *8 (W.D. Wash. 

2006), Citizens for Better Forestry v. 

USDA, 2009 WL 1883728, at *13 (N.D. 

Cal. 2009)]. Thus, to the extent that the 

Greys Mountain Project implements any 

of the changes to the 2001 Sierra Nevada 

Forest Plan Amendment made by the 

2004 ROD, the

Project is contrary to law.

commenter suggests. The 2004 Framework decision has not been vacated and there is 

no injunction against continuing to implement projects pursuant to the 2004 

Framework decision. The federal court ruling in Sierra Nevada Forest Protection 

Campaign v Rey, 573 F. Supp. 2d 1316 (E.D. Cal 2008) found that the Forest Service 

failed to consider a reasonable range of alternatives to the 2004 Framework as 

required by NEPA. The remedy phase for this ruling is currently back before the 

District Court to determine proper remedy. The latest ruling on this case occurred in 

May 2011, Sierra Forest Legacy et al v Sherman , 646 F.3d 1161 (9th Cir. 2011), 

where the 9th Circuit remanded the case to District Court for further proceedings 

related to proper remedy for the Framework NEPA violation. Until the District Court 

rules again on remedy, Sierra National Forest activities continue to implement the 

2004 Framework and are not constrained during the remand process. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 386 Appendix G 

SFL-4

Our concerns about the Greys Mountain 

project and DEIS are described in detail 

below. We ask that you revise the 

Proposed Action and environmental 

analysis to address these issues and 

recirculate a new DEIS for public review.

NEPA 

The SNF has reviewed and evaluated the concerns raised in your comment letter. The 

Proposed Action was reviewed as requested and deemed appropriate as written. The 

environmental analysis was also reviewed and strengthened, clarified and adjustments 

were made as explained in the FEIS section “Difference between the DEIS and the 

FEIS.” The SNF acknowledges that like most draft documents the DEIS contained 

errors and analysis that needed strengthening. A draft and comment system is 

designed to identify these errors and potential gaps and correct them prior to a final 

decision being made. Although care was made to explain a complex project and its 

effects, the FEIS has been strengthened to clarify the alternatives and their effects as 

appropriate. 

As per FSH 1909.15 Chap 10 Section 18.2 (2)(c)(1) “Supplement - Agencies: (1) 

Shall prepare supplements to either draft or final environmental impact statements if: 

(i) The agency makes substantial changes in the proposed action that are relevant to 

environmental concerns; or (ii) There are significant new circumstances or 

information relevant to environmental concerns and bearing on the proposed action 

and its impacts.”

The DEIS Proposed Action has not been revised nor has the SNF found there to be 

new circumstances or information which would require supplementation. Therefore 

recirculation of a revised or supplemented DEIS is not required.

SFL-5

As we describe below, adaptive 

management programs for key species 

affected by the Greys

Mountain project and specifically named 

in the 2004 Framework appeal decision, 

i.e., California spotted owl and Pacific 

fisher, have either not been designed and 

conducted as identified in the 2004 ROD 

(e.g., Pacific fisher) or the program is not 

NEPA 

The monitoring of the southern Sierra Pacific fisher status specifically identified in 

the 2004 ROD (p. 7) was designed and initiated in 2002 and continues to be 

adequately funded and conducted annually. The canopy reduction study was funded 

and completed in 2008. Long-term California spotted owl demography studies 

continue to be funded. Adaptive management studies for California spotted owls and 

fisher are part of the Sierra Nevada Adaptive Management Project (SNAMP) and 

those researchers have expanded the study areas beyond the SNAMP treatment, and 

those areas include other treatments, including Grey’s Mountain. Additional adaptive 

management research is funded by the Region and conducted by the Pacific 

Southwest Research Station in the Kings River Project area and surrounding areas. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 387 Appendix G 

being funded adequately (e.g., Pacific 

fisher and California spotted owl). In the 

absence of adequately funding and 

implementing the adaptive management 

program, the claims that viable 

populations of California spotted owl and 

Pacific fisher will be maintained cannot

be supported. Under the 2004 ROD, 

projects, such as Greys Mountain, that are 

likely to adversely affect these species in 

ways that are uncertain depend on 

adaptive management to address risk and 

uncertainty. In the absence of the required 

programs, either through lack of design or 

failure to fund and implement, the 

projects themselves cannot claim to 

maintain the viability of these species.

These studies contribute knowledge about California spotted owl demography and 

fisher ecology and habitat that we use for adaptive management. The rich baseline 

information from these studies means that they are poised to make even greater 

contributions to adaptive management as treatments are implemented and the effects 

are assessed.

SFL-6

Moreover, many of the projects are 

adjacent to each other geographically and 

collectively will be implemented over a 

narrow time frame. In the absence of an 

adaptive management strategy for fishers 

that affects a limited portion of the 

landscape and examines treatment effects 

in a timely manner to allow adjustment to 

management, projects like Greys 

Mountain must adopt a less risky 

alternative to vegetation management 

such as one based on the 2001 ROD in 

order to maintain viable populations of 

fisher and meet the requirements of

the NFMA planning rule.

Wildlife

The Project BE/BA has been updated to address these concerns. Please also see the 

response to comment SFL-1.

Additionally the DEIS includes a second action alternative, Alternative 3 (See 

Chapter 2 of the DEIS), which includes only precommercial thinning (less than 10 

inches dbh) with no thinning in the mid-level canopy. The effects on this alternative 

on the Forest including on vegetation and fuels is contrasted with the effects of the no 

action alternative and the proposed action. The decision maker will base his decision 

on the analysis of the purpose and need for action, the issues, the LRMP as amended 

and, current policies and regulations, the analysis of alternatives contained in the 

FEIS, public comments received, and other information in the project record. He will 

weigh the relative values and the degree of need to meet the purpose and need and 

make the final decision as to what action the SNF will take if any. This decision will 

be documented in a Record of Decision. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 388 Appendix G 

SFL-7

The BE (p.54) for the Greys Mountain 

project relies on these assumptions that 

are no longer correct. The BE should be 

revised to explain how, given the 

backdrop of persistent population decline, 

the adverse impacts to owl habitat will not 

will not lead to a trend toward federal 

listing or jeopardize the persistence of 

spotted owl.

Wildlife 

The BE/BA has been revised to include the latest results from the SNFPA California 

spotted owl demography studies including Scherer et al 2010, and Munton et al 2012. 

Page 7 and 8 of the comment letter discusses the results of spotted owl demographic 

studies in Lassen and Eldorado National Forests, which are more than 200 miles north 

of Sierra National Forest, but the comment fails to mention that the same 

demographic study was also conducted in Sierra National Forest over the past 20 

years and that study shows a stable spotted owl population. This study area also 

includes areas of previous vegetation management projects. 

Also, contrary to the statements made in the comments, the Eldorado National Forest 

study shows that the owl population has been stable since the beginning of the study 

and that further monitoring is needed before making conclusions about a long-term 

population decline, as quoted here: 

“The finite rate of population change that we estimated using mark-recapture data 

from the Eldorado Density Study Area indicated that the population size has been 

stable since the beginning of the study, although we have observed a gradual decline 

in the realized population change over the last 10 years. This suggests that continued 

monitoring will be needed to assess whether a long-term population decline is 

underway.” (Gutierrez et al., 2011)

It is also important to understand that the population decline in the local population of 

Lassen NF is not the full and true picture of the spotted owl population across the 

region. These three demographic studies were designed to only assess population 

change; they were not designed to determine the cause and effect of changes in 

populations, as insinuated by the commenter. Changes in populations can be caused 

by any number of single or combined factors and thus far there is no evidence that our 

forest management is a cause in the decline of the Lassen NF population. On the 

contrary, our carefully designed and professionally managed forest management 

projects help sustain spotted owl habitat. Specifically, these projects retain most large 

trees greater than 20 inches dbh; most large snags; moderate and high overstory forest 

canopy cover; most black oaks; and many other habitat components needed by spotted 

owls. Just as important, our management helps ensure that habitat remains on the 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 389 Appendix G 

landscape for those owls, by reducing the potential for large scale, severe wildfires 

that have catastrophic negative results on owl populations. It is important to 

understand that the viability of spotted owls in the Sierra Nevada will be jeopardized 

if we are unable to conduct carefully planned fuels reduction and forest restoration 

treatments, such as this project, and others implemented under the 2004 ROD 

direction.

SFL-8

There is no discussion in the DEIS or BE 

about why avoiding these areas would 

compromise the fuels strategy.

Fuels

Page 101 (DEIS) describes design measures for treatments in areas of habitat and 

buffer zones. These design measures would promote clumping of vegetation and 

enough spacing of crown closure ensuring heterogeneity and would not compromise 

fuels strategy. Treatments proposed within habitat areas would be implemented 

outside the Limited Operating Period (LOP).

There are a total of 1,454 acres of Spotted Owl PAC and 1,583 acres of Spotted Owl 

HRCA within the Grey’s Mountain Project area. Of these, 1,781 acres are also within 

WUI. WUI makes up 46% of the total project boundary area, or 4,487 acres.

Fuels reduction treatments within the WUI were designed to avoid PACs wherever 

possible, however based on the SPLAT area placement, avoiding all PACs/HRCAs 

would compromise the overall effectiveness of the landscape fire and fuels strategy. 

Mechanical treatments have been designed to maintain habitat structure and function 

of the PACs (for instance, no trees ≥20” dbh would be removed).

 

SFL-9

In addition, the intensity of treatment 

included in the Proposed Action exceeds 

the direction in the 2004 ROD to treat 

stands to meet fuel objectives. As 

disclosed in the discussion of fire and 

fuels effects (DEIS, p. 240), there is no 

significant difference in fire effects 

between the Proposed Action (Alternative 

Fuels

Alternative 2&3 both meet the desired fuel objectives however Alternative 3 does 

little to nothing for the multi-objective purpose and the need of the project which 

includes reducing stand density to create resiliency.

In the Fire/Fuels Specialist Report of the FEIS displays the comparison of 

Alternatives. Alternatives 3 shows there is a potential risk for condition crowning due 

to closer crown density. Edits to the FEIS, Alternative 3 summary have been made to 

clarify the differences.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 390 Appendix G 

2) and Alternative 3 – both

meet the desired fuel objectives.

SFL-10

Treatments in Alternative 3 are limited to 

reducing surface and ladder fuels and do 

not reduce the number of large trees or the 

overstory canopy provided by large trees 

as occurs under the Proposed Action. For 

instance, Unit 35 and 37 overlap with 

PAC MAD0026 and 78 acres of this PAC 

will be treated with “tractor thinning” 

(BE, p. 51). The BE (p. 137) indicates that 

14 or 30 trees per acre over 20” diameter 

would be removed from these units, 

respectively. The removal of these trees 

would result in reductions in the existing 

canopy cover from 70-75% to 53-62% 

post treatment. These impacts would be 

combined with substantial reductions in 

large trees in home range core areas 

(HRCAs). For example, Unit 33 occurs 

with an HRCA (BE, p. 49). There are an 

estimated 12 trees per acre greater than 

25” diameter that would be removed from 

Unit 33 with an estimated change in 

canopy cover from 70% to 61% (DEIS, p. 

329). Thus, the Proposed Action would 

result in significant alteration of habitat 

important for breeding owls.

Wildlife 

No commercial harvest would occur in units Fx-9 or T-18 as these treatment areas are 

outside of the WUI. Units T-18 and Fx-9 have been updated to be treated with 

prescribed fire only.

Thinning of trees less than 20” dbh to reduce excess fuel loading would occur within 

units T-5, T-16, T-35, and the eastern section of unit T-37 that lies within Spotted 

Owl PAC MAD0026. Trees ≥20” dbh would not be removed from these units. The 

treatment tables in the FEIS and FEIS and BE/BA analyses have been updated to 

reflect these changes.

SFL-11

The factors above combined with the 

underestimate of impacts on spotted owls 

Wildlife 

Page 7 and 8 of the comment letter discusses the results of spotted owl demographic 

studies in Lassen and Eldorado National Forests, which are more than 200 miles north 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 391 Appendix G 

we describe in the sections below indicate 

that the negative effects from the Greys 

Mountain project and the adverse 

cumulative effects from past and ongoing 

projects on public and private lands are 

likely to lead to a trend toward federal 

listing for California spotted owl. Such a 

trend is in violation of Forest Service 

direction.

of Sierra National Forest, but the comment fails to mention that the same 

demographic study was also conducted in Sierra National Forest over the past 20 

years and that study shows a stable spotted owl population. This study area also 

includes areas of previous vegetation management projects. 

Also, contrary to the statements made in the comments, the Eldorado National Forest 

study shows that the owl population has been stable since the beginning of the study 

and that further monitoring is needed before making conclusions about a long-term 

population decline, as quoted here: 

“The finite rate of population change that we estimated using mark-recapture data 

from the Eldorado Density Study Area indicated that the population size has been 

stable since the beginning of the study, although we have observed a gradual decline 

in the realized population change over the last 10 years. This suggests that continued 

monitoring will be needed to assess whether a long-term population decline is 

underway.” (Gutierrez et al., 2011)

It is also important to understand that the population decline in the local population of 

Lassen NF is not the full and true picture of the spotted owl population across the 

region. These three demographic studies were designed to only assess population 

change; they were not designed to determine the cause and effect of changes in 

populations, as insinuated by the commenter. Changes in populations can be caused 

by any number of single or combined factors and thus far there is no evidence that our 

forest management is a cause in the decline of the Lassen NF population. On the 

contrary, our carefully designed and professionally managed forest management 

projects help sustain spotted owl habitat. Specifically, these projects retain most large 

trees greater than 20 inches dbh; most large snags; moderate and high overstory forest 

canopy cover; most black oaks; and many other habitat components needed by spotted 

owls. Just as important, our management helps ensure that habitat remains on the 

landscape for those owls, by reducing the potential for large scale, severe wildfires 

that have catastrophic negative results on owl populations. It is important to 

understand that the viability of spotted owls in the Sierra Nevada will be jeopardized 

if we are unable to conduct carefully planned fuels reduction and forest restoration 

treatments, such as this project, and others implemented under the 2004 ROD 

direction.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 392 Appendix G 

SFL-12

Given the high risk of decline in the 

strength of the source in the “Nelder 

Grove & Sugar Pine” region (noted 

above) it is critical to examine the 

potential to compensate for this decline 

elsewhere in the region. (pg 11)

Wildlife 

Pages 144-147 and 149-152 of the BE/BA have been updated to address these 

concerns by more closely examining the extent of projects on the Bass Lake Ranger 

District that occur or will occur within fisher habitat.

