CHAPTER 3

Affected Environment and 

Environmental Consequences
Changes Between Draft and Final Environment Impact Statement

Updated the visitor use information.

Added environmental analysis of Alternative 4

Added environmental analysis of forest plan amendment concerning camps 

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

Expanded analysis in each section to address DEIS comments and concerns.

Incorporated information from 2012 Needs Assessment.

Added an Economic and Social Analysis.

Made numerous, minor editorial and spelling corrections.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-1 February 2013

Okanogan-Wenatchee National Forest

Chapter

3

Affected Environment and Environmental 

Consequences

Introduction

This chapter summarizes the affected physical, biological, social, and economic environments of 

the project area and the effects of implementing each alternative. The scientific and analytic 

basis is presented for the comparison of alternatives listed in Chapter 2. The effects disclosed 

are based on the effectiveness of the design criteria and mitigation measures outlined in 

Chapter 2. The analysis of resources uses varying measures due to management direction, 

research, or field practice. Therefore, the effect of similar resources cannot always be directly 

compared, although analysis for each alternative can be compared for the same resource.

The effects resulting from each action are described in terms of their context, intensity, speed, 

direction, magnitude and duration. Other activities occurring in the same area over time, under 

certain circumstances, may have incremental effects that produce cumulative effects. It is 

sometimes necessary to look beyond the defined project area to determine the cumulative 

effects on certain resources. The effects disclose the direct and indirect effects plus the past, 

present, and reasonably foreseeable actions that define cumulative effect in this chapter.

Many of the effects discussed in this chapter are not easily quantified. It should be kept in mind 

that many of the values presented are modeled or estimated predictions of effects, and that the 

actual effects may not occur exactly to the degree presented. In some cases, the value of the 

analysis is in the comparison of the estimated effects between alternatives, rather than in the 

absolute values of the effects shown.

Each environmental component is discussed in terms of the consequences of implementing 

each of the alternatives listed in Chapter 2. This allows the reader interested in specific 

resources to find the effects related to that resource in one place. The following format is used 

for each environmental component:

Regulatory Framework provides management direction from the Forest Plan, policy from 

the Forest Service Handbooks and Manuals, and laws, rules, and regulations for each 

resource.

Analysis Method details how the analysis of each resource was conducted. 

Affected Environment describes the environment of the area to be affected by the 

alternatives, that is, the baseline environment, thus including past actions. It provides 

background for understanding the discussion that follows.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-2 February 2013

Okanogan-Wenatchee National Forest

Environmental Consequences of implementing each alternative are discussed. There are 

three types of effects considered:

1. Direct Effects are caused by the action and occur at the same time and place [40 CFR 

1508.8(a)].

2. Indirect Effects are caused by the action but occur later in time or further removed in 

distance, but are still reasonably foreseeable [40 CFR 1508.8(b)].

3. Cumulative Effects result from the incremental impacts of the action when added to 

other past, present, and reasonable foreseeable actions [40 CFR 1508.7].

Consistency Finding is a statement for each resource area that demonstrates how the action 

alternatives are consistent with the amended Forest Plan.

The Chapter begins with a discussion of past, present, and reasonably foreseeable actions that 

may affect the project area. Environmental components are detailed as above.

This EIS hereby incorporates by reference the wilderness, recreation, botany/sensitive plants, 

wildlife, hydrology, aquatics, soil, range, noxious weed, heritage resources, and air quality 

specialist reports in the Analysis file [40 CFR 1502.21] all of which are summarized in this 

chapter. Other specialist reports are wholly contained in the respective sections of this chapter. 

The referenced reports are located in the corresponding resource section of the Analysis file. All 

specialist reports contain the detailed data, methodologies, analyses, conclusions, maps, 

references and technical documentation (best available science) that the resource specialists 

relied on to reach conclusions.

Past, Present, and Reasonably Foreseeable Future 

Actions

The project interdisciplinary team (IDT) identified past, present, and reasonably foreseeable future 

actions, that might have cumulative impacts with the proposed action. Those actions in and 

adjacent to the project area are listed below. Each resource specialist considered different mixes 

of these actions, depending on the cumulative effects boundary for the resource area and the 

resource affected. Only those past, present and reasonably foreseeable future actions that 

overlap the geographic analysis area boundary for each particular resource are considered, and 

only if those other actions have or are expected to have overlapping effects (spatially and 

temporally) with the pack and saddle stock outfitter-guide project. Some past projects may still be 

having effects on one resource, but not another.

Past Actions

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. 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-3 February 2013

Okanogan-Wenatchee National Forest

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 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.” 

The cumulative effects analysis in this FEIS is also consistent with Forest Service National 

Environmental Policy Act (NEPA) Regulations (36 CFR 220.4(f)) (July 24, 2008), which state, 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 reasonable

foreseeable future actions) on the affected environment. With respect to past actions, 

during the scoping process and 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)

For these reasons, the analysis of past actions in this section is based on current 

environmental conditions although the effects of past actions will be aggregated with 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-4 February 2013

Okanogan-Wenatchee National Forest

present and reasonably foreseeable future actions in determining whether the effects 

from the outfitter-guide activities included in this document are significant

Present Actions

Livestock Grazing

Grazing will continue on all active allotments. No commercial livestock grazing is occurring in 

the Pasayten or Lake Chelan-Sawtooth Wilderness, or in the Sawtooth Backcountry. Refer to 

the Range section for detailed information about the active allotments.

Trail Construction and Maintenance

Declining budgets have reduced the number of miles maintained in the Pasayten to 

approximately 400, with an additional 100 maintained in the Lake Chelan-Sawtooth. 

Trails in the North Cascades Scenic Highway, Sawtooth Backcountry, Upper Methow, Middle 

Methow, and Alta Lake sub-sections will continue to be maintained. Approximately 150 miles 

are maintained annually in these areas.

Developed Recreation Sites

The existing campgrounds and trailheads are maintained and cleaned throughout the snow-free 

seasons. Maintenance activities include repair and maintenance of picnic tables, fire grates, 

bulletin boards, buildings, water systems, roads, and other improvements.

Special Use Permits

There are currently 31 special use permittees operating in the analysis area, or in adjacent 

areas. There are several types of special use permits. Those held by existing permittees include:

Temporary Use – This type of permit lasts less than one year, and is for non-recurring use. 

None of the actual holders from 2011 and 2012 are included in this list because they change 

from year-to-year, although the effects of such use are considered as part of cumulative 

effects. There are no temporary use permits in wilderness or along the North Cascades 

Highway. Use in other areas is limited to avoid resource damage.

Transitional Priority Use – This type of permit is for long-term, temporary permit holders 

whose permits are being analyzed for conversion to Priority Use permits.

Priority Use– This type of permit lasts 1 to 10 years.

Ski-Area – This type permit is a 20-year, term permit for operating a ski area.

The following figure lists all the outfitters, type of activity, operating area, season of operation, 

and type of permit. The outfitter guide activities analyzed for this decision are included in the 

list below because they have been operating under one year permits, which expire each year. 

Therefore their activities are considered either present actions (if the permits for this past year 

have not yet expired), or past actions (if the permits from this past season have expired).
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-5 February 2013

Okanogan-Wenatchee National Forest

Figure 3.0-1. Existing Outfitters-Guides

Outfitter Type of Activity Area of Operation Season of 

Operation

Type of 

Permit

Back-country Burros Pack and Saddle 

Stock (burros)

Pasayten Wilderness, North 

Cascades Scenic Highway

Summer 

and fall

Priority

(1 year)

Cascade Wilderness 

Outfitters

Pack and Saddle 

Stock (horses 

and mules)

Pasayten and Lake ChelanSawtooth Wilderness, 

Sawtooth Backcountry, North 

Cascades Scenic Highway

Summer 

and fall

Priority

(1 year)

Deli-Llama Wilderness AdventurePack and Saddle 

Stock (llamas)

Pasayten Wilderness, North 

Cascades Scenic Highway

Summer 

and fall

Priority

(1 year)

Early Winters 

Outfitting

Pack and Saddle 

Stock (horses 

and mules)

Pasayten and Lake ChelanSawtooth Wilderness, 

Sawtooth Backcountry, North 

Cascades Scenic Highway

Summer 

and fall

Priority

(1 year)

North Cascade 

Outfitters

Pack and Saddle 

Stock (horses 

and mules)

Pasayten and Lake ChelanSawtooth Wilderness, 

Sawtooth Backcountry, North 

Cascades Scenic Highway

Summer 

and fall

Priority

(1 year)

North Cascade Safari Pack and Saddle 

Stock (horses 

and mules)

Pasayten and Lake ChelanSawtooth Wilderness, 

Sawtooth Backcountry, North 

Cascades Scenic Highway

Summer 

and fall

Priority

(1 year)

Sawtooth Outfitters Pack and Saddle 

Stock (horses 

and mules)

Pasayten and Lake ChelanSawtooth Wilderness, 

Sawtooth Backcountry, Alta 

Lake

Summer 

and fall

Priority

(1 year)

Cascade Corrals Pack and Saddle 

Stock (horses 

and mules)

Lake Chelan/Sawtooth 

Wilderness, Sawtooth 

Backcountry

Summer 

and fall

Priority

(1 year)

National Outdoor 

Leader-ship School

Backpacking/

Wilderness Skills

Pasayten and Lake ChelanSawtooth WildernessSummer 

and Fall

Priority

(1 year)

Outward Bound Inc. Backpacking/

Wilderness Skills

Pasayten, Lake ChelanSawtooth, and Alpine Lakes 

Wilderness

Summer 

and Fall

Priority

(10-year)

Wilderness Ventures Backpacking/

Wilderness Skills

Pasayten Wilderness Summer 

and Fall

Priority

(1 year)

North Cascades 

Institute

Backpacking/

Wilderness Skills

North Cascades Scenic 

Highway, Pasayten Wilderness

Summer 

and Fall

Transitional 

Priority 

American Alpine 

Institute

Climbing and 

Mountaineering

North Cascades Scenic Highway summer Priority 

(1 year)

YD Adventure Climbing and 

Mountaineering

North Cascades Scenic Highway Summer 

and fall

Priority 

(1 year)

Alpine Ascents InternationalClimbing and 

Mountaineering

North Cascades Scenic Highway summer Priority 

(1 year)

North Cascades 

Mountain Guides

Climbing and 

Mountaineering

North Cascades Scenic Highway Year 

round

Priority

(10 year)

Mountain Madness Backpacking/

Wilderness Skills

North Cascades Scenic Highway Summer 

and Fall

Priority 

(10-year)
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-6 February 2013

Okanogan-Wenatchee National Forest

Outfitter Type of Activity Area of Operation Season of 

Operation

Type of 

Permit

Rendezvous Huts, Inc. Hut Rental Cub Creek, Rendezvous Creek 

Watersheds

Winter, 

with 

occasional 

summer 

use

Priority 

(10-year)

Sun Mountain Resorts Mountain Biking Sun Mountain Vicinity Spring, 

Summer, 

and Fall

Transitional 

Priority

Mountain Transporter Transportation Methow Valley Ranger District, 

on open roads

YearroundTransitional 

Priority

Methow Biodiversity Backpacking/

Wilderness Skills

Bear/Ramsey/Volstead Summer 

and Fall

Transitional 

Priority

High-lands Stage Wagon Tours Tonasket RD summer Priority

(10 year)

North Cascade HeliSkiingHelicopterAssisted SkiingNorth Cascades Scenic 

Highway, Twisp River, 

Blackpine Basin, Sandy Butte, 

Chewuch River

Winter Priority

(10-year)

Chewack River Guest 

Ranch

Snowmobile 

Rental and 

Guiding

Methow Valley Ranger District, 

excluding Wilderness

Winter Priority

(10-year)

MillerBlue Horseback Day 

Rides

Sun Mountain Area Spring, 

summer, 

fall

Transitional 

Priority

Loup Loup SEF Downhill Skiing Loup Loup Ski Bowl Winter Ski Area

(20-Year)

Methow Valley Sports 

Trails Assoc.

Cross Country 

Skiing, 

Snowshoeing, 

Summer Trail 

Use

North Cascades Scenic 

Highway, Upper Methow, 

Twisp River, and Chewuch 

Watersheds

Year 

round

Ski Area (20-

Year)

Recreation Activities

Numerous recreation activities continue to be popular in the analysis area. On-going activities 

include hiking, non-outfitted (personal) pack and saddle stock use, fishing, camping in developed 

and undeveloped campsites, hunting, riding OHVs, riding mountain bikes, mushroom picking, 

driving for pleasure, and other activities.

There are approximately 163,840 visitor days in the analysis area each year, not including pack 

and saddle stock outfitter-guide visitor days. This figure was determined using the results of the 

2000 and 2005 National Visitor Use Monitoring survey (USDA 2001d, USDA 2012b) and trailhead 

registrations. 

Monitoring was completed in 2005 and 2010 to gather information about the number of people 

recreating on the National Forest. Refer to the Revised National Visitor Use Monitoring (NVUM) 

Results for the Okanogan National Forest, Data Collected FY2005, Revised May 2012 (USDA, 

2012b), and Data Collected FY2010, August 2011 (USDA, 2011). 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-7 February 2013

Okanogan-Wenatchee National Forest

The findings for the 2005 monitoring were updated by the authors of the NVUM 2006 report, 

and issued between the Draft EIS for the Pack and Saddle Stock Outfitter-Guide Special Use 

Permit Reissuance, and the Final EIS. The updated results were substantially lower than the 

original used in the DEIS. 

Because of this discrepancy, the Forest Service compiled data from the registration permits for 

the Pasayten Wilderness in an attempt to resolve the inconsistent results from NVUM. 

Wilderness visitors are required to fill out a registration permit prior to entering the Pasayten. 

Data from these permits was compiled and averaged for 2001 through 2011. Refer to the 

analysis file for full permit data.

The 2005 NVUM reported 11,000 visits to the Pasayten, with an average length of stay of 40.7 

hours. Multiplying these numbers gave the total number of hours spent in the Pasayten. 

Dividing this product by 24 hours converted 11,000 visits to 18,654 visitor days. 

The 2010 NVUM reported 5,000 visits to the Pasayten with an average stay of 12 hours. This 

calculated to 2,500 visitor days.

The averaged permit data showed 16,840 visitor days, which was relatively close to the 18,654 

visitor days from the 2005 NVUM. This validated the 2005 results for the Pasayten and Lake 

Chelan-Sawtooth, and suggests the 2010 data is not reliable enough to use. There is no required 

permit system for the remainder of the analysis area, so NVUM data must be used to estimate 

visitor days. Since the 2005 NVUM data for the Pasayten appears to be close to the averaged 

permit data, the 2005 data for the Lake Chelan-Sawtooth and the Pasayten is assumed to be the 

most reliable information available. 

Visitor days used for the rest of the analysis area were obtained from the National Visitor Use 

Monitoring Results for Okanogan National Forest, (USDA Forest Service 2001d). This data were 

disaggregated to give an estimate of particular portions of the analysis area. The visitor day 

estimates for the Sawtooth Backcountry are based on trailhead registration and visitor counts 

(information included in the analysis file). This area was not adequately sampled in the National 

Visitor Use Monitoring Program in 2000, so the use estimates were substantially lower than field 

observations. Refer to the registration and observation in the analysis file.

The following table lists the number of visitor days by area (not including pack and saddle stock 

outfitter-guide visitor days).

Figure 3.0-2. Number of Non-Outfitted Visitor Days by Area

Area Number of Non-outfitted Visitor Days

Pasayten Wilderness 16,900

Lake Chelan-Sawtooth Wilderness 35,885

North Cascades 71,727

Sawtooth Backcountry 13,606

Bear/Ramsey/Volstead 952

Middle Methow 15,000

Alta Lake 9,770

TOTAL 163,840
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-8 February 2013

Okanogan-Wenatchee National Forest

Highway Maintenance

The Washington State Department of Transportation will continue to maintain the North 

Cascades Scenic Highway, including, but not limited to, hazard tree removal, brushing, plowing, 

avalanche control, pavement maintenance and repair, ditch and culvert maintenance.