Additionally, Rick Sweitzer (personal communication on 2/28/12) has stated that he 

expects more recent fisher monitoring activities to show the Miami Mtn/Chowchilla 

sub section of the SNAMP study area to more closely resemble a population source

area this year. The Miami Mtn/Chowchilla source population area is adjacent to the 

Nelder Grove and Sugar Pine region. No large scale vegetation management projects 

are currently within the Miami Mtn/Chowchilla source population area, so that region 

will be able to accommodate movements by fishers that may leave the Nelder 

Grove/Sugar Pine population source area in response to treatments for the Sugar Pine 

and Fish Camp vegetation management projects. The Bass Lake district is closely 

examining timing and duration of adjacent projects to minimize the potential for 

negative effects to fishers and other species.

SFL-13

The potential adverse cumulative effects 

on population dynamics due to habitat 

alteration from the Greys Mountain 

project and other recently approved or to 

be approved projects has a high likelihood 

of contributing to the present trend toward 

extinction and to threaten the viability of 

fishers.

Wildlife 

Recent scientific information presented in 2011 at The Western Section of the 

Wildlife Society meeting indicates that the fisher population on the Sierra National 

Forest is stable to increasing. Values of lambda (λ) greater than 1 indicate that a 

population is increasing, while λ values less than 1 indicate that a population is 

decreasing. Calculated values for λ were presented for fisher populations within the 

SNAMP study area (λ 1.04) on the Bass Lake Ranger District, and the Kings River 

Fisher Project area (λ 1.2) on the High Sierra Ranger District (Sweitzer et al. 2011). 

Based on this data, fisher populations on both districts of the Sierra National forest are 

increasing. In addition, data presented by Jody Tucker at the Western Section TWS 

fisher symposium in 2012 displayed results from the Southern Sierra Nevada 

Carnivore Monitoring Program indicating the occupancy status of the southern Sierra 

Nevada fisher population from 2002-2009 was stable. (Tucker, 2012; Zielinski et al, 

In Review)

Please also see response to comment SFL-1.

SFL-14 Wildlife
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 393 Appendix G 

The MIS amendment attempts to skirt the 

issue by focusing on rangewide effects 

and adopting a planning area that is so 

expansive that the collapse of the species, 

i.e., its extinction, would be required to 

indicate a need to change management. 

This result is clearly not the intention of 

the planning rule for the NFMA.

It is important to note that our MIS assessment not only analyzes MIS at a larger 

range wide level but also at the project level. This combined assessment of species 

and habitats at large and small scales is scientifically credible in its ability to 

adequately track the MIS species and their habitats through time, and thus allow the 

Forest Service to maintain their sustainability through time. 

SFL-15

The monitoring protocol established for 

the MIS amendment cannot possible 

satisfy the requirement that "population 

trends of the management indicator 

species will be monitored and 

relationships to habitat changes 

determined” (1982: 36 CFR 

219.19(a)(6)).

Wildlife

We disagree with this assessment. The MIS monitoring program provides a respected 

scientific assessment of the conditions of species populations and their habitats at 

large and small scales. We use these results to monitor the amount of habitat as well 

as changes in populations on Forest Service lands, and results of this monitoring will 

allow adequate indicators of change to also modify management. For example, major 

changes seen through these MIS assessments (a coarse filter) will allow the Forest 

Service to create additional assessments (fine filters) to better focus on the issues and 

management needs, thus allowing us to more efficiently direct limited and continued 

declines in budget funding. Additionally, the 1982 planning rules that are cited in the 

comment are no longer are in effect and therefore that legal requirement is no longer 

applicable.

SFL-16

Sadly, the Greys Mountain project 

illustrates the degree to which the MIS 

amendment makes a sham of monitoring. 

The MIS amendment is a costly effort that 

is unlikely to ever detect the need to 

change management until species declines 

are so extreme a change course would 

have no benefit. Further, it provides 

nothing to advancing the direction to 

maintain viable populations of species

across the planning area as directed by the 

Wildlife

See the response to SFL-15, which also addresses this comment.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 394 Appendix G 

NFMA planning rule.

SFL-17

The BE (p. 53) appears to assume that if 

canopy cover in PACs and HRCAs is 

maintained at 60% and 50%, respectively, 

the design criteria included in the 

alternative will be sufficient to

provide other desirable characteristics. 

The analysis, however, does not address 

the effect of removing large numbers of 

trees greater than 20” dbh, with a 

significant number of trees proposed for 

removal that area greater than 25” dbh. 

Our review of the unit table provided in 

the DEIS (p. 328-329) suggests that large 

tree removal will reduce canopy cover in 

dominant and codominant trees that 

exceed 25” dbh.

Wildlife

No commercial harvest will occur in units Fx-9 or T-18 as these treatment areas are 

outside of the WUI. These units have been changed to prescribed Underburn only. 

Thinning to reduce excess fuel loading would occur within units T35, and the eastern 

section of unit T37 that lies within Spotted Owl PAC MAD0026. Trees ≥20” dbh 

would not be removed from these units. 

The treatment tables in the FEIS and the analysis in the FEIS and BE/BA have been 

updated to reflect these changes.

SFL-18

Significant numbers of trees >20” dbh are 

proposed for removal in these owl habitat 

areas and canopy reductions are 

significant. The removal of 5 trees per 

acre greater than 25” dbh in Unit 35 is of 

particular concern. The comparison of the 

existing condition with the 

recommendations in Verner et al. (1992) 

indicates that these habitat areas are 

currently within desired conditions. The 

BE seems to justify the removal of large 

trees to create heterogeneity, but no 

measures or assessment of this condition 

Wildlife

No commercial harvest will occur in units Fx-9 or T-18 as these treatment areas are 

outside of the WUI. These units have been changed to prescribed fire only. Thinning 

to reduce excess fuel loading will occur within units T35, and the eastern section of 

unit T37 that lies within Spotted Owl PAC MAD0026. Trees ≥20” dbh will not be 

removed from these units. 

The treatment tables in the FEIS and the analysis in the FEIS and BE/BA have been 

updated to reflect these changes.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 395 Appendix G 

are provided and no discussion about how 

removal of large tees would create 

heterogeneity is provided.

SFL-19

There is some discussion about loss of 

larger trees due to stand density concerns. 

The loss of larger trees due to density 

induced mortality has the potential to 

provide additional larger snags to these 

owl habitat areas. Current numbers of 

large snags are less than recommended by 

Verner et al. (1992) and habitat conditions 

could benefit from increases in larger 

snags and large down wood. The effects 

of reducing habitat conditions in sensitive 

area that are already within recommended 

ranges was not disclosed in the BE. 

Furthermore, the reduction of large trees 

(and future large snags) in the habitat 

areas was not discussed.

Wildlife

Pages 44-53 of the BE/BA have been updated to address these concerns. 

Prescriptions for several units have been modified to address these concerns. Several 

units (T-18 and Fx-9) have been removed from commercial harvest activities and 

proposed for prescribed underburning only. Thinning to reduce excess fuel loading 

will occur within units T35, and the eastern section of unit T37 that lies within 

Spotted Owl PAC MAD0026. Trees ≥20” dbh will not be removed from these units. 

Other project design criteria including the retention of higher basal area within large 

tree groups, oak clumps, and retaining all snags that do not pose a direct safety hazard 

will ensure that suitable habitat conditions are maintained for California spotted owls. 

The Grey’s Mountain Ecological Restoration Project would retain an average of nine 

snags per acre ≥10” dbh, and four large snags per acre (≥16” dbh) across the treatment 

units, which meets the requirement set forth in the SNFPA ROD S&G #11. The 

Grey’s Mountain Project seeks to retain all snags except those that pose a direct safety 

hazard during project implementation. 

Please also see response to JMP-27.

SFL-20

The BE also does not discuss the existing 

condition of the habitat areas and the 

degree to which management will reduced 

the currently favorable conditions. This 

information needs to be provided to create 

a baseline condition for comparison of 

how the Proposed Action affects

habitat quality.

Wildlife

See response to SFL-19.

SFL-21

Fishers are positively associated with high 

Wildlife

The Sierra National Forest understands the importance of sustaining fisher 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 396 Appendix G 

levels of biomass; the positive correlation 

does not plateau or diminish as biomass 

increases (Spencer et al. 2010). This 

suggests that maintaining a high level of 

biomass available to fisher on a given site 

contributes to the likelihood of 

occupancy. This strong association with 

increasing biomass is not discussed in the 

BE.

populations. We plan and design our management to address the conservation of that 

species as well as other wildlife species and other forest resources and uses. The SNF 

is contemplating forest thinning that retains the majority of the forest biomass, 

including all large trees greater than 30 inches dbh and nearly all moderate sized trees 

20-30 inches dbh, as well as many smaller trees, all oak trees, and all large snags 

unless deemed a safety hazard. We also included extensive areas of no thinning 

management within the Project area to retain areas of high biomass density. 

SFL-22

The primary means to assess habitat 

quality used by the BE is based on a 

habitat relationship model called “CWHR 

2.1” (BE, p. 124). The BE does not 

provide occupancy or fitness data to 

support the use of this model for assessing 

impacts to fishers. As a general matter, 

the habitat modeling undertaken by 

Spencer et al. (2010) indicated that the 

CWHR habitat ratings, the same used in 

the Greys Mountain BE, did not strongly 

predict the occupancy of fishers and this 

attribute was

not included in any of the top ten models 

(Ibid., p. 796).

Wildlife

Spencer et al (2010) use 3 variables to predict fisher distribution in the Southern 

Sierra Nevada including: latitude-adjusted elevation, average annual precipitation, and 

total above-ground biomass of trees (Spencer et al 2010). Although biomass correlates 

closely with fisher distribution at the very broad scale analyzed by Spencer et al 

(2010). The authors warn that biomass comparisons pre- to post- treatment are not

believed to be accurate methods for assessing potential impacts at the project scale

(Spencer et al 2008). The BEBA utilizes numerous variables to analyze for potential 

impacts to fisher including changes in large dbh trees, snags, coarse woody debris, as 

well as changes in CWHR 2.1 weighted habitat scores at the project level, and within 

individual fisher home ranges. The BEBA also incorporates design measures for 

retention of key habitat components within treatment units such as shrub understory 

and trees with cavities and other deformities that may serve as resting/denning sites.

SFL-23

The use of the CWHR model in the Greys 

Mountain project underestimates the 

changes to habitat condition because its 

application in the BE assumes that one 

can maintain habitat

conditions even if significant biomass has 

Wildlife

See responses to SFL 21 and SFL 22
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 397 Appendix G 

been reduced, i.e., as long as the CWHR 

class (e.g.,

4D) is maintained; conditions are equally 

favorable pre and post treatment. This is 

an

assumption that has not been tested for 

the CWHR system or for fishers. The 

positive

correlations of fisher occupancy with 

increasing biomass (Spencer et al. 2010) 

suggests that

reductions in the number of large trees 

can reduce the probability of occupancy 

regardless of the

canopy cover retained post-treatment. The 

removal of larger trees >20” dbh (and 

especially

those >25” dbh) will result in large 

decreases in biomass. The removal of the 

significant

numbers of large trees and reductions in 

canopy cover should be more fully 

evaluated in the BE.

SFL-24

The BE also should examine the effects of 

the Proposed Action on fragmentation of 

habitat in the project area. Zielinski et al. 

(2004) found that on average home ranges 

had 67% on their area

in dense canopy (>60%). The degree to 

Wildlife

Pages 146-148 of the BE/BA have been updated to address these concerns by 

incorporating home range and canopy cover analyses into Evaluation Criterion 5: 

Habitat Connectivity.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 398 Appendix G 

which the proposed treatments reduce 

home range

quality as it relates to canopy closure 

should be examined in the BE. 

Fragmentation in this case

is not focused on the movement of fishers, 

as assessed in the BE, but rather on the 

potential to

fragment or disrupt the habitat that exists 

in the home range.

SFL-25

As discussed above, the potential adverse 

effects of the Proposed Action 

(Alternative 2) on

California spotted owl and Pacific fisher 

are underestimated, in part, because the 

regional context

for these species was not closely 

examined. Because the BE does not 

adequately assess existing

concerns about these species population 

status and distribution and the baseline 

condition is not

accurately described or evaluated. 

Moreover, the BE does not examine 

potential cumulative

effect of serial projects located closely on 

the landscape and sequenced for 

implementation over

a short length of time

Wildlife

Pages 44-53 and 149-152 of the BE/BA have been updated to address these concerns

including more discussion on the regional population status of the California spotted 

owl and pacific fisher, and more detailed cumulative effects analysis of timing and 

duration of projects located closely on the landscape.

SFL-26

In assessing cumulative effects for both 

Wildlife
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 399 Appendix G 

spotted owl and fishers, the BE asserts 

that because these proposed, ongoing and 

recent projects have design measures 

intended to retain habitat features for the 

benefit of spotted owls and fishers “it is 

unlikely” that the projects will have a 

significant detrimental effect. This 

reasoning overlooks the primary concern 

when assessing cumulative effects – that 

the effects of a project by itself may not 

be significant4, yet the incremental effects 

of numerous projects over time and space 

can result in significant cumulative 

effects. The BE fails to integrate 

information about population status and 

threat, current conditions, and habitat 

changes from a variety of projects in the 

assessment of cumulative effects. This 

section of the BE should be revised to 

integrate these aspects and evaluate the 

cumulative effect on population stability 

and species persistence in the assessment 

area and the region.

See response to SFL-25.

SFL-27

We find that the Greys Mountain DEIS 

fails to comply with the National Forest 

Management

Act, the National Environmental Policy 

Act, and other federal laws. We ask that 

the DEIS be revised to comply with 

NEPA, and the revised DEIS circulated 

for additional public comment.

NEPA 

Please see comment SFL-4. The DEIS has been edited and revised as appropriate to 

address concerns raised in your comment letter. The issues raised have been further 

addressed in this response to comment section. After careful consideration of the 

issues raised, the SNF has determined that the FEIS is in compliance with NFMA and 

NEPA for the reasons articulated in the response to comments above. As per FSH 

1909.15 Chap 10 Section 18.2 (2)(c)(3) “(3) Revision. Agencies: If a draft statement 

is so inadequate as to preclude meaningful analysis, the agency shall prepare and 

circulate a revised draft of the appropriate portion..... (40 CFR 1502.9(a)”

The DEIS provides meaningful analysis throughout Chapter 3. As the FEIS is not 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 400 Appendix G 

significantly different than the DEIS the SNF is not required to recirculate the 

document and has chosen not to do so.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 401 Appendix G 

John Muir Project – Chad Hanson – 1/30/12

Comment

Number

Comment Comment 

Topic

General Response

JMP-1

However, we do oppose the proposed 

removal of mature/old trees up to 30 

inches in diameter on over 2,000 acres of 

natural forest under the Proposed Action. 

Also, as we discuss below, given that 

removal of trees over about 10 inches in 

diameter is unnecessary in order to 

effectively reduce the potential for highintensity fire (if and where that may be a 

scientifically defensible goal) the scoping 

notice does not provide a clear 

explanation as to why larger, older trees 

(e.g., those 16-20” dbh, and those 20-30” 

dbh) must be removed. 

Silviculture

The commenter opposed the proposed removal of mature/old trees up to 30 inches in 

diameter and requests clarification on why larger, older trees must be removed. The 

DEIS p 9 and p53 discloses that approximately 1,650 acres (reduced to 1,566 acres in 

the FEIS) may be commercially thinned under this document. The response to 

comment SC-36 further displays what the estimated extent of trees 20 through 29 inch 

dbh that may be removed might be.

The DEIS states in the summary and the Proposed Action as well as an objective 

under the purpose and need that density management as described in the SNFPA 2004 

ROD is an integral part of this Project. The reasoning and scientific citations for this 

proposal are disclosed throughout the document and in some cases have been 

strengthened in the FEIS. Stand density is a function of the density of the stand, not a 

particular diameter of the trees within the stand. As stated in the DEIS, thinning 

would be done from below with the larger trees remaining in the stand.

JMP-2

There is no ecologically defensible 

evidence to indicate that the forests have 

too many large snags for the many 

wildlife species that need high levels of 

large snag density. 

Wildlife

The commenter states that there is no ecologically defensible evidence to indicate that 

the forests have too many large snags. The Grey’s Mountain Ecological Restoration 

Project would retain an average of nine snags per acre ≥10” dbh, and four large snags 

per acre (≥16” dbh) across the treatment units, which meets the requirement set forth 

in the SNFPA ROD S&G #11. The Grey’s Mountain Project seeks to retain all snags

except those that pose a direct safety hazard during project implementation. 

JMP-3

Nor is there any ecologically credible 

reason as to why the forest ecosystem, 

Wildlife

The commenter states that why the forest ecosystem, and the native wildlife species, 

would be better off if these mature trees are cut as opposed to remaining in the forest. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 402 Appendix G 

and the native wildlife species, would be 

better off if these mature trees are cut and 

placed on the bed of a log truck, as 

opposed to remaining in the forest 

ecosystem to provide habitat as mature 

live trees, large snags, and/or large 

downed logs.

Large tree mortality has significantly increased both in the southern Sierra Nevada 

(Bouldin 1999, van Mantgem and Stephenson 2007, Lutz et al. 2009) and within 

forests of the western United States (van Mantgem et al. 2009). The increase in large 

tree morality appears to be linked to fire suppression (Bouldin 1999, Lutz et al. 2009) 

and climate change (van Matgem and Stephenson 2007, van Mantgem 2009). 

Consequently, large tree mortality should not be “promoted” but rather should be 

mitigated in order to reduce the loss of these high value wildlife structures. Both 

large trees and snags should be retained when possible, and the “health” of large trees 

should be promoted when suitable to mitigate for the effects of amplified mortality 

rates in this size class. See responses to comments SC-25, SC-29 and SC-36.

JMP-4

the DEIS does not address the following 

alternative discussed in our scoping 

comments, or provide any rational 

ecological explanation as to why it is 

better for Pacific fishers, Spotted Owls, 

and other wildlife to remove mature trees 

16-30” dbh rather than actively turning 

them into snags, especially given the high 

importance of high snag density to Pacific 

fishers (Purcell et al. 2009):

an alternative in which, within the acres 

of natural forest proposed for 

mechanical/commercial thinning, instead 

of the live trees over 16” dbh being 

removed, the trees that would otherwise 

be marked for removal would instead be 

girdled or killed in some other way in 

order to actively recruit more large snags 

for wildlife, or such trees would be felled 

to provide large downed log structure for 

small mammals, amphibians, and 

Wildlife

The commenter’s proposed alternative was considered but eliminated from detailed 

study because it does not meet the purpose and need of the project. The first objective 

stated in the purpose and need is to: “Protect human communities from moderate/high 

intensity wild fires as well as minimize the spread of wildfires that might originate in 

urban areas into the forested lands created by unnaturally high levels of fuel ladders 

and dead and downed fuels”. The commenters proposed alternative states: “within the 

acres of natural forest proposed for mechanical/commercial thinning, instead of the 

live trees over 16” dbh being removed, the trees that would otherwise be marked for 

removal would instead be girdled or killed in some other way in order to actively 

recruit more large snags for wildlife, or such trees would be felled to provide large 

downed log structure for small mammals, amphibians, and invertebrates”. 

Implementation of this alternative would lead to even greater concentration of the 

already unnaturally high fuel levels, making the project area and nearby human

communities even more susceptible to impacts from an uncharacteristically severe 

wildfire. The BEBA analysis indicates that adequate levels of down woody debris and 

snags are currently present within the project area to provide for wildlife habitat, and 

design measures are in place to ensure that adequate levels of both habitat 

components shall be maintained post implementation. The Grey’s Mountain 

Ecological Restoration Project would retain an average of nine snags per acre ≥10” 

dbh, and four large snags per acre (≥16” dbh) across the treatment units, which meets 

the requirement set forth in the SNFPA ROD S&G #11. The Grey’s Mountain Project 

seeks to retain all snags except those that pose a direct safety hazard during project 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 403 Appendix G 

invertebrates. implementation.

Additionally, research has shown that large tree mortality has significantly increased 

both in the southern Sierra Nevada (Bouldin 1999, van Mantgem and Stephenson 

2007, Lutz et al. 2009) and within forests of the western United States (van Mantgem 

et al. 2009). The increase in large tree morality appears to be linked to fire 

suppression (Bouldin 1999, Lutz et al. 2009) and climate change (van Matgem and 

Stephenson 2007, van Mantgem 2009). Consequently, large tree mortality should not 

be “promoted” but rather should be mitigated in order to reduce the loss of these high 

value wildlife structures. Both large trees and snags should be retained when 

possible, and the “health” of large trees should be promoted when suitable to mitigate 

for the effects of amplified mortality rates in this size class. See responses to 

comments SC-25, SC-29 and SC-36.

JMP-5

In our scoping comments, we specifically 

asked the Forest Service to analyze the 

impacts of the project on future large snag 

basal area density levels, given: a) the 

project’s stated goal of reducing stand 

density to reduce competition between 

trees and, thus, reduce future large snag 

recruitment; and b) the fact that recent 

data show that high basal area density of 

medium and large snags (over 31 square

feet per acre) is one of the two most 

important habitat features for fisher 

resting habitat—right along with high 

canopy cover (Purcell et al. 2009). There 

is no analysis of this in the less than two 

pages of text in the DEIS (pp. 103-104) 

Wildlife

See responses to JMP 2, 3, and 8. 

The Forest found that future large snag basal area density levels were not the best 

indicator for pacific fisher effects nor for other issues raised by the public. Although 

your scoping comments may have included this suggestion valuable Project analytic 

resources were invested in areas that best addressed the significant issues identified 

from scoping comments (see DEIS pp 11 &12). An issue is defined in Forest Service 

policy as 1) a point of disagreement, debate, or dispute about the Proposed Action 

alleging feared or undesirable effects that would be caused by the Proposed Action. 

Although we strive to address the public’s requests for the content of the analysis it is 

important that NEPA documents focus on the significant issues. You will find a 

robust discussion of the alternative’s effects on stand density and the pacific fisher, 

both areas of resource concern mentioned in your comments.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 404 Appendix G 

purporting to analyze adverse impacts on 

the Pacific fisher. 

Detailed effects analysis for pacific fisher can be found in the Terrestrial Wildlife 

Biological Assessment/ Biological Evaluation for the Grey’s Mountain Project, pages 

80-160 (Otto, 2012) which is summarized in the DEIS for the Grey’s Mountain 

Project.

JMP-6

However, the DEIS provides no data on 

the projected mortality levels in Pacific 

fisher habitat under Alt. 3, does not 

discuss whether these projected mortality 

levels would be beneficial for the Pacific 

fisher by brining medium/large snag 

density up to desired levels of more than 

31 square feet per acre, and does not 

discuss whether the basal area of 

medium/large trees proposed for removal 

under the Proposed Action would be 

higher than the basal area of 

medium/large trees projected to 

experience mortality under Alt. 3. 

Wildlife

See responses to JMP 2, 3, 5 and especially 8.

Additionally DEIS Table 7 (pg 54) displays the following comparisons between 

Alternatives 2&3:

Estimated Range of Basal Area Remaining (ft2/acre) for >10-inch dbh trees

Estimated Range of Stems per Acre Remaining for >10-inch dbh trees (# trees/acre)

Estimated Range of Canopy Cover Remaining (%)

Estimated Range of Tree Diameter Remaining (> 10” dbh)

This information is a summary of the Vegetation Section (which can be review for 

more detailed information) and addresses the concern raised that the EIS does “not 

discuss whether the basal area of medium/large trees proposed for removal under the 

Proposed Action would be higher than the basal area of medium/large trees projected 

to experience mortality under Alternative. 3”. 

JMP-7

The DEIS repeatedly cites North et al. 

(2009) but fails to mention that this report 

discusses the “snag deficit” and warns 

managers to take steps to rectify this. 

Wildlife

North et al 2009 states: “Large trees and snags: Given their current deficit in mixedconifer forest and the time necessary for their renewal, protect most large trees and 

snags from harvest and inadvertent loss owing to prescribed fire.” The Grey’s 

Mountain Project proposes forest thinning that retains the majority of the forest 

biomass, including all large trees greater than 30 inches dbh and nearly all moderate 

sized trees 20-30 inches dbh, as well as many smaller trees, all oak trees, and all large 

snags unless deemed a safety hazard. We also included extensive areas of no thinning 

management within the project area to retain areas of high biomass density. Also see 

response to comment JMP-27.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 405 Appendix G 

JMP-8

Again, Purcell et al. (2009) found that 

medium/large snag basal area was found 

to be one of the top two variables (along 

with canopy cover) in predicting fisher 

use of rest sites. Purcell et al. (2009) 

found that fishers selected sites with 

medium/large snag basal area over 31 

square feet per acre, about two and a half 

times greater than that at random sites. 

Zielinski et al. (2006 [Table 2]) found that 

fishers selected sites with 15.4 large snags 

(over 38.1 cm in diameter, or over 15 

inches in diameter) on average per 0.5 

hectares, or about 12.5 large snags per 

acre. Zielinski et al. (2006) found that 

fishers selected sites with 65 large 

downed logs (over 25.4 cm in diameter) 

per hectare, or about 26 logs over 10 

inches in diameter per acre—substantially 

higher than large downed log density in 

the general landscape. 

Wildlife

Although large (>20 to 30” dbh) snags are important habitat structures for Pacific 

fisher and other wildlife species, assigning a strict value of 31 ft2

/acre of snags is not 

an appropriate management guideline for fisher. In fact, Purcell et al. (2009) took 

care not to assign a value in their management recommendations. There are several 

reasons for this: (1) snags use by fisher was low in frequency (15%) compared to live 

trees (76%), (2) the majority (>80%) of snags used as resting sites by fisher were >75 

cm dbh (>30” dbh), (3) habitat use analysis was restricted to resting sites (small scale) 

making extrapolations to larger scales tenuous, and (4) snag basal area may be related 

to other factors such as availability of prey (Purcell et al. 2009). Purcell et al. (2009) 

recommends that “management practices that support the growth and retention of 

greater numbers of large trees and snags...can improve and provide for future fisher

habitat.” Therefore, retaining large live trees and snags when possible is more 

appropriate than assigning a strict basal area value for snags in management of fisher 

habitat.

JMP-9

Nor is there any discussion of the 

imperiled status of the Pacific fisher 

population, or any citations to studies 

discussing the extremely small remaining 

population and the threats to it. 

Wildlife

Status of the fisher population, current fisher research, and threats to the population 

are discussed in detail in the fisher species account section of the Terrestrial Wildlife 

Biological Assessment/Biological Evaluation for the Grey’s Mountain Project, pages 

80-106 (Otto, 2012), the main conclusions and determinations of which are 

appropriately summarized in the DEIS for the Grey’s Mountain Project.

JMP-10 Wildlife
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 406 Appendix G 

Finally, the DEIS fails to identify Pacific 

fisher den-sites, home ranges, and recent 

detections within the project area—

particularly relative to proposed logging. 

Detailed effects analysis for pacific fisher including information on fisher den sites, 

home ranges, and detections within the project area, can be found in the Terrestrial 

Wildlife Biological Assessment/ Biological Evaluation for the Grey’s Mountain 

Project, pages 80-160 (Otto, 2012) the main conclusions and determinations of which 

are summarized in the DEIS for the Grey’s Mountain Project.

JMP-11

A supplemental draft EIS must be 

prepared for this project to analyze the 

alarming new information showing that 

California Spotted Owl (CSO) 

populations in the central Sierra Nevada 

study area has been declining 

precipitously over the past decade and 

more—contrary to the previous 

representations from the Forest Service 

that no such decline was occurring 

(apparently some errors were caught, and 

corrected, recently, resulting in the new 

data showing declines). Please see 

SNAMP (2011) attached hereto (see pp. 