Invasive Plants

Invasive plants treatment and surveys will continue to be conducted in the Lake Chelan side of 

the Lake Chelan-Sawtooth area as part of the Flick Creek Fire BAER treatment plan (USDA Forest 

Service 2006b). 

Invasive plants treatment and surveys will continue to be conducted in Bear/Ramsey/Volstead 

sub-section as part of the Tripod BAER treatment plan (USDA Forest Service 2006e). 

All the known new invader1noxious weed sites in and adjacent to the project area will be 

prioritized for integrated weed management for project year 2011 and subsequent years under 

existing or future Integrated Weed Management decisions. Integrated weed management will 

continue for New Invader weed infestations on recreation access roads, trail heads, trails, 

corrals, camps and off roads in areas where weeds may spread and impact recreation facilities 

and activities. Integrated weed management (IWM) will be accomplished through 

implementing the mitigation measures in this assessment and a combination of all the control 

methods available under existing or future Integrated Weed Management decisions, with 

emphasis on early detection of new infestations, rapid treatment response, and prompt 

revegetation. The combination of herbicide, manual, and cultural treatment under the existing 

and future decisions will provide effective control of small populations. Treatments will be 

conducted by the District Weed program with herbicide treatments authorized under the1997 

and 2001 Okanogan National Forest Integrated Weed Management Decision Notices (USDA 

Forest Service1997e and 2000d), Wenatchee Forest-wide Noxious Weed Environmental 

Assessment Decision Notice (USDA Forest Service 1998) and the 2003 Crupina Integrated Weed 

Management Project EIS Record of Decision (USDA Forest Service 2003b). The 2003 Crupina 

decision allows for treatment of one specific invasive species (crupina) on the Chelan side of the 

Lake Chelan-Sawtooth Wilderness using integrated weed management, including the use of 

herbicides.

Other Present Actions

There are no other present actions in or near the analysis area that would have potentially 

cumulative environmental effects with the proposed action or alternatives.

Reasonably Foreseeable Future Actions

Livestock Grazing

The allotment that includes Bear/Ramsey will likely continue to be grazed in the future. No 

other livestock grazing is anticipated in other parts of the analysis area.

 

1. 1 New Invaders are invasive plant species that occur sporadically on the Forest and that may be controlled by 

preventing seed production and early treatment. State listed Class A or State listed Class B and C that are locally 

limited in distribution on National Forest within the project area.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-9 February 2013

Okanogan-Wenatchee National Forest

Trail Maintenance

The current amount of trail maintenance will continue into the reasonably foreseeable future. 

Developed Recreation Sites

The existing campgrounds and trailheads will be maintained into the future. 

Special Use Permits

It is reasonably foreseeable that all existing outfitter-guide permits listed above will continue 

based on past experience and performance. Additional temporary use permits may also be 

issued, but the collective number of service days is not expected to increase across the analysis 

area.

Recreation Activities

On-going activities are expected to continue into the future, including campground 

management, trail maintenance, snowmobiling, hunting, camping in dispersed camping spots, 

camping in developed campgrounds, riding OHVs, riding mountain bikes, hiking, mushroom 

picking, and driving for pleasure.

The number of visitor days expected in the future was calculated using projected changes 

included in the Washington State Comprehensive Outdoor Recreation Planning (SCORP) 

publication “Estimates of Future Participation in Outdoor Recreation in Washington State” 

(Interagency Committee for Outdoor Recreation 2003). These projected changes were for 10 

and 20-year periods based on participation data from the 1999-2000 RCO survey (IAC 2003). 

These projections took into account NSRE data and projections for the Pacific Northwest Region, 

demographic trends in Washington State, the local supply of lands available for recreation 

activities, and other factors. The exception to this is in the North Cascades Scenic Highway 

corridor, where overall use increased 147% in twelve years - from 17,000 visits in 1992, to 

42,000 in 2004. This rate of increase is expected to continue and result in a 100% increase in the 

number of people recreating in the corridor in the next 10 years.

The following figure lists current non-outfitted recreationists in each section of the analysis area, 

and the foreseeable number in 2023.

Figure 3.0-3. Current Number of Non-Outfitted Visitor Days and Estimated Number in 2023

Area Non-Outfitted Visitor Days Estimated Non-Outfitted 

Visitor Days in 2023

Pasayten Wilderness 16,900 18,770

Lake Chelan-Sawtooth Wilderness 35,885 39,362

North Cascades Scenic Highway Corridor 71,727 116,707

Sawtooth Backcountry 13,606 14,994

Bear/Ramsey/Volstead 952 908

Middle Methow 15,000 16,439

Alta Lake 9,770 10,699

TOTAL 163,840 217,933

Highway Maintenance

Maintenance of the North Cascades Scenic Highway will continue into the future.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-10 February 2013

Okanogan-Wenatchee National Forest

Invasive Plants

A Forest-Wide Integrated Weed Management EIS is scheduled for completion in 2012, and 

covers a majority of the project area that is not currently covered by a decision document for 

herbicide treatments. The actions analyzed by the new EIS include the use of more effective, 

less impactful herbicides which would help control the spread and establishment of invasive 

plants in the project area. The application of herbicides will follow Pacific Northwest Region 6 

management direction as described in section 3.4 Invasive Plants.

Other Activities

There are no other reasonably foreseeable future actions that could have cumulative 

environmental effects with the proposed action or alternatives.

3.1 OUTFITTER-GUIDES

The section below is a summary of the Outfitter-Guide Report which is available in the project 

analysis file (Zbyszewski, 2012d).

REGULATORY FRAMEWORK

Pack and saddle stock outfitter-guide activities are controlled by standards and guidelines in the 

Okanogan and Wenatchee Forest Plans, as amended, and the terms and conditions in the 

special use permits. Refer to each resource section in Chapter 3 for a detailed list of applicable 

standards and guidelines. 

The Forest Service Handbook 2709.11 gives agency-wide direction in the administration of 

outfitter-guide permits (USDA, 2008b).

ANALYSIS METHOD AND DATA SOURCES

Service Days

Use data has been compiled using the most accurate data available. The number of service days 

actually used varies from year to year. Reliable records are available for the past 10 to 20 

years. These records were used to calculate the average number of service days used in the 

past 20 years. Some data gaps and margins of error exist due to data interpretations. Reports 

of use provided by the outfitters occasionally recorded vague or unknown destination locations. 

The data is the best information available, and has a level of accuracy that is more than 

adequate for this analysis. 

Outfitter-Guides

Information on each existing pack and saddle stock outfitter-guide is from the existing permits 

and activities of the outfitters. The effect of the alternatives, including Forest Plan 

amendments, on outfitter-guides is described.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-11 February 2013

Okanogan-Wenatchee National Forest

Best Available Science

The best available science was used for this analysis, including the methodology and data 

sources described above, to describe the economic and social conditions within the analysis 

area, and the potential effects of the proposed outfitter-guide use on resources and people.

AFFECTED ENVIRONMENT

Pack and saddle stock outfitter-guides have been taking people into the analysis area for 

decades. These permitted outfitter-guides provide valuable recreation opportunities for a 

segment of the public who do not have the expertise, equipment, or physical capabilities to 

enjoy these experiences on their own. The need for pack and saddle stock outfitter-guides in 

wilderness has been documented in Assessment of Need for Outfitting-Guiding Assistance, 

Okanogan National Forest, Chelan Ranger District Portion of the Wenatchee National Forest 

North of Lake Chelan, 1996 (Needs Assessment, USDA Forest Service 1996a) and Determination 

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

Wilderness and Lake Chelan-Sawtooth Wilderness, 2012 (USDA Forest Service, 2012a, and 

Appendix B).

The number of pack and saddle stock outfitter-guides and the number of service days has been 

relatively steady for the past twenty to thirty years, although there has been a decrease in 

actual use service days in the past five years. Several factors are possibly contributing to this, 

including a decreased popularity of the activity, wildfires, and the downturn in the economy. 

Ownership of some of the companies has changed, and three are currently not operating. The 

following table shows the average number of reported service days each has had over the past 

20 years (excluding years of authorized non-use).

Figure 3.1-1. Pack and Saddle Stock Outfitter-Guide and 20-Year Average Reported Service Days 

(excluding years of non-use).

Outfitter-Guide Average Reported 

Service Days

Backcountry Burros* 322

Cascade Wilderness Outfitters 1,055

Deli-Llama Wilderness Adventure 96

Early Winter Outfitting 1,412

North Cascade Outfitters 331

North Cascade Safari 891

Pasayten Llama Packing* 183

Rocking Horse Ranch* 712

Sawtooth Outfitters 801

TOTAL 5,803

*No longer operating

The culture and history of the main communities near the analysis area – Winthrop, Twisp, 

Chelan, Tonasket, and Oroville – are built around outdoor activities. The analysis area was used 

for hunting and gathering by native peoples for thousands of years, and with European 

settlement in the mid to late 19800s, the areas were utilized for mining, trapping, and grazing. 

Horses and mules or other pack animals were fundamental components of life during that time 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-12 February 2013

Okanogan-Wenatchee National Forest

as the only mode of transportation. The first trails were constructed during this era, and camps 

were established, many of which remain to this day. 

As the towns grew, the economy was based in agriculture, with sheep and cattle ranching, dairy 

farms, and orchards among the largest contributors. Horses and mules were a necessity for the 

agricultural base, and by the middle of the 20th century, horse packing became a common 

recreational activity. The first permit for pack and saddle stock outfitting-guiding was issued in 

the mid-1950s. More companies were formed, and the number of stock outfitters increased to 

ten by the mid-1980s. When the North Cascades Scenic Highway opened in the early 1970s, the 

town of Winthrop capitalized on the old west culture. Traveling into the back country with pack 

animals and riding horses were historic parts of the culture, and the opportunity to participate 

in these activities continues to attract thousands of people to the Methow Valley every year. 

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

included in Appendix E. Outfitter-guide special use permits specify a number of service days. A 

service day is defined as one day, or part of a day on National Forest System lands for which an 

outfitter-guide provides goods or services, including transportation, to a service. 

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

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

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

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

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

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

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

Wilderness and North Cascades sub-units. 

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

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

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

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

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

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

permit is for 200 service days in the Pasayten Wilderness and North Cascades sub-units.

North Cascade Safaris has been operating under a special use permit since 1970. The current 

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

Sawtooth Backcountry, and North Cascades sub-units. 

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

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

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

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

continue on National Forest System land, and end at the ranch.
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Backcountry Burros, Pasayten Llama Packing, and Rocking Horse Ranch have gone out of 

business, so no longer have permits to operate on the Forest. 

Campsites

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

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

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

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

Description of Trip Types

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

and budgets.

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

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

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

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

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

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

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

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

food.

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

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

camps occur during high and general hunting seasons.

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

clients.

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

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

Livestock Grazing and Confinement

The outfitter-guides use two methods for caring for stock on overnight trips; stock containment 

and loose grazing. Stock containment refers to tying stock to trees for short durations, tying to 

hitch rails or highlines, picketing stock, or holding them in a corral. Loose grazing is a technique 

where the stock are let loose to graze. 

Loose grazing is the preferred method for feeding stock animals because it generally causes the 

least impact on resources. Dispersing the animals reduces concentrated impacts to vegetation 

and soil. More confinement can generally be equated to more impact because it concentrates 

impacts and contributes to restless behavior (Leave No Trace, 2001). Loose grazing does not 

work everywhere, however, so containment methods are also important and appropriate. Even 
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in camps where animals are set loose to graze, containment areas are needed to hold the 

animals while they are being unloaded, packed, or saddled.

Stock containment methods currently used include hitch rails, corrals, highlines, lowlines, 

hobbles, and pickets. Hitch rails are installed at the Sheep Mountain and Bald Mountain 

assigned sites. They consist of wooden side posts and a wooden top rail. There is also a corral 

at Sheep Mountain, constructed with wooden posts and rails. Highlines or lowlines are used at 

most camps. They are made by tying a rope between two trees, then tying the stock to the 

rope. Some outfitters occasionally use pickets to anchor stock to one spot to graze, then move 

the stock to a highline after feeding. 

Confined stock are taken to a grazing area and watering spot, then returned. Processed weedfree feed is often brought for stock that are confined, and to areas where adequate graze is not 

available near the campsite.

Confinement areas within campsites impact opportunities for solitude by increasing the amount 

of barren core, concentrating manure, attracting flies to camp, and damaging vegetation.

Loose grazing is a method used by outfitters in camps they frequent, such as the assigned sites, 

to reduce the amount of time stock are contained within campsites. The outfitter identifies 

areas with sufficient graze typically within one to two miles of camp, depending on the location 

of the camp. These areas are carefully selected to move stock well away from other campsites 

and private stock. The stock are led to the grazing area, or travel there on their own, and left for 

the night. Bells are often placed on one or two of the stock to help the outfitter locate them if 

they don’t return to camp on their own. Some outfitters hobble selected stock to help confine 

movement and facilitate catching, although stock can still travel very well with hobbles. In some 

camps, the stock are led back to camp in the mornings. In others, the stock are trained to return 

in the morning on their own. One to two horses are usually kept contained near the camp at 

night, to facilitate catching horses in the morning if needed. 

Horses and mules are herd animals, so as they graze, they stay in the same general area but 

are widely dispersed within that area and the forage use is well distributed. As with all 

grazing animals, they are constantly moving across the land, eating grasses as they go. Feral 

free-ranging horses typically spend over half their time feeding, and around 25-35% of their time 

resting (Ransom and Cade 2009). Studies with pack stock grazing show horses and mules 

behave similar to feral free-ranging horses. After daily exercise, they feed for an initial 3-4 hour 

bout and then continue to graze every hour with a constant rate of movement (Olson-Rutz et al. 

1996). When not grazing, pack stock rested more than traveling, similar to wild horses (OlsonRutz et al. 1996, Ransom and Cade 2009). 

The constant movement is a characteristic defensive pattern of grazers against predators. The 

stock form a loose herd, always nearby each other, but not tightly congregated. When water is 

readily available as it is in most places in the wilderness, horses do not gather at specific sites to 

drink as in desert environments (Salter and Hudson 1979). Outfitter-guide stock exhibit similar 

grazing behavior to that of free-ranging horses. Typically free-ranging horses move rapidly to 

and from water sources with very little feeding or loafing activities near drinking areas 

(Ganskopp and Vavra 1986). They prefer open areas and elevated terrain away from water and 

thick brush to get away from insects (Keiper and Berger 1982) and to be able to assess potential 
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threats from predators (Ganskopp and Vavra 1986). They avoid muddy areas because they 

instinctually do not want to be mired in mud, and simply because they prefer to keep their feet 

dry. During the night, they sleep by dozing off, and upon waking, graze while moving to a 

different spot. 

Mules have been known to attack burros, but there has been only one documented, reported 

case of this in the past 20 years. The incident occurred at a trailhead, and involved outfitted 

mules and burros. The Forest Service worked with the outfitters to avoid outfitted parties with 

mules and those with burros camping in the same general area. No additional incidents were 

reported. 

Trail Maintenance 

The outfitter-guides assist in trail clearing and maintenance under authorization by the Forest 

Service. They often cut fallen trees out of trails on trips to and from camps, and assist in 

maintaining or replacing trail structures and tread. The number of miles varies from year to 

year, but this benefits all trail users by keeping more trails open. 

Fire Control and Search and Rescue

The pack and saddle stock outfitter-guides also assist in fire control, and search and rescue 

operations of people lost or injured in the back country or wilderness. These are not part of 

their outfitter-guide permitted activities, but the outfitters’ knowledge of the landscape and 

access routes if very valuable and helpful in these situations. They take supplies and people to 

and from fires, and help locate and evacuate people when needed. 

Permit Administration

The outfitter-guides operate according to the terms and conditions of their special use permits. 

The permits themselves contain the standard terms and conditions, a description of the 

permitted activity, and the specific number of service days assigned to the permittee. Operating 

plans are part of the permit for each outfitter, and contain specific information about each 

company, where they operate, season of operation, and many other details about their 

operations. Each outfitter submits estimated use information before the operating season 

begins, then turns in final use reports after it concludes. 

The Forest Service administers these permits by reviewing and approving operating plans, 

tracking service days using the estimated and final use reports, inspecting outfitter operations in 

the field to check for compliance with the terms and conditions of the permit (including 

information in the operating plan), meeting with the outfitter when needed, and completing an 

annual performance evaluation. 

In the late 1990s, a concerned citizen began contacting the Methow Valley Ranger District with 

information about environmental impacts from the pack and saddle stock outfitter-guides. In 

response to the concerns, the Methow Valley Ranger District developed a “Wilderness 

Recreation, Stock, and Outfitter Use Strategy and Action Plan”, signed by the Forest Supervisor 

on April 24, 2000. The objective of the plan was to reduce pack and saddle stock-related 

wilderness impacts in both the Pasayten and Lake Chelan-Sawtooth Wilderness Areas. The plan 

included 22 specific action items for the 2000 outfitter-guide season, and beyond, designed to 

address Forest Plan compliance and concerns raised by the public (USDA Forest Service, 2000e). 
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One of the action items recommended an internal Recreation Activity Review regarding 

recreational impacts in the 2000 season. The recommended review was completed with focus 

on the Spanish Camp/Remmel Lake area. The objective of the review was to determine if 

activities were in compliance with the Forest Plan. The final report, “Recreation Activity Review, 

Spanish Camp and Remmel Lake Area, Pasayten Wilderness” (UDSA Forest Service, 2000c) 

documented a number of corrections needed to bring activities into compliance; however, no 

conditions or threats were found that constituted an emergency or were jeopardizing the 

wilderness resource. In fact, the reviewers found an upward/improving trend in overall 

resource conditions.

The report made several findings that the Methow Valley Ranger District has since been using to 

guide recreation and outfitter-guide management in the Pasayten and Lake Chelan-Sawtooth 

wilderness areas. The actions, which have been taken over the years to address the findings, 

are detailed in Appendix F. 

One of the findings in the review was that special use permit administration has not kept pace 

with the increasing complexity of social, resource, and Forest Service policy issues, nor actively 

sought the outfitter guides as partners to effectively model wilderness stewardship. Since that 

time, the Methow Valley and Chelan Ranger Districts have put a considerable amount of effort 

into improving administration of the permits. These efforts included more frequent field 

inspections of outfitter-guide operations, more frequent meetings with outfitter-guides to 

discuss operations, issuance of notices of non-compliance to outfitters when terms and 

conditions are not followed, and a standardized annual performance evaluation. The results of 

these efforts have been better documentation of operations and performance, and improved 

compliance by the outfitters with the terms and conditions of their permits.

ENVIRONMENTAL CONSEQUENCES

Direct and Indirect Effects

Alternative 1

No pack and saddle stock outfitter-guide permits would be issued with Alternative 1. This 

alternative would not meet the need for pack and saddle stock outfitting-guiding identified in 

the Needs Assessments. This would result in an elimination of the opportunity for people who 

do not own pack and saddle stock, or do not have the skills required to use them, to use this 

mode of travel for recreation on National Forest System land within the analysis area.

Current pack and saddle stock outfitter-guide permit holders would likely go out of business. 

They rely on authorization to use National Forest System land and the type of backcountry 

opportunity provided on forest is not available elsewhere. Impacts to the individual permit 

holders would be substantial, based on comments received from the outfitters on the Draft 

Environmental Impact Statement. 

The amount of trails opened and maintained would be reduced from current levels since the 

outfitter-guides would no longer be assisting with trail maintenance. They would also not be 

available to assist in fire control, or in search and rescue operations.
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Alternative 2

Alternative 2 would issue pack and saddle stock outfitter-guide permits to existing outfitters, or 

qualified replacement applicants. This would meet the need for pack and saddle stock 

outfitting-guiding identified in the Needs Assessments, and continue the opportunity for people 

who do not own pack and saddle stock, or do not have the skills required to use them, to travel 

into the back country using the animals.

Alternative 2 would allow 4,620 service days, which is a small increase over the existing 4,460 

days available now. The outfitters commented on the Draft Environmental Impact Statement 

that they would be able to sustain their businesses with this number of days, but would not be 

able to expand their businesses if demand increases without the increased number of days. 

One of the Forest Plan amendments to wilderness standards and guidelines would allow the 

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

interest areas. This would allow the outfitters to continue to use the camps they are 

accustomed to using, rather than seeking out other existing camp locations. 

The other amendment would not allow camps to exceed 5,250 square feet of barren core. 

Where camps in wilderness exceed this amount, the outfitters would be required to reuse the 

same 5,250 square feet each time they use the camp. In camps with less than 5,250 square feet, 

the outfitters would not be allowed to increase the amount of barren core. The 5,250-foot 

maximum was based on calculations of the size of common stock camp features, such as 

highlines and cook tents. Refer to Appendix C for full details on these calculations. Based on 

comments received from the outfitters on the Draft Environmental Impact Statement, fitting 

within 5,250 square feet would be difficult to achieve. In the outfitters’ professional judgment, 

the original calculations underestimated the size of highlines that could safely contain 18 head 

of stock. Attempting to keep the highline to the size used in the 5,250-foot calculation could 

result in injuries to the stock or people because of stock being too close together or highlines 

becoming loose because of an inadequate number of mid-line support trees. The outfitters 

would also need to reduce the amount of area typically impacted by sleeping tents, stock 

handling, fire ring, and the latrine. These constraints would not meet the needs of the clients, 

and would reduce the quality of the camping experience, according to comments received from 

the outfitters and other responders to the Draft Environmental Impact Statement. Refer to the 

analysis file for comments. 

Pack and saddle stock outfitter-guides would continue to open and maintain trails, helping keep 

more trails available for all users. They would also be available to assist in fire control, and in 

search and rescue operations.

Special use permit administration would continue to ensure compliance with the terms and 

conditions of the permits including all aspects of the alternative, including all mitigation 

measures included in Chapter 2. 

Alternative 3

Alternative 3 would also issue pack and saddle stock outfitter-guide permits, or qualified 

applicants. It would only partially meet the need for pack and saddle stock outfitting-guiding 

identified in the Needs Assessments. There would be a 40% reduction in service days to 2,660, 
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which would be a substantial decrease in the availability of pack and saddle stock outfitter 

guides for people wanting that commercial service. 

Alternative 3 would have a substantial impact on the viability of the outfitters due to the 

reduction in allowable service days, based on Draft Environmental Impact Statement comments 

received from outfitter-guides. The reduction in service days could result in a corresponding 

40% decrease in gross profits generated, assuming that the decrease in in gross revenue would 

mirror the decrease in service days. 

The Forest Plan amendment to reduce party size to twelve in wilderness with this alternative 

would also have a financial impact on the outfitters. Reduced party size would likely increase 

operating costs. The outfitter-guides would need to take fewer clients on each trip, or make 

twice as many trips to full service camps, using one trip to transport the gear and food, and 

another to take clients and staff to camp. For example, five clients and one outfitter-guide each 

riding horses would be a party of twelve. The gear and food for a party of this size would need 

to be taken to the campsite in separate trip. The outfitters whose clients do not ride stock 

would be able to take more clients or pack stock as long as the total party size does not exceed 

twelve, since no saddle stock would be needed. 

The Forest Plan amendment would prohibit the pack and saddle stock outfitter-guides from 

using existing campsites that are within 200 feet of wetlands, streams, lakes, and special interest 

areas. Approximately 46 campsites recently used by the outfitters would no longer be available 

for outfitter-guide use, including the Bald Mountain and Beaver Creek assigned sites. This would 

impact the quality of camping the outfitters could offer their clients, since many of these 46 

camps are the most popular and desirable ones (based on past outfitter-guide use patterns; see 

outfitter-guide use reports in the analysis file. Two additional existing campsites already being 

used by the outfitters would be chosen and designated as assigned sites to replace Bald 

Mountain and Beaver Creek camps. Appendix A indicates which campsites would be closed to 

outfitters.

The Forest Plan amendment to allow up to 2,800 square feet of barren core in campsites could 

be achievable because of the reduced party size. Approximately 85% of the campsites used by 

the outfitter-guides have less than 2,800 square feet of barren core. Nearly all of the campsites 

used most often, including all the assigned sites, have more than 2,800 square feet of barren 

core. The combination of the Forest Plan amendments could force the outfitters to change their 

current operating procedures to take fewer clients to possibly less desirable campsites, and 

offer fewer services and amenities. 

Pack and saddle stock outfitter-guides would continue to open and maintain trails, helping keep 

more trails available for all users. They would also be available to assist in fire control, and in 

search and rescue operations.

Special use permit administration would continue to ensure compliance with the terms and 

conditions of the permits including all aspects of the alternative, including all mitigation 

measures included in Chapter 2. 
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Alternative 4

Alternative 4 would issue pack and saddle stock outfitter-guide permits to existing outfitters, or 

qualified replacement applicants. This would meet the need for pack and saddle stock 

outfitting-guiding identified in the Needs Assessments, and continue the opportunity for people 

who do not own pack and saddle stock, or do not have the skills required to use them, to travel 

into the back country using animals.

Alternative 4 would increase available service days to 6,700. This would give the outfitters the 

opportunity to meet the demand for their services if that demand rebounds to the level seen in 

the early part of the last decade (refer to the 2012 Needs Assessment in Appendix B). According 

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

increasing operating costs and remain viable businesses in the future. 

As with Alternative 2, the Forest Plan amendment to wilderness standards and guidelines 

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

special interest areas would allow them to continue to use the camps they are accustomed to 

using. 

The Forest Plan amendment concerning barren core would allow the pack and saddle stock 

outfitter-guides to use existing barren core in established campsites, but not create additional 

barren core. This would allow enough room for 12 people and 18 head of stock in every camp 

without changing use patterns, or impacting the quality of the camping experience for clients. 

This would allow safe handling and confinement of stock, and comfortable, albeit primitive 

wilderness campsites that would fully meet the needs and expectations of their clients. 

Pack and saddle stock outfitter-guides would continue to open and maintain trails, helping keep 

more trails available for all users. They would also be available to assist in fire control, and in 

search and rescue operations.

Special use permit administration would continue to ensure compliance with the terms and 

conditions of the permits including all aspects of the alternative, including all mitigation 

measures included in Chapter 2. 

Cumulative Effects

Past, present, and reasonably foreseeable future actions in or near the analysis area are listed in 

the first part of this chapter. The spatial boundary for cumulative effects is the analysis area 

plus the outfitter-guides adjacent ranches where outfitters begin trips from their land. The 

temporal timeframe is from the early 1900s (when outfitting first began on the Forest) through 

2022 when the permits that would be issued under this analysis would expire and the effects of 

those permits would cease. The actions mentioned below affect, or have the potential to affect, 

pack and saddle stock outfitter-guides.

Past Actions

Outfitter guides have been operating on these districts for over half a century. They have built 

clientele that return each year, and have attracted an increasing number of clients over time. 
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Present Actions

Figure 3.0-1, beginning on page 3-4, lists all the outfitters currently operating in the analysis 

area. They are helping to meet the need for outfitting and guiding of a variety of activities, 

identified in the 2012 and 1996 Needs Assessments. 

Reasonably Foreseeable Future Actions

It is reasonably foreseeable that all the outfitters listed in Figure 3.0-1 will continue to operate in 

the analysis area, meeting the need for outfitting activities other than pack and saddle stock.

It is also reasonably foreseeable that the Okanogan and Wenatchee Forest Plans will be revised 

in the next few years. The revised forest plan will comply with all laws and regulations, and the 

environmental impacts of the revision will be completed prior to implementation. The pack and 

saddle stock outfitter-guide permits would be amended at that time to follow the new 

standards and guidelines.

Alternative 1

The cumulative effect of the past, present, and reasonably foreseeable future actions and 

Alternative 1 would be to partially meet the need for outfitting and guiding, since the other 

outfitter-guides would continue to provide the commercial services for activities other than 

pack and saddle stock. There would be no outfitter-guides for the pack and saddle stock clients, 

so there would be no opportunity for those lacking the skill or equipment for pack and saddle 

stock trips.

Alternative 2

The cumulative effect of the past, present, and reasonably foreseeable future actions and 

Alternative 2 would be that the existing demand and the future demand based on the past five 

years of actual use for commercial outfitter-guide services for a variety of activities would be 

met. The effect would be that more people would have access to recreation on National Forest 

System land. 

Alternative 3

The cumulative effect of the past, present, and reasonably foreseeable future actions and 

Alternative 3 would be that the need for outfitting and guiding identified in the Needs 

Assessment would only be partially met. About 40% of the established pack and saddle stock 

outfitter-guide services would not be able available. The effect would be that people seeking 

recreation opportunities other than pack and saddle stock would be able to hire commercial 

outfitter-guides, but the availability of pack and saddle stock commercial outfitter-guide services 

would not meet the demand. 

Alternative 4

The cumulative effect of the past, present, and reasonably foreseeable future actions and 

Alternative 4 would be that the existing demand and the future demand based on the past ten 

years of actual use for commercial outfitter-guide services for a variety of activities would be 

met. The effect would be that more people would have access to recreation on National Forest 

System land. 
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CONSISTENCY FINDING

There are no laws or standards and guidelines specific to outfitter-guides aside from those 

addressing resource concerns. Refer to each section in Chapter 3 for a detailed discussion of 

legal and forest plan and other management direction compliance. 

Pack and saddle stock outfitter guides would be required to comply with all permit terms and 

conditions and operating plans. This would be accomplished through on-going permit 

administration activities.

3.2 WILDERNESS

The section below is a summary of the Wilderness Report which is available in the project 

analysis file (Zbyszewski, 2012b).

REGULATORY FRAMEWORK

THE WILDERNESS ACT

The Wilderness Act of 1964 (P.L. 88-577) established the National Wilderness Preservation

System. There are two wilderness areas in the analysis area. The Pasayten Wilderness was 

designated in 1964 with additional area added in 1984, and the Lake-Chelan Wilderness was 

designated in 1984.

The Act includes the management of wilderness (Sec. 2a):

these shall be administered for the use and enjoyment of the American 

people in such manner as will leave them unimpaired for future use and 

enjoyment as wilderness, and so as to provide for the protection of these 

areas, the preservation of their wilderness character, and for the gathering 

and dissemination of information regarding their use and enjoyment as 

wilderness...

Wilderness is defined by the Wilderness Act (Sec. 2c) as:

A wilderness, in contrast with those areas where man and his own works 

dominate the landscape, is hereby recognized as an area where the earth 

and its community of life are untrammeled by man, where man himself is a 

visitor who does not remain.

The Act further defines wilderness as area (Sec. 2c):

...which (1) generally appears to have been affected primarily by the forces 

of nature, with the imprint of man’s work substantially unnoticeable; (2) has 

outstanding opportunities for solitude or a primitive and unconfined type of 

recreation...
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Commercial activities are prohibited by the Act (Sec. 4c):

{e}xcept as specifically provided for in this Act, and subject to existing private 

rights, there shall be no commercial enterprise...within any wilderness area 

designated by this Act...

The Act goes on to specifically authorize commercial service for recreational purposes (Sec. 

4d6):

{c}ommercial services may be performed within the wilderness areas...to the 

extent necessary for activities which are proper for realizing the recreational 

or other wilderness purposes of the areas.

FOREST SERVICE MANUAL

The Forest Service Manual Chapter 2320.2, No. 4, directs the agency to “protect and perpetuate 

the wilderness character”, and to evaluate whether wilderness character is degrading, stable or 

improving over time. 

The Manual includes the Wilderness Management Model, which was modified in the publication 

“Monitoring Selected Conditions Related to Wilderness Character: A National Framework” 

(USDA Forest Service, 2005). This model is the basis for Forest Service wilderness management 

policy. 