33-34 of that document). In light of this 

information, the Forest Service’s standing 

assumption/representation that population 

trends of California spotted owls are 

“stable” (DEIS, p. 116) must be 

reassessed, and can no longer be taken as 

true. 

Wildlife 

The BE/BA has been revised to include the latest results from the SNFPA California 

spotted owl demography studies including Scherer et al 2010, and Munton et al 2012.

See also comment response SFL-7.

Results of this latest information have been incorporated into the BE/BA and the 

FEIS. And we do not agree with the interpretation made in the comment pertaining to 

significant declines and how that this specifically 

The results of spotted owl demographic studies in Lassen and Eldorado National 

Forests are for national forests more than 200 miles north of Sierra National Forest, 

yet the same demographic study was also conducted in Sierra National Forest over the 

past 20 years, and that study shows a stable spotted owl population. This study area 

also includes areas where vegetation management projects have successfully been 

implemented. 

Additionally, the final report of the Eldorado National Forest study shows that owl 

population has been stable since the beginning of the study and that further 

monitoring is needed before making conclusions about a long-term population 

decline, as quoted here. 

“The finite rate of population change that we estimated using mark-recapture data 

from the Eldorado Density Study Area indicated that the population size has been 

stable since the beginning of the study, although we have observed a gradual decline 

in the realized population change over the last 10 years. This suggests that continued 

monitoring will be needed to assess whether a long-term population decline is 

underway.” (Gutierrez et al., 2011)

It is also important to understand that the population decline in the local population of 

Lassen NF is not the full and true picture of the spotted owl population across the 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 407 Appendix G 

region. These three demographic studies were designed to only assess population 

change; they were not designed to determine the cause and effect of changes in 

populations, as insinuated by the commenter. Changes in populations can be caused 

by any number of single or combined factors and thus far there is no evidence that our 

forest management is a cause in the decline of the Lassen NF population. On the 

contrary, our carefully designed and professionally managed forest management 

projects help sustain spotted owl habitat. Specifically, these projects retain most large 

trees greater than 20 inches dbh; most large snags; moderate and high overstory forest 

canopy cover; most black oaks; and many other habitat components needed by 

spotted owls. Just as important, our management helps ensure that habitat remains on 

the landscape for those owls, by reducing the potential for large scale, severe 

wildfires that have catastrophic negative results on owl populations. It is important to 

understand that the viability of spotted owls in the Sierra Nevada will be jeopardized 

if we are unable to conduct carefully planned fuels reduction and forest restoration 

treatments, such as this project, and others implemented under the 2004 ROD 

direction.

The FEIS has been strengthened to clarify the alternatives and their effects on CSO as 

appropriate. 

As per FSH 1909.15 Chap 10 Section 18.2 (2)(c)(1) “Supplement - Agencies: (1) 

Shall prepare supplements to either draft or final environmental impact statements if: 

(i) The agency makes substantial changes in the proposed action that are relevant to 

environmental concerns; or (ii) There are significant new circumstances or 

information relevant to environmental concerns and bearing on the proposed action 

and its impacts.”

The referenced CSO information was determined not to be a significant change to the 

analysis because it did not change the final overall effects analysis. The DEIS 

Proposed Action has not been revised nor has the SNF found there to be new 

circumstances or information which would require supplementation. Therefore 

recirculation of a revised or supplemented DEIS is not required.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 408 Appendix G 

JMP-12

Moreover, the DEIS does not adequately 

analyze the fact that recent research 

reveals that California spotted owls 

preferentially select unlogged highintensity fire patches for foraging, while 

selecting unburned or low-severity areas 

for roosting (Bond et al. 2009). Highintensity fire patches enhance habitat 

(e.g., montane chaparral, large downed 

logs, snags) for the Spotted Owl’s small 

mammal prey species (Bond et al. 2009). 

The most recent scientific evidence makes 

clear that Spotted Owls benefit from 

natural heterogeneity created by patches 

of high-severity fire—habitat that is not 

mimicked by logging. Bond et al. (2009) 

indicates that unlogged patches of highintensity fire comprise a newly discovered 

category of suitable habitat for California 

spotted owls. It is no longer scientifically 

defensible to simply cite to previous 

studies, such as Verner et al. (1992), 

which did NOT investigate whether 

burned forest was suitable for Spotted 

owls, in order to arbitrarily define suitable 

Owl habitat in a way that includes only 

unburned forest, and ignores important 

new scientific findings.

Wildlife

The commenter is concerned that the DEIS does not adequately analyze the fact that 

recent research reveals that California spotted owls preferentially select unlogged 

high-intensity fire patches for foraging, while selecting unburned or low-severity 

areas for roosting (Bond et al. 2009). There is an important distinction between 

habitat use and habitat suitability. Bond et al. (2009) only addresses the former, as no 

information related to California spotted owl demography or occupancy rates or 

habitat quality measures were evaluated in this brief study. Moreover, the results 

from Bond et al. (2009) are highly limited due to (1) extremely low effective sample 

size (e.g., owl pairs are not independent during the nesting season), (2) lack of prefire data, and (3) lack of information as to whether studied owls were inexperienced 

population ‘floaters’ or pre-fire residents, and (4) limited sample size, area, and extent 

of vegetation plots. Consequently, not all high-severity burned areas can be 

considered suitable habitat for California spotted owls. Further research will be 

required to thoroughly evaluate this question. Please also see the Grey’s Mountain 

Project Terrestrial Wildlife BEBA page 42 for further discussion on spotted owl 

habitat use as it relates to fire. As this research has been considered during the 

analysis and prior to the decision the DEIS adequately analyzes recent CSO research 

the commenter cites.

JMP-13

Scientific evidence regarding spotted owls 

in northwestern California and in Oregon 

Wildlife

Franklin et al 2000 concluded that some degree of habitat heterogeneity promoted 

fitness in Northern spotted owl territories. Restoring important forest characteristics 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 409 Appendix G 

found that positive trends in survival and 

reproduction depended upon significant 

patches of habitat consistent with highseverity post-fire effects (e.g., montane 

chaparral patches, snags, and large 

downed logs) in their territories because 

this habitat is suitable for small mammal 

prey species of the owl, including the 

Dusky-footed Woodrat (Franklin et al. 

2000, Olson et al. 2004). This habitat is 

not mimicked by logging as proposed by 

this project, which does not create an 

abundance of snags and large downed 

logs, and which seeks to reduce shrub 

cover. If your stated project objectives 

are achieved, you could not only render 

thousands of acres of spotted owl habitat 

unsuitable or marginally suitable in the 

present and near-term, but could also 

reduce survival and reproduction by 

preventing occurrence of natural post-fire 

habitat heterogeneity in the spotted owl 

territories.

such as heterogeneity is one of the main stated goals of the Grey’s Mountain 

Ecological Restoration Project.

The dusky-footed woodrat depends on forest habitats with moderate canopy, yearround greenery, and a brushy understory. (Zeiner et al 1990). Snags and downed logs 

will be retained throughout the treatment units at levels commensurate with Standard 

and Guidelines 10 and 11.

Shrub and understory diversity will be retained throughout the project area. For 

example, all understory vegetation will be maintained in Old Forest Linkages 

associated with riparian areas (typically cooler, moister sites); black oak buffer zones; 

as well as areas where no treatment will be conducted such as heritage resource sites, 

botanical areas, slopes >35%, and rocky areas (see Figure 24 for OFLs and untreated 

areas). As part of this management, tree species associated with riparian areas, such 

as dogwoods, alders, and willows will not be removed. In addition, 15-20% of the 

understory growth in treatment areas will be retained post treatment. This understory 

growth will be preserved in pockets that are at least 1/10 acre in size throughout 

plantations, and at least 1⁄4 acre in wild stand treatment units. This will preserve stand 

diversity while decreasing the threat posed by ladder fuels. It is important to note that 

many shrub species that are impacted either by underburning or mastication activities 

will re-sprout, thus providing young growth as forage and browse for herbivores. This 

forest management also will lead to greater herbaceous vegetation growth as the 

canopy is partially opened in some areas, allowing more sunlight to reach the forest 

floor, thus providing greater levels of forage for small mammals, birds, and 

invertebrates.

JMP-14

Without an affirmative statement in the 

action alternatives, designating this 64% 

of the project area as an area that would 

purposefully remain available to have 

mixed-intensity fire for some specified 

period of time (e.g., 20 years—the general 

analysis timeframe of the DEIS) during 

which thinning would not occur, and that 

Wildlife

Please see comment response to SC- 18. For the foreseeable future the SNF has no 

plans to treat the Project area that is designated as untreated. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 410 Appendix G 

if mixed-intensity fire did occur within 

this time period it would not be subjected 

to post-fire logging, the DEIS’s statement 

about potential mixed-intensity fire 

effects creating Black-backed 

Woodpecker habitat on this 64% of the 

project area is meaningless, and amounts 

to an effort to minimize adverse impacts, 

in violation of NEPA’s hard look

standard. 

JMP-15

The DEIS simply does not adequately 

discuss the potential adverse impacts of 

the Project on the Black-backed 

Woodpecker, which is the only MIS 

bellwether species for all wildlife species 

associated with snags in heavily burned 

forest.

Wildlife

We did not assess black-backed woodpeckers because black-backed woodpecker 

habitat is not within the project area. Black-backed woodpeckers on the Sierra NF are 

an MIS for the ecosystem component of snags in burned forest. Since the project will 

not directly affect the ecosystem component of snags in burned forest, the blackbacked woodpecker is not an appropriate MIS for the Grey’s Mountain project. In 

addition, Studies conducted by the USDA Pacific Southwest Research Station found 

that on the Sierra National Forest, black-backed woodpeckers inhabit high elevation 

lodgepole pine forests at low densities, they appear to breed successfully there, and 

this habitat does not appear to be sink habitat (Purcell, 2011 pers. comm.). Therefore, 

In the Sierra Nevada, although black-backed woodpeckers also are associated with 

moderate- and high-severity burns, they can also inhabit high-elevation lodgepole 

pine but not dependent on them (Purcell, 2011 pers. comm.). The Sierra National 

Forest has approximately 32,000 acres of high elevation lodgepole pine forests, and a 

large portion of that habitat is conserved within the Wilderness Areas During the past 

decade from 2000 through 2010, the Sierra National Forest has experienced a total of 

53 wildfires totaling 28,419 acres, with an average fire size of 536 acres. 65% of the 

total acres burned during this period were categorized as moderate and high severity 

burned areas, which create the habitat types preferred by the black-backed 

woodpecker (USDA FS 2010). One recent wildfire on the Bass Lake RD, the Oliver 

fire, burned a total of 2,800 acres in June of 2008. The Institute for Bird Populations 

has surveyed the Oliver fire for black-backed woodpecker presence each year (2009, 

2010, and 2011) since its occurrence. They did not detect black-backed woodpeckers 

in 2009 or 2010, but in 2011 they detected black-backed woodpeckers at more than 

JMP-16

The Forest Service has not provided 

information showing the quantity and 

quality of habitat necessary to ensure 

viable populations of Black-backed 

Woodpeckers within the Sierra Nevada 

planning area, including the minimum 

viable population threshold and the

minimum threshold amount of suitable 

habitat necessary to support minimum 

viable populations in the Sierra Nevada. 

Without this information, the Forest 

Service cannot ensure the viability of this 

species, in violation of the forest plan and 

Wildlife
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 411 Appendix G 

NFMA. one third of their survey stations (6 of 17 call stations).

The implementation of projects designed to reduce fuel loading and fire severity does 

not preclude the occurrence of wildfire across the landscape, it merely seeks to lessen 

the extent and severity of such fires when they occur. Since treatments for the Grey’s 

Mountain Ecological Restoration project are limited to a maximum of 3,556 acres out 

of the 9,600 acres within the project boundary (37% of the total area), there remains 

potential for low and moderate severity fire to occur throughout the entire project 

area, and the potential for high severity fire to occur within the untreated portion of 

the Grey’s Mountain project boundary (63% of the total area). It is reasonable to 

conclude that wildfires of all severity types will continue to occur across the Bass 

Lake Ranger District and the Sierra National Forest, even after the implementation of 

the Grey’s Mountain Ecological Restoration project. Therefore, habitat for the blackbacked woodpecker will likely continue to increase on the Bass Lake district and 

across the Sierra NF. Furthermore, current data at the range wide, California, and 

Sierra Nevada scales indicate that the distribution of black-backed woodpecker 

populations in the Sierra Nevada is stable (USDA FS 2010). Current science indicates 

that the total area of high severity burned forest in the Sierra Nevada is not lower than 

historic reference conditions (Safford 2010) and the size of high severity burned 

patches has significantly increased (Miller et al. 2008). The entire western United 

States has experienced higher large-wildfire frequency, longer wildfire durations, and 

longer wildfire seasons since the mid-1980’s (Westerling et al. 2006).

JMP-17

The DEIS cryptically claims that, due to 

insects and competition between trees, 

stand density must be substantially 

reduced supposedly in order to improve 

the ecological health of the forest. The 

DEIS uses meaningless, and hyperbolic, 

qualitative terms like “large losses” (p. 

204) and “high” mortality, but fails to 

describe the levels of basal area mortality 

that would likely occur under No Action 

of Alt. 3—particularly relative to the 

Silviculture

The stand density sections referenced in comment JMP-17 describes peer reviewed 

research by numerous researchers who draw the same conclusions that density

management needs to be undertaken to minimize the potential loss due to 

Dendroctonus bark beetles. The reference to:”large losses” is a quote from Oliver’s 

1995 research and as such cannot be quantified by anyone other than the researcher. 

Other references to mortality are also from peer reviewed research and therefore 

cannot be quantified by the Forest Service. 

Sartwell (1971) —corrected to 1975 for the FEIS)’s research in pine stands uses a 

threshold of 150 ft2 per acre with which Oliver concurred (1995). Ferrell (1996) and 

Larrson, et al. (1983) also use the same 150 ft2 as the basal area below which 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 412 Appendix G 

direct mortality from chainsaws under the 

Proposed Action, and how or why 

additional medium and large snags would 

be undesirable ecologically. The DEIS 

grossly misrepresents the data and 

presents it in a seriously misleading 

fashion, implying that high, and 

ecologically undesirable, levels of tree 

mortality will occur if intensive 

commercial thinning, as proposed, does 

not occur. This is flatly erroneous. 

extremely high tree mortality can be prevented.