The Model shows the relationship between wilderness character and the human influence that 

affects it. The figure below shows the conceptual relationship between the two factors. 

Figure 3.2-1. Wilderness Management Model

As modern human influence increases, the condition of the wilderness character declines, as 

shown by the diagonal line. A goal of wilderness management is to maintain or improve 

wilderness character from its state at the time of wilderness designation. This is often referred 

to as the “non-degradation policy” of wilderness management.

Wilderness character is not specifically defined in the Act. Exploring historical writings of the 

framers of the Wilderness Act, especially those of Howard Zahniser, its principal author, 
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revealed three ideals that are integral to the historic purpose of wilderness, and to 

understanding wilderness character:

Natural environments relatively free from modern human manipulation and impacts. 

Personal experiences in natural environments that are relatively free from the 

encumbrances and signs of modern society.

Symbolic meanings associated with wilderness (Landers, et al, 2005).

“Character” commonly means “the combination of qualities or features that distinguishes one 

person, group, or thing from another” (American Heritage Dictionary 1992) or “the aggregate of 

distinctive qualities” (Webster’s Dictionary 1976). Using these definitions, wilderness character 

is the combination of biophysical, experiential and symbolic ideals that distinguishes wilderness

from other lands. This is a complex and subtle set of relationships between the land, its 

management, and the meanings people associate with wilderness (Landers, et al, 2005).

NEED ASSESSMENT AND MINIMINUM EXTENT NECESSARY DETERMINATION

The Manual also includes the requirement to address the need for and role of outfitters in the 

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

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

areas.”

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

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

Commercial Services (Outfitters and Guides) in the Pasayten Wilderness and Lake ChelanSawtooth Wilderness”, June 2010 (USDA Forest Service, 2010). This document was revised to 

respond to public comments on the Draft Environmental Impact Statement. The calculations in 

the 2010 document were confusing, and the finding of need was based on providing enough 

service days to keep the existing outfitters in business. This did not meet the intent of 

establishing the minimum extent necessary to meet the provisions in the Wilderness Act . The 

revised document is titled “Determination of Need and Extent Necessary for Commercial 

Services (Outfitters and Guides) in the Pasayten Wilderness and Lake Chelan-Sawtooth 

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

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

Assessment. Refer to Appendix B for complete information, analysis, and calculations.

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

wilderness. The criteria used for the evaluation included:

Is the activity allowed in wilderness?

Does the activity educate clients about the wilderness resource?

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

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

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

services?

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

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

wilderness directly in conversations about wilderness, and indirectly through demonstrating 

how to travel and stay in the wilderness without modern conveniences. Pack and saddle stock 
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Okanogan-Wenatchee National Forest

outfitter-guide’s trips promote solitude by taking clients to remote locations within wilderness, 

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

public purpose by offering trips for recreation, scenic viewing, and historic use. Their services 

are needed by an element of the public due to the fact that many people are not skilled in stock 

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

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

others because of the hazards associated with stock.

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

that can be precisely calculated. Rather, several factors are considered to establish a range of 

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

need for commercial services, 

historic number of service days,

proportional relationship between outfitter and non-outfitted use levels,

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

wilderness capacity, and 

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

Historic Number of Service Days

The range of years used for this determination was from 2001 to 2010. There has been a 

decline in outfitter guide service days in the past five years, but the reason for that decline in 

unknown. The decline may be a result of wildfires, the downturn in the economy, decreased 

demand, or other factors. The eleven year span was selected in case the factors affecting the 

use change, and the need increases to the levels seen earlier in the 11-year span.

The lowest number of service days, or an average of a range of years cannot be used in the 

minimum extent necessary determination. The number of people needing the services of an 

outfitter-guide will vary from year-to-year, so the minimum extent of commercial services 

allowed needs to be large enough to cover the years with the largest need. 

Proportional Relationship Between Outfitted and Non-outfitted Use Levels

Comparing the current visitor day totals to the largest need, approximately 30% of pack and 

saddle stock users need outfitter-guides services in the Pasayten Wilderness, and 

approximately 5% in the Lake Chelan-Sawtooth.

Current Resource Conditions and Impacts on Wilderness Character

The analysis of the impact of existing recreation use (including outfitter-guides) on 

wilderness character has shown that there are localized impacts to the opportunities for 

solitude, but these are not interfering with the current upward trend in wilderness character 

for the Pasayten or Lake Chelan-Sawtooth wildernesses. Current conditions meet or exceed 

the expectations of the vast majority of wilderness visitors (Burns, et al, 2010). 

Wilderness Capacity

The capacity analyses for the Pasayten and the Lake Chelan-Sawtooth found that the existing 

amount of use is within the biophysical and social capacities, with some areas needing closer 

monitoring to ensure that wilderness character is not degraded. 
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Anticipated Changes in Need and Demand

There will be increasing demand for recreation in the coming years. The technical report 

Outdoor Recreation in the Pacific Northwest and Alaska: Trends in Activity Participation (Hall 

et al., 2009) and Washington State’s Interagency Committee on Outdoor recreation 

(Interagency Committee on Outdoor Recreation, 2003) both predict the increase. The 

Interagency Committee estimates that there will be a 13% increase in the number of people 

hiking and backing, and a 3% increase in the number of people riding horses in the next 10 

years (Interagency Committee on Outdoor Recreation, 2003). These projections are used to 

estimate the number of people who will be recreating in the Pasayten and Lake ChelanSawtooth ten years from now.

The shifting demographics in the population will influence the minimum extent of 

commercial services needed. The need for stock outfitter guides is likely to increase as the 

population ages, and more people are physically unable to access the wilderness on foot or 

carrying a backpack. There will be approximately 25% more people in the over 50 age class 

by 2020 (Washington State Office of Fiscal Management, 2010). The number of people in 

this age class wanting to travel into the wilderness could also increase by approximately 25%. 

Since approximately 73% of stock outfitter-guide clients are over 49 years old, the minimum 

extent of stock outfitter-guide service days could be an additional 25% above and beyond the 

3% increase in stock users estimated by Washington State (Interagency Committee on 

Outdoor Recreation, 2003). 

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

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

FOREST PLAN STANDARDS AND GUIDELINES

The Okanogan National Forest Land and Resource Management Plan (Okanogan Forest Plan, 

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

Forest Plan, 1990) contain standards and guidelines to ensure compliance with the Wilderness 

Act and Forest Service Manual 2320. Standards and guidelines specify activities related to 

planning, facilities, use, administration, trails, in addition to fish and wildlife, vegetation, range, 

noxious weeds, soil and water, minerals, lands, and protection. In the Okanogan Forest Plan, 

these standards and guidelines are on pages 4-86 through 4-97. In the Wenatchee Forest Plan, 

the standards and guidelines are on pages IV-69 through IV-77, IV-227 through IV-232, and on E4 through E-23. Maps 1-4 and 1-5 show the wilderness areas and management areas.

Management Areas

Okanogan Forest Plan

In an effort to provide a spectrum of recreation opportunities appropriate in wilderness, the 

Okanogan Forest Plan established two wilderness management areas. These areas are 

Trailed (MA 15B) and Trail-less (MA 15A). Map 1-4 and Map 1-5 in the Map Section show 

division of the Pasayten and Lake Chelan-Sawtooth Wilderness Areas into these two 

management areas. All outfitter-guide travel routes and camps included in this EIS are 

within the Trailed area (MA 15B). There may be a rare instance where drop camp clients 

may visit on foot the Trailless area (15A) from a campsite in the Trailed area (MA 15B).
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Okanogan-Wenatchee National Forest

The Desired Future Condition in the Okanogan Forest Plan states that the Trailed area will 

provide a high to moderate opportunity for exploring and experiencing isolation and 

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

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

challenge and risk. The Trail-less area will provide an outstanding opportunity for isolation 

and solitude and utilizing primitive skills in an environment offering a high degree of 

challenge and risk. Standards in the Okanogan Forest Plan have been established that 

represent the appropriate social and resource conditions for the Trailed (MA 15B) and Trailless (MA 15A) areas.

Wenatchee Forest Plan

A portion of the Lake Chelan-Sawtooth Wilderness is located on the Chelan Ranger District, 

and is covered by the Wenatchee Forest Plan, 1990. The Wenatchee Forest Plan has both 

Forestwide (LRMP, IV-69 to IV-77) and management prescription specific management 

direction for wilderness (WI-1, LRMP page IV-227 to IV-232, and Appendix E), and divides 

wilderness into four recreation opportunity spectrums: Pristine, Primitive, Semi-Primitive, 

and Transition. Pack and saddle stock outfitter-guides are allowed to operate in areas 

where their use is consistent with the standards and guidelines of the Wilderness Recreation 

Opportunity Spectrum. 

Pristine: This area is characterized as an extensive, unmodified, natural environment. 

Natural processes and conditions have not been measurably affected by the actions of 

users. The area will be managed as free as possible from the influences of human 

activity. Terrain and vegetation allow extensive and challenging cross-country travel, 

however the use of stock is not encouraged for cross-country travel.

Primitive: The area is characterized by an essentially unmodified, natural environment. 

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

high opportunity for isolation, solitude, exploration, risk, and challenge.

Semi-Primitive: The area is characterized by a predominately unmodified environment 

of at least moderate size. Campsites and system trails are present and there is evidence 

of other uses. A minimum of on-site controls and restrictions are implemented to 

protect physical, biological, and social resources. Some facilities may be present to 

reduce visitor impact.

Transition: The area is characterized by a predominately unmodified environment, 

however, the concentrations of visitors may be moderate to high at various times. The 

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

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

boundaries.

The Desired Future Conditions for wilderness areas, as stated in the Wenatchee Forest Plan 

are that wilderness resource values will be somewhat improved through management of 

recreation visitor use. A general upward trend should be apparent in monitoring results. 

The expected increase in visitors will result in more management actions employed to 

reduce use in heavily impacted areas, disperse use into areas that can accommodate more 
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Okanogan-Wenatchee National Forest

use, and more regulations to alleviate specific problems. Restoration and revegetation of 

heavily impacted areas will be on-going in areas where visitor use has resulted in loss of 

vegetation and unnatural or accelerated soil erosion. Refer to page IV-6 in the Wenatchee 

Forest Plan for more information on the desired future condition.

Standards and Guidelines

The Okanogan and Wenatchee Forest Plans contain standards and guidelines designed to 

ensure compliance with the Wilderness Act, and Forest Service policy.

Two of the four components of the Wilderness Act definition of wilderness are reflected in 

the standards and guidelines: “generally appears to have been affected primarily by the 

forces of nature, with the imprint of man’s work substantially unnoticeable”, and “has 

outstanding opportunities for solitude or a primitive and unconfined type of recreation”. 

The standards and guidelines frame the management direction to protect wilderness 

character. There are also general standards and guidelines that address the undeveloped 

and natural qualities of wilderness, and the opportunities for solitude or primitive and 

unconfined recreation. Refer to the Okanogan Forest Plan, pages 4-91 through 4-97, and 

the Wenatchee Forest Plan, pages IV-69 through IV-77, IV-227 through 232. The 

Consistency finding section of this analysis, beginning on page 3-91, includes a full list of 

standards and guidelines, including details of how the proposed action and alternatives 

comply with each. 

ANALYSIS METHOD

This report analyzes and discloses the effects pack and saddle stock outfitter-guide activities 

have on wilderness character. Since the outfitter-guides are only a portion of overall recreation 

use (10% of all use and 32% of pack and saddle stock use in the Pasayten, and 2% of overall use 

and 6% of stock use in the Lake Chelan-Sawtooth), the environmental effects of all recreation 

use, and how those effects change with the alternatives, are included in the cumulative effects 

section. 

The analysis follows the process detailed in “Applying the Concept of Wilderness Character to 

National Forest Planning, Monitoring, and Management”, by Peter Landers et al., December 

2008. 

A key component of the wilderness resource is wilderness character. The concept of wilderness 

character comes from Section 2(a) of the Wilderness Act: “ ... for the use and enjoyment of the 

American people in such a manner as will leave them unimpaired for future use and enjoyment 

as wilderness and so as to provide for the protection of those areas, the preservation of their 

wilderness character.” 

Wilderness character is, in part, an intangible concept, yet results in substantial disagreement 

over whether the agency is managing wilderness in a manner that meets the legal requirements 

of the Act. For this reason, this analysis will use concepts from the Act to help frame the 

discussion. The four qualities will be referred to throughout this analysis and used to represent 
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wilderness character. These four qualities are derived from the definition of Wilderness, Section 

2(c) of the Act, which contains distinct attributes that link to the concept of wilderness 

character:

A Wilderness, in contrast with those areas where man and his own works dominate the 

landscape, is hereby recognized as an area where man himself is a visitor who does not 

remain. An area of wilderness is further defined to mean in this Act an area of 

undeveloped Federal land retaining its primeval character and influence, without 

permanent habitation, which is protected and managed so as to preserve its natural 

conditions and which (1) generally appears to have been affected primarily by the forces of 

nature, with the imprint of man’s work substantially unnoticeable; (2) has outstanding 

opportunities for solitude or a primitive and unconfined type of recreation; (3) has at least 

five thousand acres of land or is of sufficient size as to make practicable its preservation 

and use in an unimpaired condition; and (4) may also contain ecological , geological, or 

other features of scientific, educational, scenic, or historical value.

The four qualities or concepts of wilderness character that will be addressed throughout this 

analysis are: 

1. Untrammeled – wilderness ecosystems are essentially unhindered and free from human 

control or manipulation. Recreation activities do not impact this quality, since they do 

not intentionally control or manipulate the ecosystems.

2. Undeveloped – wilderness is essentially without permanent improvements or modern 

human occupation. Recreation activities do not impact this quality, unless they involve 

construction of buildings or require motorized or mechanized equipment.

3. Natural – wilderness ecological systems are substantially free from the effects of 

modern civilization. Recreation activities can influence this quality through pack and 

saddle stock grazing, and impacts to water quality, stream bank erosion, and 

disturbance to soils.

4. Outstanding opportunities for solitude or a primitive and unconfined type of 

recreation – wilderness provides outstanding opportunities for people to experience 

solitude or primitive and unconfined recreation, including the values of inspiration and 

physical and mental challenge. This is the quality most affected by recreation activities. 

The number of visitors, and encounters between them, number and condition of 

campsites, number of user-created recreation facilities, and number of miles of trails all 

impact the opportunities for solitude, or a primitive and unconfined type of recreation 

(Landers et al, 2008). 

Landers et al. (Landers et al, 2008) describes the technique of using these qualities in evaluating 

effects to wilderness character. Wilderness character is the primary administrative 

responsibility mandated by the Wilderness Act, but it is not defined by the Act. Wilderness 

character is the biophysical, experiential, and symbolic relationships and meanings that 

distinguish wilderness from all other lands, is supported or degraded by stewardship decisions 

and action, and is unique to each wilderness. 

The wilderness resource analysis uses these qualities for evaluating the effects of management 

actions on the wilderness character. In addition to the use of the four qualities of wilderness 

character in the evaluation, the context, intensity, duration, and type of effects provide 
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Okanogan-Wenatchee National Forest

boundaries for the effects analysis. For the purpose of this analysis, the following approach is 

used.

Context: Local effects are those that occur at site-specific locations within the wilderness. 

Wilderness-wide impacts would be effects to the entire wilderness. 

There are activities outside the wilderness boundary of the Pasayten and Lake Chelan-Sawtooth 

wildernesses that may have cumulative effects when considered with the effects of the 

alternatives. Developed recreational sites, such as campgrounds and trailheads, exist in many 

locations near the wilderness boundary. In these cases, activities outside the wilderness 

boundary may have effects inside wilderness areas.

Intensity: The intensity of the impact considers whether the effect to wilderness character is 

negligible, minor, moderate, or major. Negligible effects are considered not detectable to the 

visitor and therefore expected to have no discernible outcome. Minor effects are slightly 

detectable, though not expected to have an overbearing results on wilderness character. 