Oliver (1995, 2009) states pine stands should be thinned to a SDI of 230 or lower. 

Cochran and Barrett (1999) state that the upper limit SDI for pine should be 240.

The DEIS presents the peer reviewed findings of the previously mentioned 

researchers. The DEIS, p 209, states the target leave basal area in pine would be 

between 150 and 180 ft2 (depending on crown condition). (The desired basal area, 

DEIS p. 204, would be 150 ft2—approximately a SDI 230). Thinning to this level 

would reduce the stocking to the threshold level, not below. As described in the 

DEIS, density management is one of the objectives of this project in order to improve 

stand resistance to drought, insects, and disease by reducing inter-tree competition 

and improving tree vigor as described in the SNFPA 2004, ROD.

The DEIS abstract describes that the ecological restoration goals of the Greys 

Mountain Project are multi-faceted and include: (1) increase forest resilience to 

insects, disease, and drought through prescribed fire and mechanical thinning 

treatments, (2) promote heterogeneity in forest structure for improving wildlife 

habitat, as well as others. Density management through thinning would be 

undertaken to accomplish these goals. The body of the DEIS describes the 

environmental effects of these proposed treatments. 

As stated above, goals of the project are to work towards restoring proposed treatment 

areas to a more historical condition found prior to the 20th Century. 

Treatments would result in:

(1) increasing the growth and reducing drought-stress to large-diameter pines and 

oaks by removing shade-tolerant competitors, (2) increasing stand heterogeneity and 

enhancing regeneration of shade-intolerant pines and oaks through the creation of tree 

gaps or increase in size of existing small-sized gaps (Bonnicksen and Stone 1983), (3) 

increasing long-term carbon sequestration by increasing growth rates of largediameter fire-resilient trees (North et al. 2009b), and (4) reducing stand densities to 

promote tree growth and forest stands that are resilient to fire, insect outbreaks, and 

future climate change.

There is ample evidence that fuel and forest restoration treatments will be effective at 

reducing fuel loads, fire severity, and crown fire risk when ground fuels are treated 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 413 Appendix G 

with ladder fuels (e.g., Stephens et al. 2009, North et al 2009a, North et al. 2009b).

There is also sufficient scientific support for fuel treatment effectiveness in mitigating 

the negative impacts of wildfire (e.g., Skinner et al. 2004, Safford et al. 2009).

Inventory data for the project area indicates snag and large down log numbers within 

the project area presently meet LRMP standards. Existing snags and down logs are 

not planned to be treated. Commercial thinning is estimated to be conducted on about 

1556 acres out of the 9600 acres within the proposed project boundary. Within this 

acreage there are between 500 and 700 clumps of larger diameter trees where no tree 

larger than 20 inches dbh would be removed. These clumps would retain basal areas 

substantially above desired for the surrounding stand. These more densely stocked 

clumps along with Stream Management Zones, and other non-treatment areas would 

provide snag and large down log recruitment sites. Existing down logs and snags in 

non-treatment areas would remain. Non-treatment areas would provide a source for

recruitment of additional down logs and snags

JMP-18

Further, despite modest mortality as 

stands neared SDI of 365, the stands 

ultimately continued to grow more mature 

and more dense, reaching an SDI of 571 

finally (Fig. 1 A-C of Oliver 1995). 

Silviculture

Oliver’s 1995 paper does not mention a SDI of 571. The highest SDI referred to in 

that paper is 500 (“the maximum number used in Region 5 or 429 used in Region 6 

for Forest Vegetation Simulators”). Oliver states this is the maximum value caused 

by competition induced mortality. He states the limiting SDI of 365 is considerably 

below that number. Oliver refers to a SDI of 365 as the limiting SDI for ponderosa 

pine stands in northern California as defined by Dendroctonus bark beetles (DEIS 

p204). 

Oliver’s conclusions in his 1995 report as well as his 2009 declaration, Exhibit 1, 

referenced in JMP-19 below, are that thinning in pine stands should be done to a SDI 

of 230 or lower (DEIS p204). His 2009 declaration further states “it would make 

little sense to rely upon a hypothetical SDI-Max of 500 or more in designing a forest 

health improvement project under such conditions, since that higher number is not 

applicable where bark beetles present a serious risk of mortality.”

As stated in the response to JMP-19 below, Cochran and Barrett (1999) stated that a 

SDI of 240 should be the upper limit for management.

SDImax is not used in this FEIS for determining treatments. Treatment proposals as 

they relate to Dendroctonus bark beetles and ponderosa pine utilize treatment values 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 414 Appendix G 

recommended by various researchers as cited in the DEIS and FEIS.

JMP-19

Oliver (2005) found that the very densest 

pine plots increased to a basal area of 175 

square feet per acre, and an SDI of around 

350, and then experienced beetle 

mortality of only 17% of the basal area 

(down to about 145 square feet per acre). 

In the ponderosa pine plots in California, 

the densest plots increased to a basal area 

of about 220 with very low beetle 

mortality (5-20% periodically, followed 

each time by a gentle increase in basal 

area) after the stands reached about 85 

years of age (Oliver 2005, Fig. 1). The 

stands in the Project area are over 85 

years of age. Oliver (2005) noted that 

mortality levels have “declined over the 

years” in the eastside ponderosa pine 

forests as these forests have grown older 

and denser. 

Further, the Cochran and Barrett (1995) 

study investigated pine stands and found 

that, even at higher SDI levels, “there was 

no apparent correlation between stand 

density and mortality” (see p. 9 of 

Cochran and Barrett 1995). In that study, 

the highest annual growth rates were at 

SDI values over 200 (Figs. 14, and 18-20 

of Cochran and Barrett 1995). The 

Silviculture

Oliver, 1995, conclusions state:”Sartwell’s threshold of 34m2 per ha (150 ft2 per acre 

of basal area above which density stands are susceptible to attack by bark beetles 

appears to be a reasonable average value for California” (DEIS p208). “The limiting 

SDI for ponderosa pine stands in northern California as defined by Dendroctonus 

bark beetles is 365. SDI 230 defines the threshold for a zone of imminent bark beetle 

mortality within which endemic populations kill a few trees but net growth is still 

positive” (DEIS p204). Ferrell, 1996, states extremely high tree mortality can be 

prevented by reducing stand densities below 150 ft2 per acre in basal area. 

Oliver in his 2005 study does not draw any conclusions in this report. He references 

his 1995 report but gives no indication that his 1995 conclusions were invalid. On the 

contrary, he states in his declaration, Exhibit 1, Document 60-2, Case 2:08-cv-01897-

JAM-JFM Filed 8/19/2009—Earth Island Institute vs. Randy Moore and the Lassen 

NF, that “it is proper to use 365 as the SDI-Max for ponderosa pine, Joseph Sherlock 

correctly states in his paper ‘Integrating Stand Density Management With Fuel 

Reduction’ that ‘Bark beetles define ponderosa pines maximum SDI at 365....’ This 

finding did not mischaracterize my 1995 paper, but instead recognized that the 

limiting SDI of 365 becomes practical maximum SDI where bark beetles are present.” 

“Although stands with greater SDI do occur, bark beetles soon reduce their density, 

and thus 365 is a more reasonable measure of maximum density.” He goes on to 

state: “For a forest-thinning project in a stand dominated by ponderosa pine in 

California, that would mean thinning to or below an SDI of approximately 230, 

referred to as the ‘zone of imminent bark beetle mortality.’”

The data presented in the comment is used by Cochran and Barrett (1995) to form 

their conclusions. It is not part of their conclusions. Cochran and Barrett (1995) 

concluded that mortality in high (ponderosa pine) stand densities may be severe and 

individual tree sizes will be lower than in stands managed at lower densities. They 

stated: “thinning from below to low densities would speed up the development of 

large trees in second growth stands.” They further stated that “once stands reach 

commercial size, thinning to maintain low stand densities will be necessary to reduce 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 415 Appendix G 

maximum basal area mortality of any plot 

(i.e., not the average) was only 29%, and 

most plots had far, far less mortality than 

this. The “high” mortality rates in 

Cochran and Barrett (1995) were only 

about 5-10% of the basal area and less 

than 5% of the SDI for the very densest 

plots (Figs. 1 and 2 of Cochran and 

Barrett 1995). 

Similarly, Cochran and Barrett (1999) 

found essentially the same thing as Oliver 

(2005), discussed above. The study found 

that, once ponderosa pine stands became 

older than 85 years of age (like those in 

the Project area), mortality from beetles 

dropped to nearly zero even at SDI values 

of 250-300 (see Fig. 3 and Table 3 of 

Cochran and Barrett 1999). Even when 

the stands in this study area were younger, 

as they were when studied by Larsson et 

al. (1983), the mortality levels from 

beetles were still relatively modest for 

stands with basal areas over 150 square 

feet per acre (i.e., a minority of the total

stand basal area). 

Youngblood et al. (2004) found old 

ponderosa pine forests to remain stable at 

SDI levels of more than 500, with only 

about 10% periodic basal area mortality 

(see Table 1 and Fig. 6 of Youngblood et 

al. 2004). 

the probability of serious problems with mountain pine beetles and perhaps western 

pine beetles (Dendroctonus brevicomis Le Conte).” (DEIS, p208)

The data presented in the comment is that used by Cochran and Barrett to form their 

conclusions and is not a part of their conclusions. Their conclusions follow (exerted 

from the DEIS, p208): In a follow-up paper, Cochran and Barrett (1999) concluded 

that mechanical thinning would result in greater stand and individual tree growth than 

would occur through bark beetle mortality that resulted in the same overall stand 

density. The conclusions stated that density management (in second-growth 

ponderosa pine stands) “is necessary to speed development of mid and late seral size 

and density conditions.” They further concluded that a SDI 240 should be the upper 

management zone on a high site and “should lower the probability of serious 

mortality from mountain and perhaps western pine beetles.” Their study also noted 

that ponderosa pine responds well to increased growing space even at advance ages 

and should continue to grow well until stands are very old. 

 Larsson, et al. (1983) recommended the following: “for management of ponderosa 

pine, we recommend careful attention to stocking control if risk of mountain pine 

beetle is to be minimized. In this study, a basal area below 34m2/ hectare (the same 

150 ft2/acre as Sartwell recommended) provided the most trees with a vigor level at 

which they could withstand at least moderate attack” (by beetles). He went on to 

state “the susceptibility of ponderosa pine forests to damage from mountain pine 

beetle is closely related to tree vigor, which has been demonstrated to respond to 

stocking control” (DEIS p205).

Reviewing the data for the Youngblood, et al. (2004) report, it was found that the 

highest SDI of trees 10 inches dbh and larger was around 282 at Pringle Butte. The 

SDI 500 number that is referred to is for all stems 4.5 feet and taller. The upper 

canopy SDI 282 is according to the paper for stems around 10 inches and larger. 

(SDI numbers used in the Greys DEIS are for trees 10 inches dbh and larger).

The Youngblood, et al, (2004) study was designed to attempt to determine what 

stands were like pre-1900 as well as what were the historical ranges of tree densities. 

This study found that around 22 trees per acre (24 inch avg. dbh) were found in the 

upper canopy (dominant & codominant) layer (generally trees over 100 years of 

age)(52% of the SDI). They characterized the lower canopy layer (intermediate & 

suppressed), around 648 trees per acre (3 inch avg. dbh), as less than 100 years of age 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 416 Appendix G 

(48% of the SDI). They attributed this recruitment of younger trees to gradual 

climate warming, above normal precipitation, and exclusion of fire. They further 

characterized this high density of smaller trees as “a pervasive characteristic across 

much of the ponderosa pine ecosystems (Arno, 1988; Covington et al, 1997; Fule’ et 

al., 1997, Kaufmann et al., 2000; Brown et al., 2001).” “The single most dramatic 

difference between historic and present-day conditions.” They expressed concern that 

the increased density of stems may negatively impact growth rates of large live trees 

and contribute eventually to accelerated snag creation.

Prior to active fire suppression the density of the lower canopy layer and, therefore, 

high SDI would not have been present.

As disclosed in response to JMP-18, Oliver acknowledged that SDI’s of 500 can be 

found but stated that forest health projects should not be designed around them.

Cochran, et al., 1994, stated that although some sites appear capable of supporting 

much higher densities, they did not recommend using an SDI higher than 365 for 

ponderosa pine as the upper limit for full stocking. 

(The target leave SDI for pine stands in the Greys Project is 230 to 270)(DEIS p.209). 

(These target SDI levels are generally higher than those recommended by Oliver, 

Cochran and Barrett.) As described in the DEIS and FEIS, target leave SDI figures 

for pine stands utilize SDI levels recommended by various researchers cited in these 

documents. 

JMP-20

The DEIS (pp. 203-204) also cites Meyer 

(1938), implying that high tree mortality 

occurs if ponderosa pine has basal area 

over 150 square feet per acre. However, 

Meyer (1938) says nothing of the sort. 

Meyer (1938) shows that, for stands with 

site indices of 80 or more, basal area is 

generally over 200 to 300 square feet per 

acre at stand ages of 80 years or older (see 

Table 4 of Meyer 1938). In a ponderosa 

pine stand with a site index of 80, growth 

Silviculture The DEIS does not imply that the Meyer (1938) yield tables show high tree mortality 

at basal areas over 150 ft2 per acre. References to 150 ft2 basal area and potential 

mortality losses due to bark beetles were to findings of Sartwell (1975), Oliver 

(1995), and Larsson, (1983), all of whom concurred that a basal area of 150 ft2 per 

acre was the density where pine stands are susceptible to attack by bark beetles (DEIS 

p. 204-205). The DEIS p. 204, states: “Susceptibility to excessive tree mortality 

from bark beetles can be lessened by reducing stand density below 150 ft2 per acre in 

basal area [Sartwell (1976)--corrected in FEIS to 1975](Oliver, 1995)”. “Larsson 

(1983) states: ‘a basal area below 34m2

/ha (150 ft2/acre) provided most trees with a 

vigor level at which they could withstand at least moderate (insect) attack.’” The 

response to comment JMP-17 further describes thinning levels recommended by a 

number of researchers.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 417 Appendix G 

is 61 cubic feet per year at a stand age of 

80, and 89 cubic feet per year in a stand 

of 100 years old (see Table 21 of Meyer 

1938). In ponderosa pine stands 80-100 

years old with a site index of 80, mortality 

is only 465 cubic feet over 20 years—i.e., 

only about 23 cubic feet per year; and 

mortality is only 722 cubic feet over 20 

years, or only 36 cubic feet per year, in 

stands 80-100 years old with site index of 

100 (see Table 18 of Meyer 1938). Thus, 

based upon this huge data set of actual 

conditions from Meyer (1938), growth 

greatly exceeds mortality in ponderosa 

pine stands, even at basal area densities 

well above 200. 