Moderate effects would be clearly detectable to the visitor and could have an appreciable effect 

on one or more aspects of wilderness character. Major effects would have a substantial, highly 

noticeable influence on the visitor’s experience and could permanently alter more than one 

aspect of wilderness character.

Duration: The duration of the effect considers whether the impact would occur in a short- or 

long–term period. A short-term effect would be temporary in duration, such as an encounter 

while traveling or camping. A short-term effect (to physical qualities of wilderness character) 

would be 1 to 2 years. A long-term effect would have lasting effects on the wilderness 

character, such as an impression from noticeable ecological impacts. Long-term physical effects 

to the wilderness character last 10 to 20 years.

In summary, the objective of this analysis is to forecast potential environmental effects of the 

proposed action and alternatives on wilderness resources with particular attention to qualities 

of wilderness character. Wilderness character is described by using four qualities: 1) 

untrammeled; 2) undeveloped; 3) natural; and 4) outstanding opportunities for solitude or a 

primitive and unconfined type of recreation of wilderness character. The context of impacts, 

intensity of impacts, and the duration and type of impacts— as defined above— further bound 

the analysis. The topics focus the discussion on meaningful and relevant effects.

DATA SOURCES

Pack and Stock Outfitter-Guide Activities

Pack and saddle stock outfitter-guide activities are constantly monitored as part of the special 

use permit administration process (see monitoring data in the analysis file). This process 

generates information about compliance with permit terms and conditions, camp conditions, 

use patterns, grazing practices, and other permit and resource information. This information 

was used to evaluate compliance with the Wilderness Act, FSM 2300, and Forest Plan standards 

and guidelines.
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Service Days

Use data has been compiled using the most accurate data available. The number of service days 

in the existing pack and saddle stock outfitter-guide permits plus the number of days in the 

priority use pool is used as the current service days. The number of service days actually used 

varies from year to year. Reliable records for the Pasayten and Lake Chelan-Sawtooth are 

available for the past 10 to 20 years. Some data gaps and margins of error exist due to data 

interpretations. Reports of use provided by the outfitters occasionally recorded vague or 

unknown destination locations. The data is the best information available, and has a level of 

accuracy that is more than adequate for this analysis. More detailed use data, or data that goes 

back farther in time, is not essential and is not critical to the analysis of wilderness character 

attributes. 

Monitoring Data

The Forest Service has been monitoring conditions in the Pasayten and Lake Chelan-Sawtooth 

wilderness areas for over 20 years. Specific information includes campsite conditions, including 

the size of barren cores, number of trees with exposed roots, and other elements. Monitoring 

has been done on areas around campsites where pack and saddle stock graze. This monitoring 

has gathered information used to determine wilderness character and the impacts of pack and 

saddle stock outfitter-guide activities on the character. This information was also used to 

determine compliance with existing Forest Plan standards and guidelines. Refer to the 

Wilderness folder in the analysis file for complete monitoring data.

Encounter Data

A permit system is used to gather information about wilderness trips, including date, duration, 

type of use, area, etc. The information from these permits, in addition to observations made by 

wilderness rangers, was used to determine the number of encounters a wilderness visitor is 

likely to have with other groups. This was used to assess the opportunities for solitude, and 

compliance with standards and guidelines. Refer to the Wilderness folder in the analysis file for 

complete encounter data and analysis.

Total Recreation Use Levels

Monitoring was completed in 2005 and 2010 to gather information about the number of people 

recreating in the wilderness areas. Refer to the Revised National Visitor Use Monitoring 

(NVUM) Results for the Okanogan National Forest, Data Collected FY2005, Revised May 2012

(USDA, 2012b), and Data Collected FY2010, August 2011 (USDA, 2011). 

The findings for the 2005 monitoring were updated by the authors between the Draft EIS for the 

Pack and Saddle Stock Outfitter-Guide Special Use Permit Reissuance (USDA 2010), and the Final 

EIS. The updated results were substantially lower than the original used in the DEIS. The results 

of the 2010 monitoring were also issued between Draft and Final, and these results were 

substantially lower than the revised 2005 results.

Because of this discrepancy, the Forest Service compiled data from the registration permits for 

the Pasayten Wilderness in an attempt to resolve the inconsistent results from NVUM. 

Wilderness visitors are required to fill out a registration permit prior to entering the Pasayten. 

Data from these permits was compiled and averaged for 2001 through 2011. Refer to the 

analysis file for full permit data.
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The 2005 NVUM reported 11,000 visits to the Pasayten, with an average length of stay of 40.7 

hours. Multiplying these numbers gave the total number of hours spent in the Pasayten. 

Dividing this product by 24 hours converted 11,000 visits to 18,654 visitor days. 

The 2010 NVUM reported 5,000 visits to the Pasayten with an average stay of 12 hours. This 

calculated to 2,500 visitor days.

The averaged permit data showed 16,830 visitor days, which was relatively close to the 18,654 

visitor days from the 2005 NVUM. This validated the 2005 results, and suggests the 2010 data is 

not reliable enough to use. 

There is no required permit system for the Lake Chelan-Sawtooth Wilderness, so NVUM data 

must be used to estimate visitor days. Since the 2005 NVUM data for the Pasayten appears to 

be close to the averaged permit data, the 2005 data for the Lake Chelan-Sawtooth and the 

Pasayten is assumed to be the most reliable information available. 

Comparisons of Outfitted and Non-outfitted Use

The number of service days in the existing pack and saddle stock outfitter-guide permits plus the 

number of days in the priority use pool and the total recreation use information from the 2005 

NVUM survey (USDA, 2006c & USDA, 2006d) were used to calculate the comparisons of 

outfitted to non-outfitted use. The number of service days varies from year to year, as does the 

total number of recreationists (outfitter and non-outfitted), so these percentages are merely 

estimates, and do not represent an exact reflection of the relationship between outfitted and 

non-outfitted use in any given year. This is the best available data, however, since the Forest 

Service calculates overall use numbers once every five years. More accurate percentage 

calculations are not essential or critical to the analysis of wilderness character attributes. Any 

impacts to wilderness character as a result of not having more precise data are not likely to 

affect the decision making process because they would be localized and minor in context of 

impacts from overall use. Current conditions and future uses are the most relevant factors to 

consider.

Future Estimates of Recreation Use Levels

The number of visitor days expected in the future was calculated using projected changes 

included in the Washington State Comprehensive Outdoor Recreation Planning (SCORP) 

publication “Estimates of Future Participation in Outdoor Recreation in Washington State” 

(Interagency Committee for Outdoor Recreation 2003). These projected changes were for 10 

and 20-year periods based on participation data from the 1999-2000 RCO survey (IAC 2003). 

These projections, shown in Figure 3.2-21, took into account NSRE data and projections for the 

Pacific Northwest Region, demographic trends in Washington State, the local supply of lands 

available for recreation activities, and other factors.

Social Monitoring Data

Another monitoring exercise was conducted in 2009 to gather information about visitor’s 

perception of the condition of the wilderness, including sense of crowding, resource condition, 

social conflicts, and other elements. The results documented in the paper titled “2009 

Wilderness Use Study: A comparison of Pasayten and Lake Chelan-Sawtooth Wilderness Use 

Patterns”, May 2010, (Burns, et al, 2010) were used to evaluate opportunities for solitude, 

undeveloped character, capacity, and social conflicts. 
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Barren Core

All barren core measurements throughout this document are approximate. Barren core was 

calculated using measurements of barren areas within campsites, taken in the field during 2011 

and 2012. These measurements were converted to square feet, and are the best data available. 

The bare areas are never straight-sided shapes where repeated measurements are likely to 

generate consistent results. Rather they are typically odd-shaped, with more than one area 

occurring within a single campsite. Repeat measurements of barren core will fluctuate from one 

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

and pattern of actual measurements. 

Best Available Science

The best available science was used for this analysis, including the methodology and data 

sources described above, to describe the ecological and social conditions within the analysis 

area, and the potential effects of the proposed outfitter-guide use on wilderness character.

AFFECTED ENVIRONMENT

Historic Activities

The wilderness character in the Pasayten and Lake Chelan-Sawtooth wilderness areas has been 

stable or on an upward trend since the areas were designated as part of the Wilderness 

Preservation System (1968 for the Pasayten, and 1984 for the Lake Chelan-Sawtooth). In order 

to understand this, it is important to consider the historic use of the areas. Human activities 

altered the biophysical condition of the resources prior to designation. Commercial livestock 

grazing and wildfire suppression had altered plant communities over much of the landscape, 

and fish stocking of high elevation lakes changed the aquatic ecosystems and recreation use 

patterns. Recreation activities (including outfitting and guiding), livestock herders, and mining 

activities created a network of trails, campsites, and scattered buildings in both wilderness 

areas. Some of the effects of these past activities are still evident today. 

Grazing

Historical grazing changed the condition of the wilderness areas before they were 

designated, and continued to adversely impact the untrammeled and natural qualities of the 

areas while grazing continued after designation. Prior to the introduction of livestock 

grazing, the areas that became the Pasayten and Lake Chelan-Sawtooth Wilderness Areas 

were largely untouched by human activities. Grazing altered the vegetative communities 

across large portions of the areas. Sheep and cattle herders established camps where they 

stayed when the livestock were grazing. These camps were large (well in excess of the 

current 400 foot barren core standard), and resulted in damaged trees in and around the 

camps. When the grazing allotments were vacated, the condition of the landscape began to 

improve. Some altered vegetative communities began to slowly return to pre-grazing 

conditions. Campsites not used by the public revegetated. Campsites that were used by the 

public changed very little after the areas were designated as wilderness due to the short 

growing season, and impacts from continued use. These are continuing to impact the 

opportunities for solitude.
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Wildfires and Wildfire Suppression

Wildfire is a natural process in wilderness. In the early to mid-1900s, the Forest Service 

started suppressing wildfires. This has had a major, adverse impact to the wilderness-wide 

untrammeled and natural qualities of the Pasayten and Lake Chelan-Sawtooth Wildernesses. 

The suppression changed the disturbance cycle of the ecosystem, leaving much of the 

wilderness areas with high levels of down material, which has led to higher density stands, 

and increased mortality from insects and disease.

Some of the lower elevations surrounding the western slopes of the Lake Chelan-Sawtooth 

have burned in the last 10 years. This burn pattern reduces the probability of fires burning 

upslope from Lake Chelan to spread fire into the wilderness, since the wilderness boundary is 

within approximately 50 feet of the lake’s high water mark. Over 200,000 acres have burned 

in the Pasayten in the last 10 years. Areas burned by high severity fire in Andrews and 

Farewell Creek drainages continue to elevate the risk of debris slides in these two 

watersheds. The wildfires caused short-term displacement of recreationists, increasing use 

in portions of the wilderness away from the burned areas. Use patterns returned to pre-fire 

conditions once the fires burned out and trails were repaired to allow access.

Fish Stocking

In the 1930s, various sportsmen's associations began stocking high lakes, historically fishless 

waters, with various species of fish. The Washington Trail Blazers, formed in 1933, continues 

to volunteer for the State Department of Fish and Wildlife in this role by packing fish in on 

their backs and with stock. In 1958, a similar advocacy group, the HiLakers, formed around 

the common goal of enhancing opportunities for high lake fishing. Approximately 40 lakes 

have been and continue to be stocked in the Pasayten and Lake Chelan-Sawtooth 

wildernesses. 

The stocking has major localized impacts on the natural and untrammeled quality of the 

wilderness areas since it changed the structure of the aquatic ecosystems in each stocked 

lake. In addition, stocked lakes became a focal point for recreational use. Consequently 

much of the higher density recreational impact in wilderness occurs in lake basins, 

decreasing the opportunities for solitude.

Mining

The Pasayten and Lake Chelan-Sawtooth have a history of mining activity. The biggest mine 

in the Pasayten is the Tungsten located near the boundary between the Tonasket and 

Methow Valley districts. It operated from the early 1900s to approximately the 1930s. 

Mineral rights for the Tungsten and several other claims in the vicinity were found to be 

invalid in 1989. There are four buildings still standing at the site, though not maintained by 

the Forest Service. The mine is a destination for some recreationists. There is a large barren 

core at the mine site. Unauthorized maintenance of the buildings by members of the public 

is having a major impact on the undeveloped quality of wilderness character and the 

opportunities for solitude in the vicinity of the mine. The structures interfere with the 

primeval character since they are evidence of modern human occupation. The sights and 

sounds of people at the mine decrease the remoteness of the area.

Mines were staked in the late 1890s and early 1900s on Gilbert and Crescent Mountains in 

the Lake Chelan-Sawtooth Wilderness Area in the upper Twisp River. Operations at the 
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Crescent ended around 1915 after a depression forced the Canadian company financing the 

operation to abandon the project. Some evidence of the old mine exist; it is not a 

destination for recreationists and seldom visited. The miner leasing the claims on Gilbert 

Mountain constructed the trail to North Lake in the 1940s to extract and transport ore. 

There are currently no activities at these claims. In 1984, 375 Jolly claims were established 

on Gilbert Mountain, however little to no activity has occurred on any of them (Portman 

1993).

These mining activities had moderate, local impacts to the undeveloped quality in the 

immediate vicinities because they show evidence of modern human occupation. The impact 

is lessening over time as the buildings and mine shafts decay. 

Recreation Use

People have been using pack and saddle stock to travel into the backcountry for nearly a 

century. Pack and saddle stock outfitter-guides have been operating in the areas for 

decades, before the Pasayten and Lake Chelan-Sawtooth Wildernesses were designated, and 

long before the Forest Plans were signed and implemented. Parties that included over 

twenty people, and forty head of stock were common. Camps were constructed and 

maintained to provide for clients’ comfort, with facilities such as permanent latrines, picnic 

tables, cook tents with wooden floors and ovens, camp furniture, and tent pads. Trees were 

cut down for firewood, or to improve the view or lay-out of camps. Pack and saddle stock 

were tied to trees, damaging some, and exposing their roots. All these activities were 

completely legal and acceptable at the time. As commercial grazing was eliminated, many 

camps used by commercial livestock permittees were converted to pack and saddle stock 

outfitter camps. This created and perpetuated camps with large areas of vegetation loss and 

compacted bare mineral soil, trees with exposed roots, trees killed by recreation activities, 

and removal of all snags in and around camps. 

Hiking and backpacking started to gain popularity in the 1960s and 1970s, and overtook 

horseback riding as the most common mode of transportation into the backcountry. 

Outfitter-guides offering trips in backpacking and wilderness skills have been operating in the 

Pasayten and Lake Chelan-Sawtooth wilderness areas since 1977. These groups occasionally 

use the large, established campsites, but also operate in the trail-less portions of the 

wilderness areas, teaching their clients about hiking, backpacking, mountaineering, survival 

skills, environmental and wilderness education.

Many of these campsites established by the sheep herders are used today by recreationists 

and outfitters. Due to the level of historic and continuing use, these hardened sites are still 

devoid of vegetation cover. Most of the camp areas predate the current Forest Plans and 

exceed current plan standards for vegetation loss and compacted bare mineral soils, and 

number of trees with exposed roots. The camps are having a localized, moderate effect on 

the opportunities for solitude because they detract from the remoteness from sights of 

people inside the wilderness. 

Forest Service Administration

Several cabins were constructed in the wilderness areas for Forest Service employees 

working in the areas. The Hidden Lakes, Spanish Camp, Horseshoe Basin, and War Creek 
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Okanogan-Wenatchee National Forest

cabins were staffed nearly every summer, and regularly maintained. The buildings are having 

localized, moderate impacts on the undeveloped quality of the wilderness areas.

Trail Maintenance

Trails have been maintained on a regular basis since they were developed. Both the people 

using the trails and the Forest Service have kept the trails open by cutting fallen trees, 

constructing and maintaining drainage structures and bridges, and maintaining trail tread for 

nearly 100 years. Trails have also been relocated when needed to prevent or correct 

resource damage.

In the 1970s and 1980s, the Forest Service was maintaining about 600 to 700 miles of trail in 

the Pasayten and 120 to 150 miles in the Lake Chelan-Sawtooth annually. Trail maintenance 

budgets began to decline in the 1990s, gradually reducing the miles of trail maintained 

annually to between 350 and 500 in the Pasayten, and 85 to 90 in the Lake Chelan-Sawtooth. 