The DEIS describes the Meyer (1938) ponderosa pine yield table on p 203. It states 

the following: “A normal stand—or fully stocked stand—is a stand that, so far as any 

practical consideration is involved, utilizes its site completely. Maximum stocking is 

not implied; it practically never exists over a continuous area of more than a few acres 

(Meyer, 1938). For a short period of time, basal areas in excess of ‘normal’ can be 

maintained in some areas.” Basal Area is the primary method used in this document 

to describe treatment proposals in relation to full site occupancy. Meyer’s tables are a 

measure of full site occupancy. Since Meyer’s tables represent full stocking, he 

searched for stands that fully occupied each site class. They are not an indicator of 

mortality that can be expected from disturbance factors such as insects or drought. 

Yield tables are used to determine appropriate treatment levels that will more fully 

utilize the growth potential of a given site. An example from Smith (1962, 1986) 

displaying how a series of treatments would be undertaken to maintain or improve 

growth and vigor of a stand using Basal Area has been added to the Basal Area 

Stocking Levels section of the FEIS.

The DEIS, p209, discloses that normal (full) basal area stocking for pine stands for

the Greys Mountain sites is 270 to 290 ft2 per acre. This upper limit was used to 

determine desired basal area stocking for pine following treatment. 

As stated by the commenter, Meyer’s tables do not display mortality that can be 

expected. They display full site occupancy basal area per acre at different ages on 

various soil productivity sites.

Oliver (1995, 2009), Cochran and Barrett (1995, 1999), and other peer reviewed 

papers referenced in the DEIS describe SDI as it relates to insect induced mortality. 

Using Meyer’s Basal Area Table 4, Site Index 80 at 60 years of age has a Basal Area 

of 198ft2 which is 100% of Normal Stocking (full stocking). Site Index 110 at 60

years is fully stocked at 243ft2

. Using these tables, Basal Area per acre does not 

increase as the stand becomes older since as additional basal area growth occurs on 

residual trees, others will die and drop out of the stand so the total basal area remains 

the same. The commenter has misread Table 21. At age 80 on a Site Index 80, 

annual growth was 61 cu ft./yr, by age 100 it had dropped to 56 cu ft./yr indicating a 

decline in growth rates. (Gross cubic foot growth in this table includes growth of 

trees 0.6 inches dbh and larger. This table does not include mortality.) Trees will 

continue to have some height and diameter growth, although at declining rates, which 

will result in increased cubic volume per acre. Diameter growth will be small. 

Cochran and Barrett (1995) state high densities will produce the most gross cubic 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 418 Appendix G 

volume, but mortality may be severe. 

Table 3 displays that during the same referenced 20 year period 1/3 of the trees within 

the fully stocked stand died (which would have added additional fuel loading). 

Table 5 displays the average diameter of trees in the referenced 80 year old, site 80, 

stand was 9.6 inches and only 11.7 inches 20 years later--2 inches larger.) Thinning 

can greatly enhance diameter growth of residual trees over this same time span. A 

thinned stand over the same 20 year period would have substantially larger diameters 

(Cochran and Barrett, 1995).

The DEIS, p. 7-8, states that treatments will follow the principles of North (2009) 

GTR 220 which describes the need for density management and reducing the 

percentage of shade tolerant fir and incense cedar and encouraging growth of larger 

diameter trees through thinning. Cochran and Barrett (1999) stated that density 

management (in second-growth ponderosa pine stands) “is necessary to speed 

development of mid and late seral size and density conditions.” Cochran and Barrett 

(1995) stated that thinning from below to low densities would speed the development 

of large trees in second-growth stands. As stated previously, the basal area tables are 

being utilized to determine desired stocking levels in the residual stand that will result 

in achieving 80 percent of normal stocking 15 to 20 years later (DEIS p. 204). The 

DEIS p. 209 describes the anticipated increased basal area growth as a result of 

thinning compared to no thinning. 

As previously stated, normal yield tables display the basal area levels of stands that 

are fully utilizing various sites by site quality. Full utilization of the site favors 

retention of shade tolerant, fire prone fir and incense cedar to the determent of pines 

and oaks. North (2009) and others describe open pine stands prior to the 1900s, not 

fully stocked stands. Retention of full or close to full stocking does not provide a 

safety margin for a stand to respond to changes in weather patterns that are being 

predicted to continue. The DEIS p. 208 states maintaining stocking levels at 80 

percent or less of full (normal) stocking would ensure a healthy rate of growth while 

retaining a level of stocking that would be better able to survive the lower levels of 

yearly precipitation that were common prior to the past century. This will help 

provide a safety margin for the predicted impacts of insects, diseases and drought and 

grow larger diameter trees more quickly, more fully utilize the growth capabilities of

the site, and retain greater numbers of intolerant pines and oaks.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 419 Appendix G 

JMP-21

The DEIS claims (p. 203) that Meyer 

(1938) may overestimate growth because 

it was conducted during “the abnormally 

wet 20th Century”. However, the DEIS 

cites no data to support its contention that 

precipitation has declined, and the Sierra 

National Forest’s records in other 

analyses indicate that annual precipitation 

has increased, not decreased, in recent 

decades. Moreover, Crimmins et al. 

(2011) report increases in precipitation in 

forests of the Sierra Nevada. 

Silviculture

The Basal Area Stocking Levels section of the DEIS is stating that the maximum 

basal area of fully stocked sites described in the normal yield tables may be too high 

in relation to what may be maintainable under the changing weather patterns that are 

predicted to occur. 

The DEIS, p. 203, states that normal yield tables were calculated during “the 

abnormally wet 20th Century” and may overestimate the maximum basal area sites 

can maintain under drier conditions. A citation has been added to the reference to the 

abnormally wet 20th Century (SFNPA, 2004, ROD). The DEIS does not state that 

precipitation has declined. It refers to “drier periods that are more likely the norm”. 

The FEIS has been rewritten to state that these stocking levels are likely too dense to 

be maintained during the predicted longer, hotter, more moisture stressed summers 

that are described in the Climate Shifts section. North (2009) states: “most models 

predict the southern Sierra will receive less precipitation, with a higher percentage of 

it occurring as rain rather than snow”. He goes on to state that “the climate will 

become more extreme, suggesting oscillations between wet and drought conditions 

will be more common.”(See DEIS p. 238) North (2009) goes on to express that 

“drought stress would make current, high-density, Sierra forests more susceptible to 

pest and pathogen mortality, particularly from bark beetles (Ferrell 1996, Fettig et al. 

2007, Maloney, et al 2008, Smith et al. 2005).”

JMP-22

For fir-dominated stands, maximum stand 

density index is even higher than it is for 

ponderosa pine, and is generally around 

800 (Oliver and Uzoh 1997). 

Silviculture

Stand Density Index was not used to describe treatments in fir—only pine as it relates 

to insect attack (DEIS p204)

Fir stands would be expected to have higher SDIs than pine since they support higher 

basal areas per acre than pine.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 420 Appendix G 

JMP-23

The DEIS misuses and misrepresents the 

term “resilience”. (pg 6)

If it is the Forest Service’s intention to 

promote engineering resilience, to the 

detriment of native biodiversity and 

natural ecological disturbance processes, 

rather than ecological resilience, which 

would benefit native biodiversity, the 

Forest Service must be clear about this 

and the adverse impacts of it. (pg 6)

Silviculture

The term resilience was taken from the 2004 Sierra Nevada Forest Plan Amendment 

ROD, page 6. On page 6 of the 2004 SNFPA ROD, a concern is voiced regarding the 

negative influence of drought and climatic variances throughout the range of the 

Sierra Nevada. The 2004 ROD provides for density management to “improve the 

forest’s resilience to drought, and insect and disease conditions”. 

North, 2009, defines resilience as “improve the capacity of ecosystems to return to 

desired conditions after disturbance.”

Please refer to the Glossary for a definition of resilience. (This definition was 

obtained from the SNFPA FEIS, Vol.1 Glossary)

JMP-25

The DEIS asserts that patches of highintensity fire (generally termed “highseverity fire” by the Forest Service), 

wherein most or all trees are killed within 

a mosaic of low- and moderate-intensity 

fire effects, is damaging and implies that 

such fire is unnatural in the Sierra Nevada 

management region. This is flatly 

inaccurate. The scientific evidence is 

clear that, historically, prior to fire 

suppression and logging, Californian 

mixed-conifer and ponderosa/Jeffrey-pine 

forests experienced a mix of low, 

moderate, and high-intensity fire effects 

(Leiberg 1902, Minnich et al. 2000, Beaty 

and Taylor 2001, Bekker and Taylor 

2001, Nagel and Taylor 2005, Bekker and 

Taylor 2010, Collins and Stephens 2010), 

and high-intensity fire was always a 

natural part of historic fire regimes. 

Fuels

Although high severity fire was historically a part of historic fire regimes in Sierra 

Nevada lower to mid-elevation mixed conifer forests, the proportion and size of high 

severity fire patches were relatively minor (typically less than 15% of total burned 

area and less than 1 acre per patch) components of this historic fire regime (Collins 

and Stephens 2010, Scholl and Taylor 2010). Large (>10 ha) patches of high-severity 

fire were very infrequent and relatively rare in these forest types. Smaller patches 

(usually less than one acre) are more beneficial for the purposes of enhancing forest 

heterogeneity and are more characteristic of fire-frequent forests of western North 

America and the Sierra Nevada (North et al. 2009b, Larson and Churchill 2012). 

Moreover, larger gaps created by large patches of high severity fire may have many 

negative impacts to key resources (forest habitat for late-seral associated species such 

as Pacific fisher) or critical ecosystem services, such as air quality, forest carbon, and 

watershed integrity. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 421 Appendix G 

JMP-26

With regard to high-intensity fire 

proportion (the average percentage of 

high-intensity effects, relative to low- and 

moderate-intensity), Collins and Stephens 

(2010) found that reference mixed-conifer 

and white fir forests in Yosemite National 

Park (forests that had never been logged, 

and had continued to experience frequent 

fire—i.e., had not missed fire return 

intervals) had an average of 15% highintensity fire effects, and most of the 

high-intensity fire area was comprised of 

patches hundreds of acres in size. Collins 

and Stephens (2010) concluded that 

“stand-replacing patches should be 

considered an important component 

shaping these forests”. In mixed-conifer 

and ponderosa/Jeffrey-pine forests of Baja 

California that had never been subjected 

to logging or fire suppression, Minnich et 

al. (2000) found that the average highintensity fire proportion was about 17% 

(52-year overall fire rotation interval and 

300-year high-intensity fire rotation 

interval). Beaty and Taylor (2001 [Table 

8]) found historic high-intensity fire 

proportions of 18-70%, depending on 

slope aspect, in mixed-conifer and fir 

forests of an unmanaged area of the 

Lassen National Forest. Bekker and 

Taylor (2001 [Fig. 2f]), in a different 

unmanaged mixed-conifer and fir forest 

on the Lassen National Forest, found 

Fuels

Three points can be made in regards to this comment.

First, several of the cited studies were conducted in different forest types not typical 

of nearly all of the Greys Mountain Project area. For example, Collins and Stephens 

(2010) conducted their study in upper-montane mixed conifer forests of the 

Illillouette Basin of Yosemite National Park. This basin consists primarily of a 

different forest type (dominated by red fir, white fir, lodgepole pine, and Jeffrey 

pine) than the lower mixed conifer forests of the Greys Mountain Project Area 

(primarily Ponderosa pine, sugar pine, white fir, and incense cedar). These two forest 

types have different associated fire regimes (including fire return intervals and fire 

severity patterns). In another example, Bekker and Taylor (2001, 2010) were 

conducted in the upper elevation montane forests in the southern Cascades. These 

vegetation types (Jeffrey pine, lodgepole pine, red fir/white fir, and mountain 

hemlock forests) have a notably different fire regime (with longer fire return intervals 

and more frequent stand-replacing fires) than forests of the Greys Mountain project 

area (Sugihara et al. 2006, Miller et al. 2009, Thode et al. 2011; Van de Water and 

Safford 2011). 

Second, the size of high-severity fire patches is overestimated by focusing on 

maximum fire size. For instance, In addition, Collins and Stephens found that the 

majority of stand-replacing fire patches were less than 4 ha in size in Yosemite 

National Park (Collins and Stephens 2010). Leiberg (1902) may have located a few 

large areas of high-severity wildfire (>1000 acres). However, most of stand-replacing 

patches observed by Leiberg (1902) were substantially smaller in total area, and the 

patterns he observed were already following decades of post-settlement activities 

including logging, extensive sheep grazing, mining, and, in some cases, fire 

exclusion.

Third, fire severity trends within the Sierra Nevada show a clear increase in the size 

and frequency of high severity fire in low- to mid-elevation mixed conifer forests 

within the region (Miller et al. 2009). Such trends indicate that patches of highseverity fire and an increasing threat to values at risk (e.g., contiguous fisher habitat, 

late-seral forest, air quality, soil hydrologic function and productivity) and should be 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 422 Appendix G 

historic high-intensity fire proportions of 

about 50-65%. Bekker and Taylor (2010) 

found that, in an unmanaged area of the 

Lassen National Forest within mixedconifer forests, the fires burned mostly at 

high-intensity historically, with some 

high-intensity fire patches being 

thousands of acres in size. Bekker and 

Taylor (2010) concluded that “highseverity fire was important in shaping 

stand structure” historically. Leiberg 

(1902) mapped large expanses of highintensity fire prior to fire suppression in 

the Sierra Nevada, with some individual 

patches exceeded 10,000 acres in size in 

areas mapped as unlogged by Leiberg. 