This reduction concentrated people on to the maintained trails. 

Trail maintenance has helped manage recreation use, but has had localized negative impacts 

to the opportunities for solitude by concentrating and containing use on the existing trails. 

The negative impact from the trails is offset by the beneficial impact of keeping traffic 

localized and controlled, and leaving the vast majority of each wilderness area untouched. 

This has protected the opportunities for solitude across most of the wilderness areas.

Restoration Activities

The Forest Service has been working to restore campsites and trails since the Pasayten 

became a designated wilderness in 1968, and the Lake Chelan-Sawtooth was designated in 

1984. These have improved the opportunities for solitude by restoring impacted sites by 

controlling and limiting use, and constructing facilities at campsites to reduce further damage 

to vegetation and soil. A list of these recreation activities is included in the analysis file. 

Pasayten Airport

The Pasayten Airport was constructed starting in 1931. It was built to accommodate small 

aircraft. It was maintained as a landing strip and airport until the Pasayten was designated a 

wilderness in 1968. The runway can still been seen, although small trees are growing on the 

north half. A cabin and barn are located next to the runway which the Forest Service uses as 

housing for wilderness rangers or as a base camp for trail maintenance. This is a destination 

spot for some outfitted non-outfitted pack and saddle stock users, but not used frequently 

because it is one of the few places with forage for stock.

Although no longer used for aircraft, the airport continues to have a moderate, local impact 

to the undeveloped quality of the immediate area as a result of the landing strip disturbance 

and the presence of the cabin.

Untrammeled Quality

The current recreation use, including the current pack and saddle stock outfitter guide activities, 

is having no effect on the untrammeled quality of the Pasayten or Lake Chelan-Sawtooth 

wildernesses. This quality pertains to the wilderness ecosystem, and whether it is essentially 

unhindered and free from human control or manipulation (Landers et al, 2008). Pack and saddle 

stock outfitter-guide activities and non-outfitted recreation use are certainly causing localized 
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Okanogan-Wenatchee National Forest

impacts, but these are more associated with the Natural and Opportunities for Solitude qualities 

of wilderness character, and are discussed below. As discussed in the previous section titled 

“Historic Activities”, livestock grazing, wildfire suppression, and fish stocking have had 

wilderness-wide, moderate to major, long-term impacts to wilderness character. The overall 

condition of both wilderness areas has been on an upward trend since designation due to the 

elimination of commercial livestock grazing and implementation of forest plan standards and 

guidelines.

Undeveloped Quality

Recreation activities are also not impacting the undeveloped quality in either wilderness. The 

undeveloped quality is that wilderness is essentially without permanent improvement or 

modern human occupation. Non-recreational structures, inholdings, use of motorized or 

mechanized equipment, or impacts to cultural resources degrade the undeveloped quality 

(Landers et al, 2008). The existing recreation use, including pack and saddle stock outfitter 

guides does not depend on or result in these indicators, and therefore is not impacting this 

quality. Building and cabins were constructed in the past for mining activities at the Tungsten 

Mine, trapping, the construction and maintenance of the Pasayten Airstrip, and Forest Service 

administration. Many of these structures remain today, and degrade the undeveloped quality 

of the wilderness. 

Natural Quality

The natural quality refers to wilderness ecosystems that are substantially free from the effects 

of modern civilization. Ecological systems inside wilderness are directly affected by things that 

happen inside, as well as outside wilderness. Indicators of the natural quality are plant and 

animal species communities, physical resources, and biophysical processes (Landers et al, 2008). 

Recreation activities, including pack and saddle stock outfitter-guides, can impact plant 

communities through stock grazing, and animal communities through disturbance of individuals 

or habitat. Pack and saddle stock use can also impact physical resources if watering spots or 

trail crossings change water quality, lead to streambank erosion, or disturb soils.

The current recreation use, including existing and pack and saddle stock outfitter-guides, was 

evaluated in terms of impacts to plant communities and wetlands, with detailed included in the 

Botany section of the FEIS, and the Botany Report in the analysis file. Impacts to animal species 

were analyzed in the Wildlife section; water quality in the Hydrology section, and soil in the Soil 

section and their respective specialist’s reports in the analysis file. Each analysis found localized 

impacts to these indicators in some locations, but no impacts wide-spread or intense enough to 

adversely affect the natural quality of either wilderness. Refer to the mentioned sections in the 

FEIS, and supporting data in the analysis file for more information.

Opportunities for Solitude or Primitive and Unconfined Recreation

Current recreation use, including pack and saddle stock outfitter-guides is impacting the 

opportunities for solitude in both wilderness areas, in addition to the opportunities for primitive 

and unconfined recreation. The meaning of solitude has been at the center of considerable 

debate, but was likely viewed as encompassing attributes such as separation from people and 

civilization, inspiration, and a sense of timelessness by early wilderness writings. Primitive 

recreation refers to travel that is non-motorized and non-mechanized, and requires reliance on 

personal skills to travel and camp. The unconfined component refers to areas free of 

management confinement or controls. Primitive and unconfined environments together 
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Okanogan-Wenatchee National Forest

provide ideal opportunities for the physical and mental challenges associated with adventure, 

real consequences for mistakes, and personal growth that result from facing and overcoming 

obstacles (Landers et al, 2008).

Recreation use is impacting the remoteness from sights and sounds of people inside wilderness -

an indicator of this quality. Specifically, the amount of use, number of trail contacts, impacts 

from recreational livestock grazing, and the number and condition of campsites all impact 

opportunities for solitude, or primitive and unconfined recreation. Each of these is discussed 

below.

Current Recreation Use

Current pack and saddle stock outfitter-guide activities are a small percentage of overall 

recreation use in the Pasayten and Lake Chelan-Sawtooth Wilderness Areas. In the Pasayten, 

outfitter-guide clients make up about 9% of total use and 32% of the pack and saddle stock 

use. In the Lake Chelan-Sawtooth, outfitter-guide clients are about 2% of the total use and 

6% of the pack and saddle stock use. Refer to Figures 3.10-1, 3.10-2, 3.10-3, and 3.10-4 

below. The effects of pack and saddle stock outfitter guide activities are the same as those 

caused by non-outfitted pack and saddle stock use. 

Non-outfitted groups tend to be smaller than some outfitted groups. Based on use records 

over the past 10 years (see use record data in the analysis file) outfitter-guides occasionally 

have groups with 12 people and 18 head of stock (with occasional oversize parties by written 

authorization), while non-outfitted groups normally do not reach this party size limitation. 

The average size of an outfitted pack and saddle stock group is 8 people and 14 head of stock 

(based on outfitter-guide use records over the past 10 years). The average size of a nonoutfitted group is 3 people and 5 head of stock and non-outfitted groups tend to spend 

fewer days in wilderness (based on trailhead registrations) compared to outfitter-guide 

groups with full-service and drop camps. 

In terms of evaluating the effect of pack and saddle stock outfitter-guides on the current 

condition of the wilderness, the analysis focuses on the environmental effects of the pack 

and saddle stock outfitter-guides, and the cumulative effects of all recreation activities on 

wilderness. The following sections discuss the use levels in each wilderness.

Pasayten Wilderness

The 531,541-acre Pasayten Wilderness is located on both the Methow Valley and 

Tonasket Ranger Districts. There are about 18,700 annual visitor days (one visitor day 

equals one person for one day) in the Pasayten. This number was calculated by 

converting the number of annual visits reported in the National Recreation Use 

Monitoring completed on the Okanogan National Forest in 2005 to visitor days. The 

number of annual visits was 11,000, and the average length of stay was 40.7 hours 

(averaged for the Pasayten and Lake Chelan-Sawtooth together). Multiplying these 

numbers gives the total number of hours spent in the Pasayten. Dividing this product by 

24 hours converted 11,000 visits to 18,654, rounded to 18,700 visitor days. 

About 70% are hiking/backpacking visitor days, and 30% use pack and saddle stock. This 

breakdown was developed by analyzing trailhead registrations, wilderness permits, and 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-38 February 2013

Okanogan-Wenatchee National Forest

the professional judgment of the wilderness manager and wilderness rangers on the 

Methow Valley Ranger District. 

The number of service days in the current pack and saddle stock outfitter-guide permits 

plus the amount in the priority use pool were used to calculate the current percentage of 

overall use outfitter. None of the hikers reported in the total visitor day column are pack 

and saddle stock outfitter-guide clients2. Approximately 32% of the pack and saddle stock 

users are outfitted. Overall, pack and saddle stock outfitter-guide service days represent 

9% of the visitor days in the Pasayten.

Figure 3.2-2. Number of Visitor days by User Group in the Pasayten, and Number of Pack and Saddle 

Stock Outfitter-Guide Service Days in Current Permits.

User Group Total Visitor days Current Pack and Saddle 

Stock Outfitter-guide 

Service Days

% of Total 

Visitor Days

Backpackers 13,090 0 0%

Stock Users 5,610 1,800 32%

Total 18,700 1,800 9%

The number of pack and saddle stock was estimated using the average party size for outfitted 

and non-outfitted groups. The calculations are included in the Wilderness Report in the analysis 

file (Zbyszewski, 2012). A stock day is one head of stock for one day. The following figure 

displays the approximate number of stock days, and the division between outfitted and nonoutfitted users.

 

2

There are commercial hiking/backpacking companies operating in the wildernesses. Refer to the 

cumulative effects analysis for this information, and how the use cumulatively affects wilderness 

character.
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Okanogan-Wenatchee National Forest

Figure 3.2-3. Approximate Number of Stock Days in Outfitted and Non-outfitted Parties in Pasayten 

Annually, and Percent of Total 

Total Number of 

Visitor/Service Days Per 

Year

Approximate Number 

of Stock Days Per year

Percent Stock Days of 

Total

Non-outfitted Pack and 

Saddle Stock Use

3,810 6,350 67%

Outfitted Pack and 

Saddle Stock Use

1,800 3,150 33%

Total 5,610 9,500

Wilderness access from the Tonasket District includes the Irongate, Chewuch, Long 

Swamp and Fourteen Mile trailheads. On the Methow Valley District, the Thirtymile, 

Andrews, Lake Creek, Crystal Lake, and Billygoat trailheads lead to the Pasayten from the 

Chewuch watershed. In the Harts Pass area, trails from the Robinson Creek, West Fork 

Pasayten, Monument Creek, Buckskin Ridge, Harts Pass, and Pacific Crest Trail North 

trailheads lead to the Pasayten. The Devils Pass and Lightning Creek trails that lead from 

the shore of Ross Lake and the Canyon Creek trailhead enter the west side of the 

Pasayten.

Pack and saddle stock users favor and are more common in the Spanish Camp/Remmel 

Lake, Sheep Mountain/Corral Lake, and Horseshoe Basin areas of the Pasayten. The 

Robinson Creek and Pasayten River areas also receive some stock use, but there is a 

limited amount of forage and more difficult trail access so stock use is relatively light 

compared to Spanish Camp/Remmel Lake and Sheep Mountain/Corral Lake areas. The 

Hidden Lakes area also receives some stock use, with approximately one-quarter of the 

use with stock. Tatoosh Buttes has ample forage but stock use outside of high hunt 

season is limited by more difficult trail access. The Pacific Crest Trail, Buckskin Ridge area, 

and the portion of the Pasayten west of the Pacific Crest Trail generally have light stock 

use.

The highest concentration of hikers and backpackers are in the Horseshoe Basin, Pacific 

Crest Trail, Buckskin Ridge, middle portion of Robinson Creek area, Jackita Ridge, and 

Hidden Lakes areas. Sheep Mountain/Corral Lake, Spanish Camp/Remmel Lake, and 

Pasayten River destinations are popular but require more time for access. Lower 

Robinson Creek and Monument Creek trails are used primarily by day hikers.

Lake Chelan-Sawtooth Wilderness

The 153,129 acre Lake Chelan-Sawtooth Wilderness is divided between the Methow 

Valley and Chelan Ranger Districts. There are about 56,332 annual visitor days (one 

visitor day equals one person for one day) in the Lake Chelan-Sawtooth. This number was 

generated by the National Recreation Use Monitoring completed on the Okanogan and 

Wenatchee National Forests in 2005 The number of annual visits was 33,218 (USDA, 

2006c & 2006d). The report states that the average length of stay was 40.7 hours 

(averaged for the Pasayten and Lake Chelan-Sawtooth combined), so the 33,218 visits was 

converted to approximately 56,332 visitor days. 
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Okanogan-Wenatchee National Forest

About 65% are hiking/backpacking visitor days, and 35% use pack and saddle stock. This 

breakdown was developed by analyzing trailhead registrations, wilderness permits, and 

the professional judgment of the wilderness manager and wilderness rangers on the 

Methow Valley Ranger District.

The number of service days in the current pack and saddle stock outfitter-guide permits 

plus the amount in the priority use pool was used to calculate the current percentage of 

overall use for outfitters. As in the Pasayten, none of the hikers included in the total 

visitor days are pack and saddle stock outfitter-guide clients3. Approximately 4% of the 

pack and saddle stock users are outfitted. Overall, outfitter-guide service days represent 

1% of the visitor days in the Lake Chelan-Sawtooth.

Figure 3.2-4. Current number of Visitor days by User Group in the Lake Chelan-Sawtooth, and Number 

of Outfitter-Guide Service days in Current Permits.

User Group Total Visitor 

days

Current Pack and Saddle 

Stock Outfitter-guide 

Service Days

% of Total Visitor Days

Hikers 23,790 0 0%

Pack and 

Saddle Stock 

Users

12,810 715 6%

TOTAL 36,600 715 2%

The number of pack and saddle stock was estimated using the average party size for 

outfitted and non-outfitted groups. The calculations are included in the Wilderness Report 

in the analysis file (Zbyszewski, 2012b). A stock day is one head of stock for one day. The 

following figure displays the approximate number of stock days, and the division between 

outfitted and non-outfitted users.

Figure 3.2-5. Approximate Number of Stock Days in Outfitted and Non-outfitted Parties in the Lake 

Chelan-Sawtooth Annually, and Percent of Total 

Total Number of 

Visitor/Service Days Per 

Year

Approximate Number 

of Stock Days Per year

Percent Stock Days of 

Total

Non-outfitted Pack and 

Saddle Stock Use

12,095 20,162 94%

Outfitted Pack and 

Saddle Stock Use

715 1,260 6%

Total 12,810 21,422

On the Methow Valley Ranger District, the Wolf Creek, Slate Creek, Scatter Creek, Gilbert, 

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

Buttermilk, East Fork Buttermilk, Scaffold Ridge, and Libby Lake trailheads provide direct 

access. On the Chelan Ranger District, the Fish Creek, Prince Creek trailheads provide 

access; these areas are located on the shores of Lake Chelan and accessible by boat.

 

3

There are commercial hiking/backpacking companies operating in the wildernesses. Refer to the 

cumulative effects analysis for this information, and how the use cumulatively affects wilderness charater.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-41 February 2013

Okanogan-Wenatchee National Forest

Non-outfitted pack and saddle stock use in the Lake Chelan-Sawtooth Wilderness has 

increased since the construction of the Twisp River Horse Camp in the early 1990s. The 

camp provides 13 campsites for people with horses or other pack animals, and has an 

outhouse, feeding mangers, hitch rails, high lines, and watering troughs. The camp is not 

used by outfitters. It is filled to capacity most weekends in July and August. The number 

of people riding on Twisp River trails has increased with the popularity of this camp. The 

majority of people using the Horse Camp are day riders, with North Lake and Louis Lake 

the most popular destinations. Other trails include South Creek, Scatter Creek, Twisp 

Pass, War Creek, and Williams Lake.

Contacts or Encounters

Outstanding opportunities for solitude, primitive, and unconfined recreation exist in most 

locations throughout the Pasayten and Lake Chelan-Sawtooth. Every person has a different 

perception of solitude, and of how many encounters with others it takes to lose the sense of 

solitude. The 2009 Wilderness Study gathered information on people’s perception of the 

opportunity for solitude by asking about crowding (Burns, et al, 2010). Approximately 90 to 95% 

of those interviewed did not feel crowded at all or felt only slightly crowded during their trips in 

the wilderness areas. The feeling of crowds is grounded in a person’s expectations, and about 

three-quarters (72% in the Pasayten and 79% in the Lake Chelan-Sawtooth) of the people saw as 

many or fewer people than they expected. Roughly one-half (55% in the Pasayten and 42% in 

the Lake Chelan-Sawtooth) of the visitors felt solitude is part of the wilderness experience, while 

the other half (43% in the Pasayten and 48% in the Lake Chelan-Sawtooth) felt that they did not 

expect complete solitude and expected to see other people some of the time (Burns, et al, 

2010). 

David Cole and Troy Hall found similar satisfaction levels when they conducted surveys and 

analyzed the data from wilderness areas around Oregon and Washington. In their paper titled 

Wilderness Visitors and Experiences in Oregon and Washington: Trailhead Surveys in Thirteen 

Forest Service Wildernesses, 2005, they reported that most visitors appeared to be highly 

satisfied with their trip and with wilderness conditions. They categorized trailheads into very 

high use, high use, and moderate use, with moderately used trails receiving less than one-third 

of the use of the very high use trails. The differences among visitors to each category of 

trailhead were surprisingly small. It appeared that visitors to more highly used trailheads had 

adjusted their tolerance of other wilderness users. Most knew what conditions they were likely 

to find, adjusted their expectations accordingly, and found their trips enjoyable. Most people 

were able to find solitude, or at least have what they considered a real wilderness experience 

(Cole and Hall, 2005).

Encounters between groups or parties on trails has an impact on opportunities for solitude. 

Hikers must step to the downhill side of the trail if at all possible when they encounter pack or 

saddle stock. Stock can be startled if the hikers are uphill, endangering the riders and hikers. 

Some hikers feel frightened or intimidated when they encounter horses or a pack string of mules 

on the trail, and may find it difficult or scary to step to the downhill side of the trail. This can 

impact the opportunities for solitude for riders and hikers, depending on the personalities of the 

people involved, and how the stock react to the situation.

The Forest Service has had backcountry rangers gather encounter data since 2001. Rangers 

record the number of groups they encounter for each section of trail and associated 
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Okanogan-Wenatchee National Forest

destinations. Encounters with previously contacted groups are counted as a separate encounter 

when more than 20 minutes passes between contacts. Rangers patrol high use areas more 

often and are generally scheduled for the busiest use periods such as holidays and weekends. 

Thus their encounter data might be slightly skewed to the high end. Data collected in over 1,129 

ranger patrol days and 2,400 encounters indicates that both wilderness areas are meeting 

Forest Plan standards for encounters: “There is a better than 80% chance of visitors not 

encountering more than seven encounters per day between groups while traveling on trails 

during all use periods.” There is a 98% probability of encountering not more than seven parties 

on the trail in the Pasayten on any given day, and a 99% probability in the Lake ChelanSawtooth. 

Since certain portions of each wilderness are more popular, the data was examined for different 

trail and travel corridors to see if standards were being exceeded at specific locations. The 

following tables show data for common trails and travel corridors in the two wilderness areas. 

Some travel corridors include several sections of trail in order to best capture typical visitor 

travel patterns. 

Pasayten

In the Pasayten, the highest encounter rates occurred on the Pacific Crest Trail, and this was the

most likely location for a visitor to have more than seven encounters. Data for the Pacific Crest 

Trail may be slightly skewed higher as backcountry rangers did not always differentiate 

encounters on the Pacific Crest Trail between the Harts Pass trailhead and Windy Pass which is a 

popular day hike and outside of the wilderness. Other locations that occasionally exceeded 

seven encounters were: the Hidden Lakes, Buckskin Ridge, Boundary Trail, Devils Dome, and 

Pasayten River trails. The highest likelihood of more than seven encounters generally occurred 

on weekends and holidays in July, August, and September, but also occurred randomly during 

the week. Trails such as the Pacific Crest Trail, Billy Goat, Buckskin Ridge, Chewuch, and 

Andrews serve as primary access routes into the wilderness so it is not uncommon for 

encounter rates to be higher near the trailhead and drop further into the wilderness as people 

disperse to various destinations. Other factors have also influenced the amount and distribution 

of use, which influences encounters. Weather, fire activity, featuring a particular trail or trip in 

the media, can cause an obvious increase or decrease at specific in use on a yearly basis on an 

individual trail. 
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Okanogan-Wenatchee National Forest

Figure 3-2-6. Probability of Encountering Not More Than Seven Parties By Pasayten Travel Corridor.

Travel 

Corridors/Trails

Trail 

Numbers

Patrol 

days

Total 

Encounters

Days exceeding 

seven 

encounters

Probability of 

encountering more 

than seven groups

West Fork Pasayten 472 9 24 0 0%

Hidden Lakes 477, 458 405 647 2 0%

Robinson, Mainstem 

& Middle Fork 

Pasayten River

478, 474, 

451

78 144 1 1%

Monument Creek 484 3 2 0 0%

Tatoosh Buttes 485 21 32 0 0%

Buckskin Ridge 498 28 65 1 4%

Lake Creek 500 25 78 0 0%

Larch Creek Trails 502, 502A 88 173 0 0%

Andrews Creek 504 103 196 0 0%

Chewuch 510, 360 71 118 0 0%

Crystal Lakes 517 2 6 0 0%

Boundary Trail 533 136 243 1 1%

Devils Dome, 

Canyon Creek

752, 738, 

754

27 49 1 4%

Pacific Crest Trail 2000, 472A, 

473

70 279 9 13%

Lake Chelan – Sawtooth

The Lake Chelan-Sawtooth receives more day use than the Pasayten. Popular destinations 

include: South Creek, North Lake, Louis Lake and Twisp Pass. The highest likelihood of more 

than eight encounters generally occurs on weekends and holidays in July, August and 

September. As in the Pasayten, there are many factors influencing amount and distribution of 

use, which influences encounters. Weather, fire activity, or featuring a particular trail or trip in 

the media, can cause an obvious increase or decrease in use on a yearly basis on an individual 

trail. Detailed encounter information is in the Wilderness Report in the analysis file (Zbyszewski, 

2012). 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-44 February 2013

Okanogan-Wenatchee National Forest

Figure 3.2-7. Probability of Encountering Not More Than Seven Parties By Lake Chelan-Sawtooth Travel 

Corridor.

Travel Corridors/Trails Trail 

Numbers

Patrol 

days

Total 

Encounters

Days exceeding 

seven 

encounters

Probability of 

encountering more 

than seven groups

South Creek 401 9 12 0 0%

Reynolds Creek 402 1 0 0 0%

Williams Lake 407 16 12 0 0%

War Creek 408 12 49 0 0%

West Fork Buttermilk 411 6 4 0 0%

North Lake 413 22 61 1 5%

Slate Lake 414 1 0 0 0%

Libby Lake 415 6 2 0 0%

East Fork Buttermilk 420 4 1 0 0%

Copper Pass 426 9 10 0 0%

Scatter Lake 427 10 22 0 0%

Louis Lake 428 13 42 1 8%

Twisp Pass 432 18 97 0 0%

Wolf Creek 527 3 35 0 0%

Scaffold Ridge 436 18 97 0 0%

Summit Trail 1259 18 97 0 0%

The duration of these impacts would be short term if all recreation activity stopped, but in reality 

is long-term because continued use of impacted areas is perpetuating the impacts, such as 

vegetation loss, soil disturbance, damaged trees, , and other impacts from modern temporary 

occupation. The following discussion details the existing conditions in established campsites.

Campsites

People enjoying the abundant opportunities for unconfined recreation in the Pasayten and 

Lake Chelan-Sawtooth Wildernesses have had an effect on ecological conditions and 

wilderness character. Opportunities for solitude or unconfined recreation are decreased 

because the sights and sounds of people detract from the remoteness of wilderness. There 

are approximately 637 established campsites in the Pasayten Wilderness, 75 of which are 

used consistently by the pack and saddle stock outfitter-guides. In the Lake ChelanSawtooth, there are approximately 338 established campsites, 78 of which are used by the 

outfitters.

Historic uses of the Pasayten and Lake Chelan-Sawtooth created campsites with relatively 

large areas of barren core (vegetation loss), trees with exposed roots, social trails, and other 

impacts. Recreationists, including outfitters, have continued to use many of these sites, 

perpetuating, and in some cases enlarging the camps. Outfitters have also been directed by 

Forest Service staff to use these large and already impacted sites whenever possible versus 

creating new disturbance. Since the areas were designated as wilderness, campsite locations 

and size have fluctuated. New campsites have been created by both the outfitted and nonoutfitted public, and some established campsites have started to recover. Overall the effects 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-45 February 2013

Okanogan-Wenatchee National Forest

are localized, and minor on a wilderness-wide scale, and moderate on a local scale. The 

effects are generally long-term due to continued use and a short, dry growing season, 

inhibiting recovery. Vegetation tends to recover at a faster rate than damaged trees. 

Both Forest Plans have standards and guidelines establishing the maximum amount of 

hardened area in established campsites. The Okanogan Forest Plan sets the standard at 250 

to 400 square feet of “vegetation loss”, and the Wenatchee Forest Plan specifies 400 to 

1,000 square feet of “vegetation loss and compacted bare mineral soil.” “Vegetation loss” 

and “vegetation loss and compacted bare mineral soil” are both alternate names for what is 

more commonly called “barren core.” This is the area within a camp devoid of vegetation 

with exposed soil. The term “barren core” is used in this document in place of the Forest 

Plan terminology. Many campsites in both the Pasayten and Lake Chelan-Sawtooth have 

more than the specified number of square feet of barren core, and more than the number of 

trees with exposed roots. These sites do not comply with the Forest Plan standards and 

guidelines. 

Since the implementation of Forest Plans, the Forest Service has been monitoring campsite 

conditions. Monitoring protocols have changed over the years, so some elements of data 

collected are not consistent over multiple surveys. Additionally, there may be variations in

area calculations, attributable to a variety of data collectors over the years. Early surveys 

focused on gathering in-depth site information from sites across the wilderness, but they did 

not capture all of the known sites across the entire wilderness. Thus there is not baseline 

data for many sites. 

Extensive surveys were completed in 2011 and 2012 with the goal of capturing a minimum of 

95% of the known campsites for each wilderness. The survey was based on the “National 

Minimum Recreation Site Monitoring Protocol,” but protocols were expanded to include 

barren core estimates. The number of damaged trees was also recorded as a part of this 

survey, however this number included damage to the bole as well as damage to the roots, 

which makes it challenging to directly correlate to the Forest Plan standard for exposed 

roots. As of September 2012 surveys have been completed on 242 established campsites in 

the Lake Chelan-Sawtooth, and 626 campsites the Pasayten. Where baseline data exists, the 

monitoring show that resource conditions at campsites are on an improving trend. This is 

true for camps that are used primarily by outfitters and for camps that are used primarily by 

non-outfitted stock users. There are approximately 117,694 square feet collectively in all the 

campsites consistently used by the pack and saddle stock outfitter-guides. This converts to 

approximately 2.7 acres scattered across the 531,541-acre wilderness. In the Lake ChelanSawtooth, there are approximately 48,534 square feet, or 1.1 acre in 153,129-acre 

wilderness.

Monitoring has also shown that the amount of barren core in a campsite can fluctuate from 

one year to the next based on use patterns and weather. Each party that uses a campsite 

influences the condition of the camp based on how and where stock are contained, where 

tents are set, and the location of the campfire ring, and other factors. Weather determines 

vegetative growth, so the amount of barren core can increase in dry years and decrease in 

wet years. Reduced trail maintenance has resulted in a decrease in use in many areas, which 

has corresponded to decreases in barren core. Likewise large fires in the Pasayten have had 

a similar effect. In the eastern Pasayten, many campsites in meadows have shown 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-46 February 2013

Okanogan-Wenatchee National Forest

remarkable vegetative recovery with large decreases in barren core numbers. However, 

other indicators such as damaged trees persist for much longer and those numbers have not 

shown as much improvement. 

The area of barren core and number of trees with exposed roots are generally greater in 

campsites frequently used by stock compared to campsites never or rarely used by stock. 

Stock campsites often consist of a camping area and one or more stock containment areas. 

There is also a grazing area associated with many campsites frequented by the pack and 

saddle stock outfitter-guides, where stock are turned out for loose-grazing. Generally 

speaking, the loose-grazing stock travel up to two miles away from campsites. Grazing is 

dispersed across a large area, and any evidence or effects are minimized. Refer to discussion 

of stock containment and loose grazing, beginning on page 3-52.

In an attempt to meet the standard and guideline pertaining to trees with exposed roots, a 

hitching regulation for stock enacted in 1992 for the Lake Chelan Sawtooth and in 2001 for 

the Pasayten, prohibited tying stock directly to trees for an overnight period, or in a manner 

to cause damage to the roots or tree boles. While this has decreased damage to tree roots, 

it has resulted in a change at stock camps with high lines being used outside the traditional 

stock containment areas where high lines could not be properly installed. These highline 

areas increased vegetation loss at many horse camps.

Campsites that are used primarily by hikers generally have a camping area and a smaller or 

no stock containment area compared with campsites frequented by horse and mule parties. 

Outfitted drop camps, llama and burro outfitted parties utilize both stock camps used by the 

non-outfitted stock users and hiker campsites.

The campsites used by pack and stock users still exceed the standard for vegetation loss and 

have more than the allowed number of trees with exposed roots per site despite this upward 

trend. The average amount of barren core at established campsites is 1,663 square feet in 

the Pasayten and 602 in the Lake Chelan-Sawtooth. Most of the bigger sites in the Pasayten 

have more than 4 damaged trees, while less than have of the sites in the Lake ChelanSawtooth exceed that number. 

Campsite monitoring also collected data concerning the visibility of campsites from trails and 

other campsites, and the distance between campsites. Approximately 77% of the campsites 

in the portion of the wildernesses covered by the Okanogan Forest Plan are partially or fully 

screened. Campsites are only visible or audible if occupied. The capacity analysis done in the 

2012 Needs Assessment (Appendix B) demonstrated that use levels are well below the 50% 

occupancy level. Based on this data, the conclusion can be drawn that there is an 80% or 

higher probability of two or fewer campsites being visible or audible from any campsite. In 

the portion covered by the Wenatchee Forest Plan, there is no more than one campsite

visible or audible from any one campsite because camps are either screened or over 500 feet 

apart. 

The following table shows analysis for barren core and tree damage based on the recreation 

site inventory completed in 2011 and 2012. Approximately 344 sites without any barren core 

were excluded from this analysis. These were un-established trace sites and sites that have 

fully recovered. 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-47 February 2013

Okanogan-Wenatchee National Forest

Figure 3-2.8. Percent of Established Campsites Exceeding 400, 1,000, and 2,800 Square Feet of Barren 

Core and With More than Four Damaged Trees in Pasayten and Lake Chelan-Sawtooth Wildernesses

Pasayten Wilderness Lake Chelan-Sawtooth Wilderness

All sites Sites Used by Pack and 

Saddle Stock Outfitterguides

All sites Sites Used by Pack 

and Saddle Stock 

Outfitter-guides

Sites exceeding 400 sq. 

feet

46% 68% 41% 27%

Sites exceeding 1,000 

sq. feet

23% 40% 16% 25%

Sites exceeding 2,800 

sq. feet

6% 19% 6% 22%

Average Barren Core 775 1,663 630 602

Sites with more than 

four damaged trees

41% 75% 39% 47%

In addition to monitoring, the Forest Service has worked over the years to bring sites into 

compliance with standards and guidelines. Examples of this work include: regulations 

intended to reduce impacts and closing sites for restoration. This work has been limited by 

budget constraints, but has helped contribute to the upward trend in campsite conditions. 