Moreover, these data indicate that, 

historically, the rotation intervals for 

high-intensity fire in mixed-conifer and 

ponderosa/Jeffrey-pine forests were about 

150-350 years in length, if the proportion 

of high-intensity fire effects and the 

overall fire rotation, or the proportion of 

the area affected by high-intensity fire 

over time, are used to calculate highintensity fire rotations (Minnich et al. 

2000, Beaty and Taylor 2001, Bekker and 

Taylor 2001, Bekker and Taylor 2010, 

Collins and Stephens 2010). Even under 

the broadest possible definitions of “highseverity” or “high-intensity” fire, the 

current high-intensity fire rotation 

intervals in the Sierra Nevada are at least 

500-1000 years long (annual average of 

15,000 to 20,000 acres of high-intensity 

minimized to smaller patches more typical of historic fire regimes in representative 

forest types. A more progressive management strategy would be to use a mixture of 

low- and moderate-severity fire coupled with strategic mechanical treatments to 

achieve near-term ecological restoration and fuel treatment objectives (North et al. 

2009, Stephens et al. 2009, Evans et al. 2011, and Collins et al. 2011).
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 423 Appendix G 

fire in the 12 million acres of Sierran 

forests).

JMP-27

Given that the DEIS’s proposal to 

severely reduce stand densities would 

greatly reduce or essentially halt future 

recruitment of large snags (reducing 

future tree mortality to very low levels), 

or substantially reduce future large snag 

recruitment levels relative to no action, as 

discussed in the section immediately 

above, densities of large snags (generally, 

snags over 15 inches dbh, and preferably 

over 20 inches dbh) in future decades will 

necessarily be reduced relative to current 

levels, as attrition of currently-standing 

snags occurs. The DEIS does not mention 

the impacts that this would have on 

cavity-nesting wildlife species, including 

Sensitive Species and Management 

Indicator Species.

Wildlife

Snag biomass and densities often increase or do not change in response to fuel 

treatments that manage for these important wildlife structures (North et al. 2009b). 

Prescribed burning or mechanical thinning followed by burning can increase snag 

densities but reduce coarse woody debris (Stephens and Moghaddas 2005b). Largediameter snag densities may increase or decrease in response to fuel treatments, 

therefore retention of large-diameter snags is an explicit goal of this proposed project. 

All snags will be retained throughout the treatment units unless they constitute a 

direct hazard. The Grey’s Mountain Ecological Restoration Project would retain an 

average of 9 snags per acre ≥10” dbh, and 4 large snags per acre (≥16” dbh) across 

the treatment units, which meets the requirement set forth in the SNFPA ROD. The 

Grey’s Mountain Ecological Restoration Project will also retain an average of 33 

large (≥20” dbh) live conifers per acre to serve as replacement snags in the future as 

some of these large trees receive environmental damage and decadence or succumb to 

disease and/or insect attacks. 

To maintain decadent stand characteristics and provide for fisher resting and denning 

sites throughout the treatment units, conifers >20” dbh with structural decadence 

and/or the potential to become future snags have been identified for retention within 

treatment areas. Standard and Guideline #11 provides direction for retention of these 

structural elements. Within treatment units, conifers with the greatest existing or 

potential for structural decadence were marked as a Wildlife tree for retention at an 

average of 1 every 100 feet. Conifers were selected using the following 

characteristics listed in order of priority: evidence of known or potential cavities; 

broken top; conks or other heart-rot indicators; mistletoe or other abnormalities; 

witches broom formation or other diseased or insect damaged trees; teakettle 

branches; forked top; or broken large branches.

JMP-28

The DEIS does not establish that the basal 

area mortality of conifers that would 

result from the combined thinning (killing 

Silviculture

The DEIS abstract describes that the ecological restoration goals of the Greys 

Mountain Project are multi-faceted and include: (1) increase forest resilience to 

insects, disease, and drought through prescribed fire and mechanical thinning 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 424 Appendix G 

of trees via chainsaws) and fire/insect 

mortality would be less than the basal 

area mortality that would result from fire 

or insect mortality alone; nor does the 

DEIS establish that, after implementation 

of the proposed action, the project area 

would have adequate and ecologicallyhealthy levels of large snags and large 

downed logs for wildlife, as discussed 

below.

treatments, (2) promote heterogeneity in forest structure for improving wildlife 

habitat, as well as others. Density management through thinning would be 

undertaken to accomplish these goals. The body of the DEIS describes the 

environmental effects of these proposed treatments. 

As stated above, goals of the project are to work towards restoring proposed treatment 

areas to a more historical condition found prior to the 20th Century. 

Treatments would result in:

(1) increasing the growth and reducing drought-stress to large-diameter pines and 

oaks by removing shade-tolerant competitors, (2) increasing stand heterogeneity and 

enhancing regeneration of shade-intolerant pines and oaks through the creation of tree 

gaps or increase in size of existing small-sized gaps (Bonnicksen and Stone 1983), (3) 

increasing long-term carbon sequestration by increasing growth rates of largediameter fire-resilient trees (North et al. 2009b), and (4) reducing stand densities to 

promote tree growth and forest stands that are resilient to fire, insect outbreaks, and 

future climate change.

There is ample evidence that fuel and forest restoration treatments will be effective at 

reducing fuel loads, fire severity, and crown fire risk when ground fuels are treated 

with ladder fuels (e.g., Stephens et al. 2009, North et al 2009a, North et al. 2009b).

There is also sufficient scientific support for fuel treatment effectiveness in mitigating 

the negative impacts of wildfire (e.g., Skinner et al. 2004, Safford et al. 2009).

Inventory data for the project area indicates snag and large down log numbers within 

the project area presently meet LRMP standards. Existing snags and down logs are 

not planned to be treated. Commercial thinning is estimated to be conducted on about 

1566 acres out of the 9,600 acres within the proposed project boundary. Within this 

acreage there are between 500 and 700 clumps of larger diameter trees where no tree 

larger than 20 inches dbh would be removed. These clumps would retain basal areas 

substantially above desired for the surrounding stand. These more densely stocked 

clumps along with Stream Management Zones, and other non-treatment areas would 

provide snag and large down log recruitment sites. Existing down logs and snags in 

non-treatment areas would remain. Non-treatment areas would provide a source for 

recruitment of additional down logs and snags. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 425 Appendix G 

JMP-29 The federal courts have ruled that the 

2004 Framework forest plan is illegal 

under NEPA. You are using the wrong 

forest plan. This project must be 

governed by the 2001 Framework FEIS 

and ROD. 

NEPA There is no requirement that the project be governed by the 2001 Framework as the 

commenter suggests. The 2004 Framework decision has not been vacated and there 

is no injunction against continuing to implement projects pursuant to the 2004 

Framework decision. The federal court ruling in Sierra Nevada Forest Protection 

Campaign v Rey, 573 F. Supp. 2d 1316 (E.D. Cal 2008) found that the Forest Service 

failed to consider a reasonable range of alternatives to the 2004 Framework as 

required by NEPA. The remedy phase for this ruling is currently back before the 

District Court to determine proper remedy. The latest ruling on this case occurred in 

May 2011, Sierra Forest Legacy et al v Sherman , 646 F.3d 1161 (9th Cir. 2011), 

where the 9th Circuit remanded the case to District Court for further proceedings 

related to proper remedy for the Framework NEPA violation. Until the District Court 

rules again on remedy, Sierra National Forest activities continue to implement the 

2004 Framework and are not constrained during the remand process. 

JMP-30

Recent research provides evidence that 

seriously questions the very basis for 

thinning and its assumed effectiveness. 

Rhodes and Baker (2008) found that, 

based upon the fire rotation interval for 

high severity fire, and assuming an 

effectiveness period of 20 years for a 

mechanically-thinned area (i.e., before it 

would need to be treated again to 

maintain effectiveness from a fire/fuels 

perspective), the probability of a thinned 

area encountering a high severity fire 

patch during the 20-year effectiveness 

period (assuming for the sake of argument 

that the thinning actually does reduce fire 

severity during this period) is only about 

3.3% in California’s forests. It would be 

less than 2% if an 11-year thinning 

effectiveness period is assumed (Rhodes 

and Baker 2008). This means that, in 

Silviculture

The Rhodes and Baker (2008) paper brings into question the likelihood of a fire 

occurring within any given treated area within the 15 to 20 year time period that the 

study considers treatments to be effective. This is not a study on the effectiveness of 

thinning for density management to maintain and/or improve stand vigor, increase 

growth and thus diameters of residual trees, increase the percentage of 

intolerant/more fire resistant trees and other density management objectives discussed 

in the DEIS.

As stated in the DEIS p208-209, another thinning entry would most likely take place 

15 to 20 years following this entry. That entry would thin out competing trees to

permit continued growth and vigor of the stand and would provide the opportunity to 

undertake fuels maintenance treatments where needed. Future treatments beyond the 

next probable entry are beyond the scope of this document. 

Bouldin (1999) in his conclusions states “the combination of increased density and 

standing mortality (with enormously increased surface/ground fuel loads) presents, 

without any question, the greatest single threat to the integrity of Sierra Nevada forest 

ecosystems (SNEP 1996), USDA Forest Service 1998). These increases have led 

directly to the greatly increased high-severity fire probability over many millions of 

acres.”
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 426 Appendix G 

order to have a 50% chance of having the 

thinned area reduce the severity of a fire 

patch that would have otherwise been 

high severity, the thinned area would have 

to be re-thinned every 20 years for about 

300 years (see Rhodes and Baker 2008). 

Please fully analyze the implications of 

this new data, and please also fully 

divulge whether you intend to re-thin this 

area over and over again every couple of 

decades or so for the next three centuries 

or so in order to have a reasonable 

probability of having the thinning area 

ACTUALLY prevent high severity fire 

from occurring in the thinned area. If so, 

please fully analyze the cumulative 

environmental impacts on wildlife, soils, 

and watersheds from such repeated

mechanical activities on this site. If not, 

please divulge the fact that the probability 

that the thinned area will NOT encounter 

a high severity fire area is about 97% or 

greater, and that your thinning activities 

are extremely unlikely to be effective in 

any tangible or meaningful way for 

fuels/fire management.

JMP-31

The DEIS suggests that a key objective of 

the proposal is to prevent patches of high 

severity fire from occurring ostensibly to 

prevent damage of some type. However, 

the DEIS does not adequately explain the 

Fuels

The purpose and need of the Greys Project is multi-faceted and utilizes an ecosystem 

approach that compares the current condition of key ecosystem components against 

desired conditions.

One of the purpose and need of the project is to create a network of landscape area 

treatments and defensible fuel profile near key transportation corridors to reduce the 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 427 Appendix G 

ecological damage sought to be avoided, 

nor does it explain or divulge the damage 

to wildlife species that would occur from 

preventing high severity fire patches from 

occurring, or divulge the fact that many 

forest species benefit from and depend 

upon such high severity fire patches.

intensity and spread of wildfires across the landscape and near communities. Fire 

suppression capabilities are enhanced by modified fire behavior inside these areas and 

would also provide a safe and effective area for suppression activities to occur.

JMP-33

The DEIS states that a key objective is to 

reduce future mortality of trees ostensibly 

in order to benefit the forest. However, 

the DEIS does not explain the ecological 

damage that large snags supposedly cause 

in the forest, and fails to divulge the 

damage that would be caused to numerous 

forest species if large snag levels are 

reduced further from current levels due to 

stand density reduction, reduction in 

competition between trees, and resulting 

lower levels of large snag recruitment in 

the future. 

Wildlife

Snag biomass and densities often increase or do not change in response to fuel 

treatments that manage for these important wildlife structures (North et al. 2009b). 

Prescribed burning or mechanical thinning followed by burning can increase snag 

densities but reduce coarse woody debris (Stephens and Moghaddas 2005b). Largediameter snag densities may increase or decrease in response to fuel treatments, 

therefore retention of large-diameter snags is an explicit goal of this proposed project. 

All snags will be retained throughout the treatment units proposed in the Grey’s 

Mountain project unless they constitute a direct safety hazard.

JMP-34

Nor does the DEIS divulge the current 

density of snags in each size class (this 

should be presented for each proposed 

mechanical thin unit).

Wildlife

The Grey’s Mountain Ecological Restoration Project will retain an average of 9 snags 

per acre ≥10” dbh, and four large snags per acre (≥16” dbh) across the treatment 

units, which meets the requirement set forth in the SNFPA ROD S&G #11. The 

Grey’s Mountain Project seeks to retain all snags except those that pose a direct 

safety hazard during project implementation. 

Pages 130-133 of the BE/BA for the Grey’s Mountain project displays snag density

JMP-35

The DEIS implies, incorrectly, that highWildlifeThe PLAS 2009 Avian Monitoring Report states that “Species richness was highest in 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 428 Appendix G 

intensity fire is unnatural and wholly 

harmful in mixed conifer forests of the 

Sierra Nevada. The U.S. Forest Service 

recently began a study of avian diversity 

and abundance in unburned areas and in 

three large recent fires, including the 

Moonlight and Storrie fires that some 

have inappropriately described as 

“catastrophic”. This study, conducted by 

PRBO Conservation Science, found that 

nest density increased with increasing 

proportions of high-intensity fire (with the 

highest nest densities occurring in 100% 

mortality areas), and that total bird 

abundance was the highest in the highintensity areas of the Storrie fire of 2000 

(where shrubs had fully matured, and 

some snag attrition had occurred, creating 

important downed log structure)—higher 

than the unburned mature forest in the 

same area (USDA 2010).

green forest of the PLAS and high severity areas of the Storrie fire, Shannon diversity 

was highest PLAS green forest, and total bird abundance was highest in the high 

severity areas of the Storrie fire”. This data indicates that both green forest and 

patches of high severity fire are important habitat components for avian species in the 

Sierra Nevada. 

The report goes on to state: “The difference in avian species diversity and total bird 

abundance between green forest and post-fire habitat in our study area was not clear 

cut. Per point species diversity and total bird abundance was generally greater in 

unburned forest than post-fire habitat. However, more total species were detected in 

the Moonlight fire which covers a much smaller geographic area and had far fewer 

sampling locations than the PLAS green forest. Green forest in our study area likely 

have greater structural diversity and total foliage volume at the point level which can 

support a greater diversity of species (McCarthur et al. 1966, Verner and Larson 

1989), while post-fire habitats in our study area appear more heterogeneous on a 

landscape scale. Therefore, whether green forest or post-fire habitat supports greater 

avian diversity depends on the resolution at which the question is considered.” USDA 

2010.

Within Sierra Nevada mid-elevation forests, biodiversity of plants, fungi, and wildlife 

is not greatest in high-severity burned patches, but is maximized in diverse landscapes 

that incorporate a matrix of burn severities, forest seral stages (including managed 

forests), and most importantly, habitat diversity (Graber 1996, Wayman and North 

2007, Meyer et al. 2008, Kennedy and Fontaine 2009, Vierling and Lentile 2009).

During the past decade from 2000 through 2010, the Sierra National Forest has 

experienced a total of 53 wildfires totaling 28,419 acres, with an average fire size of 

536 acres. 65% of the total acres burned during this period were categorized as 

moderate and high severity burned areas. The implementation of projects designed to 

reduce fuel loading and fire severity does not preclude the occurrence of wildfire 

across the landscape, it merely seeks to lessen the extent and severity of such fires 

when they occur. 

Since treatments for the Grey’s Mountain Ecological Restoration project are limited 

to a maximum of 3,556 acres out of the 9,600 acres within the project boundary (37% 

of the total area), there remains potential for low and moderate severity fire to occur 

throughout the entire project area, and the potential for high severity fire to occur 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 429 Appendix G 

within the untreated portion of the Grey’s Mountain project boundary (63% of the 

total area). It is reasonable to conclude that wildfires of all severity types will 

continue to occur across the Bass Lake Ranger District and the Sierra National Forest, 

even after the implementation of the Grey’s Mountain Ecological Restoration project. 

Therefore, early seral stage habitat for land birds will likely continue to increase on 

the Bass Lake district and across the Sierra NF. 

Current science indicates that the total area of high severity burned forest in the Sierra 

Nevada is not lower than historic reference conditions (Safford 2010) and the size of 

high severity burned patches has significantly increased (Miller et al. 2008). The 

entire western United States has experienced higher large-wildfire frequency, longer

wildfire durations, and longer wildfire seasons since the mid-1980’s (Westerling et al. 

2006).

JMP-36

Other recent data reveals that highintensity fire patches can result in highly 

beneficial ecological effects to riparian 

zones and watersheds by causing an 

increase in invertebrate prey and 

dissemination of such riparian 

invertebrates to the terrestrial landscape 

(Malison and Baxter 2010). 

Aquatics

Malison and Baxter (2010) describe an increase in benthic macroinvertebrate biomass 

as a mid-term effect (five years after the fire). They noted an increase in Baetidae and 

Chironomidae, which have short life histories allowing them to adapt quickly to 

changing physical conditions, such as those that might result from a high severity fire. 

A portion of the response may be a reflection of a change in species composition to 

species with higher productivity. These results are similar to other reported effects to 

benthic communities: that some indicators of community health may return to pre-fire 

conditions within 1-2 years, but the overall community will probably vary for 5-10 

years after the fire (Minshall 2003; Reardon et al 2005). 

Opening up of dense stream canopies have been noted to increase aquatic 

productivity (Beschta et al 1987). However, opening up dense canopies can be 

accompanied by increases in sediment due to decreased site buffering and alteration 

of hydrologic regime. Impact of fire on the macro invertebrate community varies by 

burn intensity and extent; steam size and gradient; precipitation and amount of runoff; 

vegetative cover; geology; and topography. 

It is expected that water temperatures within the project area will increase due to 

climate change. Thompson (2005) summarizes that direct solar radiation has the 

greatest influence on water temperature, thus managing to maintain or improve shade 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 430 Appendix G 

is important to reduce heat flux. 

JMP-37

The project documents fail to 

acknowledge that patches of high severity 

fire are natural in these ecosystems, and 

that many plant and animal species 

depend upon such habitat (Hanson 2007, 

Hutto 1995, Hutto 2006, Noss et al. 

2006). In fact, peak levels of native 

diversity in higher plants and wildlife 

species is found in patches of conifer 

forest burned at high severity which have 

not been managed (logged) (Noss et al. 

2006). Please explain your suggestion 

that wildland fire is an ecological threat in 

light of this information. 

Wildlife

The statement by Noss et al. (2006) that species diversity is often highest following a 

natural stand-replacement event (e.g., fire), is based on a broadly generalized 

statement by Lindenmeyer and Franklin (2002) that encompasses forest ecosystems 

of the world, not specifically any forest type in the Sierra Nevada or even the western 

United States. Within Sierra Nevada mid-elevation forests, biodiversity of plants, 

fungi, and wildlife is not greatest in high-severity burned patches, but is maximized in 

diverse landscapes that incorporate a matrix of burn severities, forest seral stages 

(including managed forests), and most importantly, habitat diversity (Graber 1996, 

Wayman and North 2007, Meyer et al. 2008, Kennedy and Fontaine 2009, Vierling 

and Lentile 2009). This includes prey species for forest service sensitive species, 

such as Pacific fisher and California spotted owl (Waters and Zabel 2008, Roberts et 

al. 2009) and species dependent on high severity burned patches (Kennedy and 

Fontaine 2009, Kotliar et al. 2009). Wildland fire itself is not an ecological threat 

unless it occurs across many acres with high fuel loading rendering remaining habitat 

unsuitable or less suitable for some forest species including pacific fisher.

JMP-38

The DEIS suggests that stands were much 

less dense historically in the Project area. 

Please explain your scientific basis for 

assuming that basal area density was 

higher historically in the Project area than 

it is now, in light of Bouldin (1999). 

Silviculture

The DEIS p203 states: “fairly recent studies have indicated that the exclusion of fire 

may have also resulted in normal basal area densities in excess of what would have 

been found during previous centuries”. The following reference have been added: 

(Kilgore, 1979)(Parsons, 1979) (Oliver, 1996) (Bouldin, 1999) (Fitzgerald, 

2005)(Taylor, 2006)(North, 2009) The DEIS p202 further states: “The wetter than 

normal 20th Century coupled with the exclusion of fire has set the stage for stands to 

become overcrowded with competing conifers, oaks and other vegetation.” 

The DEIS does not state basal area density in the project area was higher than it is 

now.

JMP-39

Please include a cost estimate for a 30”-

limit mechanical thin, including, at a 

Timber & 

Silviculture As stated in the DEIS in a number of places, this project proposes to thin from below. 

Thinning from below removes the poorest crowned trees while retaining the trees 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 431 Appendix G 

minimum, the following with respect to 

the Forest Service’s net expenses (i.e., not 

the timber contractor): a) administrative 

costs to the USFS pertaining to analysis 

and appeals; b) costs to the USFS of sale 

preparation and administration; c) PER 

ACRE costs to the USFS of slash piling 

and burning; d) PER ACRE costs to the 

USFS of brush maintenance following the 

mechanical thinning as a result of canopy 

reduction (this cost must be included, 

regardless of whether brush maintenance 

is required only 3-5 years after 

mechanical thinning or 10-15 years after 

mechanical thinning; and no similar cost 

would be applied to non-commercial 

thinning since essentially no measurable 

canopy reduction would occur); e) the 

administrative costs to the USFS 

pertaining to analysis and planning for the 

slash clean-up and brush maintenance 

projects following the mechanical 

thinning; f) the projected timber sales 

receipts to the USFS from the timber sale; 

and g) the total timber volume of the 

timber sale (in board feet of sawtimber, as 

well as tons of biomass). Please include 

citations to actual projects for all 

estimates.

with the best crowns (DEIS p214) and retains the majority of the crown cover. The 

intent of this project is to retain 60 percent canopy cover in CWHR 4 and CWHR 5 

(DEIS p214) where present. Retention of this level of canopy cover will minimize 

the likelihood of brush becoming a problem in the understory. Maintenance of 

invading brush is not expected to be needed as a result of this treatment. Field 

reviews of areas thinned in previous projects to this crown cover retention level have 

not indicated a need to treat invading brush. 

Costs need to be determined

a) Administrative costs are explained on page 261 of DEIS – “Cost of producing 

environmental document is approx. $95,000.

b) Costs of USFS sale preparation is $11.80 per ccf and $10.80 per ccf for 

administrative costs (pg. 261)

c) Per acre costs for slash piling = $280/acre for tractor piling, $75/acre for 

burning those piles (Table 55, Forest Service Agency Responsibility)

d) Per acre costs of brush maintenance = $545/acre (Table 55, Forest Service 

Agency Responsibility under “Mastication”

e) Administrative costs to USFS for analysis and planning for slash and brush 

maintenance are not expected, please see explanation above.

f) Projected timber sale receipt = $548,213 after costs of operations are 

removed from total timber value (Table 55, “Net Value”)

g) Total timber volume in sale = approximately 15,184 ccf (Table 55), 

approximately 2211 tons of biomass (Table 55), volume in board feet = 8,153 

mmbf
Sierra National Forest – 432 Appendix G 

Benton Cavin 1/30/12 (letter)

Comment

Number

Comment Comment 

Topic

General Response

BC-1

Prescribed burns do get away. Please see 

to it that there is a suitable buffer against 

my property line. Suggestion: 300 feet

Document 

Concerns & 

Fuels The commenter has a concern over prescribed burns escaping and burning onto 

private property. 

The Forest Service policy relating to this issue is:

FSH-5140.3 Fire Use Policy

The following fire use policies apply on all National Forest System lands:

2. The Interagency Prescribed Fire Planning and Implementation Procedures 

Reference Guide is Forest Service policy (incorporated by reference).

a) A prescribed fire burn plan will be completed prior to ignition and as part of 

this burn plan a thorough complexity analysis will be completed to ensure 

risks have been evaluated and mitigations developed to prevent an escape. 

The Project is in compliance with policy as the boundaries for the proposed 

prescribed burning are located on Forest Service land. During the planning of the burn 

units a buffer would be established along the property line that is of a suitable 

distance to reduce the risk of escape onto private property and is safe for personnel 

implementing the burn.

It is true that prescribe fire could get away. Forest personnel are required to follow a 

suite of prescriptive measures to make sure prescribed fires do not put homes at risk. 

(page 11). In preparing a prescribed burn plan a thorough process is followed for risk 

management and what mitigations and contingency planning will be required to 

implement the burn. The burning is proposed to occur during the late fall and spring 

months’ when environmental and fuels conditions would keep fire behavior at 

acceptable levels to meet fuels objectives. The type of fire that is used during these 

burns is typically a backing fire which produces lower intensities and allows for 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 433 Appendix G 

higher levels of fuel consumption. 

BC-2

Map 16 shows reconstruction of my access 

easement from Road 6S38. I request no 

reconstruction.

Document 

Concerns The commenter requests proposed road reconstruction on Forest Service Lands not be 

done because it would allow easier access for public to trespass onto private property. 

This road will be removed from proposed reconstruction. This will not cause any 

issues for completing any of proposed restoration treatments’. Map 16 has been edited 

for this change. 

BC-3

Map 16 shows reconstruction of Road 

6S10A to the old MID siphon facilities in 

Section 10. I request no reconstruction.

Document 

Concerns The commenter requests proposed road reconstruction on Forest Service Lands not be 

done because it would allow easier access for public to trespass onto private property. 

If an action alternative is selected, Road 10S10A would need to be reconstructed 

because this is the road that provides the only access into proposed treatment area T29’. Upon completion of the restoration work this road would be closed to public 

access.

BC-4

Figures 18 & 20 show the Project 

encroaching on to my property. Please 

correct these maps and any other maps 

with this defect.

Document 

Concerns Requests maps have been corrected to show Project boundary in the correct location 

instead of crossing over private property.

The maps associated with the figures have been edited and the requested changes 

made. Upon review no other maps were found to have this error. 

BC-5

Blister Rust is decimating the young 

Sugarpine population. I ask that you 

modify your presentation to give this 

significant prominence and work towards a 

permanent solution. I suggest a new trial 

area of say 40 acres where the gooseberries 

are eliminated.

Silviculture

A new trial area of 40 acres where the gooseberries are eliminated to reduce blister 

rust is outside the scope of this project and is not needed to achieve the purposes and 

needs established for this project. The Sierra’s mission is to manage the Forest using 

the best available science and typically the Forest itself does not initiate research 

projects. The Pacific Southwest Research Station is research arm of the Forest 

Service in this area and it may prove fruitful to make your proposal to that agency. 
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 434 Appendix G 

US EPA Kathleen Goforth 1/30/12

Comment

Number

Comment Comment 

Topic

General Response

EPA-1

We rated the Draft EIS as Lack of 

Objections.

NEPA 

The SNF appreciates the United States Environmental Protection Agency for taking 

the time to review the Greys Mountain Project DEIS.

Benton Cavin 1/30/12 (e-mail)

Comment

Number

Comment Comment 

Topic

General Response

BCEM-1

I suggest modifying the transmittal in the 

future so that those of us who are not fully 

hep get the correct message.

(Responding to information provided that 

the beginning of the public comment 

period is the day after publication in the 

federal register.)

NEPA 

The Forest Service strives to provide clear communication to the public. Future 

messages will be reviewed for clarity.
Final Environmental Impact Statement Greys Mountain Ecological Restoration Project

Sierra National Forest – 435 Appendix G 

OEPC-1 Chapter 3, Pg. 116: The Draft EIS 

addresses the relationship between 

California spotted owl habitat and fire, 

but does not address the information 

presented by Roberts et al, 2011. Roberts 

et al, 2011, surveyed for California 

spotted owls throughout late-successional 

montane forest in Yosemite National 

Park, California and found that spotted 

owl detection and occupancy rates were 

similar between burned and unburned 

sites. Nest and roost site occupancy was 

best explained by a model that combined 

total tree basal area (a positive effect) 

with cover by coarse woody debris (a 

negative effect). The density estimates of 

California spotted owl pairs were similar 

in burned and unburned forests. 

Their results indicated that low to 

moderate severity fires, historically 

common within montane forests of the 

Sierra Nevada, California, maintain 

habitat characteristics essential for spotted 

owl site occupancy. These results suggest 

that managed fires that emulate the 

historic fire regime of these forests may 

maintain spotted owl habitat and protect 

this species from the effects of future 

catastrophic fires.

Wildlife

The BEBA (page 42) has been updated to include this literature reference.