Although impacts from past use are recovering under the current management direction, 

campsites frequented by pack and stock users still exceed the standard for vegetation loss 

and have more than the allowed number of trees with exposed roots per site. 

The following tables show the pack and saddle stock outfitter-guide campsites in the 

Pasayten and Lake Chelan-Wilderness areas which exceed 2,800 square feet currently, or 

exceeded 2,800 square feet in the past. Where data exist, the change in the amount of 

barren core at each site recorded between 1989 and 2002 is compared to the most current 

data. Many of the sites had not been surveyed prior to the monitoring completed in 2011 

and 2012. The information for campsites with less than 2,800 square feet of barren core is 

included in Appendix A.

Figure 3.2-9. Established Camps in the Pasayten Used by Outfitter Guides with over 2800 square feet of 

Barren Core.

Camp Name Square Feet of 

Barren Core

(from monitoring 

completed from 

1989 to 2002)

Square Feet of 

Barren Core

(from monitoring 

completed in 2011 

and 2012)

Damaged Trees 

(from monitoring 

completed in 2011 

and 2012)

Comments

3 Fools No Data 2,800 More than 10 Used occasionally 

by outfitters for fullservice and drop 

camps

Bald Mountain* No Data 3,900 Less Than 4 Used by outfitters 

for full-service and 

drop camps

Beaver Creek* 8,038 6,747 More than 10 Used by outfitters 

as full-service camp 

site.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-48 February 2013

Okanogan-Wenatchee National Forest

Camp Name Square Feet of 

Barren Core

(from monitoring 

completed from 

1989 to 2002)

Square Feet of 

Barren Core

(from monitoring 

completed in 2011 

and 2012)

Damaged Trees 

(from monitoring 

completed in 2011 

and 2012)

Comments

Charlie Brown

(Spanish Camp 2)

15,239 1,870 4 to 10 Used by outfitters 

for full-service and 

drop camps

Chandler

(Spanish Camp 1)

9,181 60 More than 10 Used by outfitters 

as a drop camp

Chewuch

(Drop C)

No Data 3,000 More than 10 Used by outfitters

as a drop camp

Corral Lake No Data 3,500 More than 10 Used by outfitters 

as a drop camp

Cougar Lake No Data 2,916 More than 10 Used regularly by 

the general public 

as well as outfitters.

Crow Lake* No Data 9,610 More than 10 Used by outfitters 

as full-service camp 

site.

Crow Lake 2 No Data 7,000 More than 10 Recreation camp, 

not used regularly 

by outfitters

Fred’s Lake No Data 5,400 More than 10 Used occasionally 

by outfitters for fullservice and drop 

camps

Goat Lakes Basin 

2 

2,650 3,000 4 to 10 Used occasionally 

by outfitters for 

drop camps

Peeve Meadow 5,500 5,640 More than 10 Used occasionally 

by outfitters for 

drop camps

Sheep 

Mountain* 

19,368 8,879 More than 10 Used by outfitters 

as full-service camp 

site.

Spanish Creek 6,000 60 4 to 10 Recreation camp, 

not used regularly 

by outfitters

Tatoosh 3,316 900 More than 10 Used by outfitters 

as full-service camp 

site 

WhistlerBasin No Data 4,020 More than 10 Used occasionally 

by outfitters for fullservice and drop 

camps

Whistler Camp* 9,906 3,254 More than 10 Used by outfitters 

as full-service camp 

site

*Assigned Site
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-49 February 2013

Okanogan-Wenatchee National Forest

Figure 3.2-10. Established Camps in Lake Chelan-Sawtooth used by Outfitter Guides with over 2800 

square feet of Barren Core

Camp Name Square Feet of Barren 

Core

(from monitoring 

completed from 1989 

to 2002)

Square Feet of 

Barren Core

(from monitoring 

completed in 2011 

and 2012)

Damaged Trees 

(from monitoring 

completed in 2011 

and 2012)

Comments

Bike West No Data 2,900 4 to 10 Used occasionally by 

outfitters for fullservice and drop 

camps

Cascade Creek 21,000 NA NA Unable to locate the 

site, as the area 

burned very hot in 

early 2000’s. No 

longer accessible to 

stock. 

Muleshoe 2 9,134 3,000 More than 10 Used occasionally by 

outfitters for fullservice and drop 

camps

Muleshoe North No Data 4,200 More than 10 Used occasionally by 

outfitters for fullservice and drop 

camps

Prince 4 Mile 5,600 0 Less than 4 Historically used by 

outfitters for fullservice camps. 

Burned in 2003. 

Little to no recent 

use

Surprise No Data 3,500 More than 10 Used occasionally by 

outfitters for fullservice and drop 

camps

Twin Springs 1 12,245 3,071 More than 10 Used occasionally by 

outfitters for fullservice and drop 

camps

Pack and Saddle Stock Outfitter-guide Camps

Pack and saddle stock outfitter guides use a combination of assigned camps (Bald 

Mountain, Sheep Mountain, Crow Lake, Beaver Creek, and Whistler), and designated and 

non-designated sites. In the Pasayten and the portion of the Lake Chelan-Sawtooth on 

the Methow Valley Ranger District, outfitters can camp in any established campsite, and 

tend to re-use the same ones over the years. In the portion of the Lake Chelan-Sawtooth 

on the Chelan Ranger District, outfitters are restricted to using designated campsites only. 

Appendix A includes a list of all established, regularly used campsites. The campsites are 

shown on Map 3.2-1, Map 3.2-1 and Map 3.2-3 in the Map Section of this document.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-50 February 2013

Okanogan-Wenatchee National Forest

Across both wildernesses, totaling approximately 685,000 acres, there are approximately 

153 camps frequently used by pack and saddle stock outfitter guides, and of these, 42, or 

approximately 28% (those used regularly for full-service camps) see more impacts than 

less frequently used campsites (refer to Figures A-1 and A-2 in Appendix A). More 

impacts include large barren cores, excessive number of trees with exposed roots, social 

trails, and other impacts. 

The campsites that have the most effect on the opportunities for solitude or primitive and 

unconfined recreation character are the assigned sites and the non-assigned sites used 

for full-service camps. These camps are typically set up for the entire season in the 

assigned sites, and for the duration of the trip in the non-assigned sites (usually 4 to 7 

days). The camps usually have a kitchen area and cook tent, sleeping tents, stock 

handling area, fire pit area, latrine, and stock handling and tying areas. Stock are usually 

turned out to graze in nearby areas, but return to the camp each day so clients can take 

day-rides from the base camp. Keeping the stock in or near the camp for these extended 

times increases the amount of vegetation damage and soil exposure. There are usually 

social trails leading between the different sections of the camp, and often stock trails 

between the camp and the grazing area. 

These campsites have the sights and sounds of people in the wilderness, therefore 

detracting from the remoteness of wilderness. They have minor to moderate localized 

impacts to opportunities for solitude, depending on their location and whether or not the

camps are occupied. Their impact is minor to negligible at the wilderness scale. 

Campsites where outfitters drop clients and do not remain at the site with their stock 

have fewer effects than campsites where stock remain (full service camps). These sites 

typically have kitchen and sleeping tent areas and a fire ring, and relatively small areas 

disturbed by confined stock since the outfitters only keep stock in camp for short periods. 

The outfitters tie stock to trees while loading and unloading, then move on to the next 

camp. 

The Forest Service monitors the outfitter camps as part of the permit administration 

process. The camps are visited and reviewed by Forest Service employees as often as 

possible during the operating season. Reviews are timed to occur when camps are 

occupied so conditions can be discussed on-the-ground with the outfitter, whenever 

possible. The following sections include information about the camps used by the 

outfitters.

Pasayten

Pack and saddle stock outfitter-guide activity occurs in the areas most popular with nonoutfitted pack and saddle stock users. The assigned, Bald Mountain and Beaver Camps 

are in the Spanish Camp/Remmel Lake area. The assigned Crow Lake and Sheep 

Mountain camps are in the Sheep Mountain/Corral Lake areas. Whistler Camp, also an 

assigned site, is in the Pasayten River area. Assigned sites are the only ones where nonoutfitted use is prohibited. The locations are shown on Map 3.2-1 in the Map Section. 

Each of the assigned campsites is described below.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-51 February 2013

Okanogan-Wenatchee National Forest

The Bald Mountain Camp was creates by one of the pack and saddle stock outfitters 

approximately 15 years ago, and has been used as an assigned site ever since. It has 

a barren core area of approximately 3,900 square feet, and 29 trees with exposed

roots. The camp is located on a flat area, on a north-east aspect, far from the 

summit. There is a hitchrail, but no other constructed features. Spanish Creek is 

approximately 300 yards below the camp. Stock are turned loose to graze on the 

hillsides around the camp. Stock generally graze within one mile of the camp; wet 

areas are traversed as stock move to and from the camp location. The original 

location of the Bald Mountain camp is located approximately 800 feet from the 

current location. It had been used by outfitter-guides and non-outfitted public for 

approximately 20 years prior to establishment of the new camp. The original 

location has since revegetated and there is no evidence of use.

The Beaver Creek Camp, in the Spanish Camp/Remmel Lake area, was established 

approximately 40 years ago by sheep herders and recreational pack stock users. It 

has a barren core area of approximately 6,747 square feet and 45 trees with 

exposed roots. It is located in the headwaters of Beaver Creek in a grove of trees 

with a wet meadow to the west. Stock loose graze up on the top of Airplane Ridge, a 

high and dry area with ample grass for feed. There are no constructed facilities. A 

highline is installed seasonally for stock containment. A small, plastic pipe is installed 

in a spring for drinking water. The pipe is removed at the end of the operating 

season.

The Sheep Mountain Camp was originally a sheepherder’s camp, but has been an 

outfitter camp for approximately 35 to 40 years. It has a barren core area of 

approximately 8,879 square feet, and 69 trees with exposed roots. There are tent 

pads and a corral that were constructed before the implementation of the Forest 

Plans. This camp has the largest area of vegetation loss and bare compacted soil in 

the Pasayten. There is approximately one acre next to the camp where historic 

grazing has altered the vegetative community and condition. Stock loose graze 

toward Sheep Mountain and Peeve Pass, generally within one mile of camp.

The Crow Lake Camp, located in the Sheep Mountain/Corral Lake area, has been 

used as a recreation campsite for decades, and has been used by a pack and saddle 

stock outfitter for approximately 10 years. It has a barren core area of 

approximately 9,610 square feet, and 33 trees with exposed roots. There are no 

constructed facilities, such as hitch rails, tent pads, or corrals, in the camp. A highline 

is installed seasonally for stock containment. It is located on a ridge approximately 

1/4 mile above Crow Lake. The stock loose graze north of the camp in a basin and 

along a ridge.

Whistler Camp was originally a sheep herders camp, used until sheep grazing was 

eliminated in the mid-1900s. It has also been used as a trail camp for pack and 

saddle stock users, both outfitted and non-outfitted, for nearly 50 years. It has a 

barren core area of approximately 3,254 square feet, and 53 trees with exposed 

roots. It is typically used by a pack and saddle stock outfitter between 2 to 7 times 

per year, with an average of 4 times. Stock are let loose to graze, mostly in an 

avalanche chute to the east of camp.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-52 February 2013

Okanogan-Wenatchee National Forest

The outfitters also use other camp locations for full service and drop camps. There are 

approximately 75 established camps. Refer to Appendix A for a table that lists the 

majority of the camps regularly used by the pack and saddle stock outfitter-guides, and 

Map 3.2-1 in the Map Section of this document shows their locations. The outfitters are 

not limited to camping only in these locations, but tend to return to these established 

spots year after year.

Lake Chelan-Sawtooth

There are no assigned sites in the Lake Chelan-Sawtooth Wilderness. The most frequently 

used camps include Mule Shoe, Twin Springs, and Chipmunk; all located on the Chelan 

Ranger District. Most trips originate in the Twisp River drainage, or from the Crater Creek 

Trailhead on the Methow Valley Ranger District. 

The outfitters also use other camp locations for full service and drop camps. There are 

approximately 78 established camps. The outfitters are limited to camping only in these 

locations in the portion of the wilderness on the Chelan Ranger District. On the Methow 

Valley Ranger District, the outfitters have not been limited to certain camps on the 

Methow Valley Ranger District, but tend to return to these established spots year after 

year.

Figure E-2 in Appendix A lists the majority of the camps used by outfitters. Map 3.2-2 in 

the Map Section of the document shows the locations.

Livestock Grazing and Confinement

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

stock containment and loose grazing, as described in section 3.1 Outfitter-Guides. Loose 

grazing can impact opportunities for solitude when people encounter grazing stock. The grazing 

areas tend to be away from most established campsites, however stock will occasionally move 

through an occupied campsite, especially if they are frightened and running away from danger. 

This happens rarely, but incidents have been reported to the Forest Service. The stock do not 

graze through occupied campsites because there is typically little graze in campsites. People do 

occasionally see stock grazing in meadows or on open hillsides, and hear the bells placed on one 

or two members of the herd. Rarely, people also encounter stock on main trails, and can feel 

intimidated if they are unfamiliar with stock behavior. In the past 10 years, only two such 

incidents have been reported.

There are ten drift gates in the Pasayten and Lake Chelan-Sawtooth Wildernesses. These gates 

are located where topography or terrain, in addition to the drift gate, helps prevent loose 

grazing stock from moving out of an area. The gates are constructed with native materials, and 

consist of parallel poles that can be slid out of the way to allow passage of hikers or stock. 

They detract from the opportunities for solitude in the wilderness since they are a constructed 

facility. They help protect the wilderness character by helping facilitate loose grazing. Having 

the gates is a precaution for the infrequent event that loose grazing stock leave their preferred 

grazing area and try to move down a trail or back to the trailhead.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-53 February 2013

Okanogan-Wenatchee National Forest

ENVIRONMENTAL CONSEQUENCES

Direct and Indirect Effects

There would be virtually no difference in the effect to wilderness character from one alternative 

to the next since the amount of use associated with the pack and saddle stock outfitter guides is 

such a small percentage of overall use. The following table compares the alternatives by 

alternative components.

Figure 3.2-11. Comparison of Alternative Components by Alternative

Wilderness Alternative 

Component

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Pasayten Number of 

Service Days***

0 2,000 1,000 2,170

Lake ChelanSawtoothNumber of 

Service Days***

0 720 320 825

Common to 

both 

wilderness 

areas

Amount of Barren 

Core Outfitters 

Can Use (Forest 

Plan 

Amendment*)

No 

amendment

5,250 square 

feet

2,800 square 

feet

Existing barren 

core at 

established 

campsites

Common to 

both 

wilderness 

areas

Party Size Limit 

for Outfitters**

(Forest Plan 

Amendment*)

No 

amendment

12 people and 

18 head of 

stock (no 

amendment) 

12 

(combination 

of people and 

stock)

12 people and 

18 head of 

stock (no 

amendment)

Common to 

both 

wilderness 

areas

Camping with 200 

feet of meadows, 

streams, lakes, 

and special 

interest areas 

(forest plan 

amendment; 

Okanogan only)

No 

amendment

Camping in 

established 

campsites 

within 200 feet 

of meadows, 

streams, lakes, 

and special 

interest areas 

allowed

Camping 

within 200 

feet of 

wetlands, 

streams, lakes, 

and special 

interest areas 

prohibited. 

Camping 

within 200 

feet of dry 

meadows 

allowed.

Camping in 

established 

campsites 

within 200 feet 

of meadows, 

streams, lakes 

,and special 

interest areas 

allowed

*Forest Plan amendment would only apply to pack and saddle stock outfitter-guides.

**Oversized parties may be approved if certain criteria are met. See mitigation measure 9a for criteria.

***This would be the total number of service days available. Some would be assigned to each outfitter, 

and the rest held in a pool. Refer to the alternative descriptions in Chapter 2 for more information.

The following sections consolidate information about recreation use and campsite condition 

associated with each alternate. The effects of these on wilderness character are described 

below for each alternative.

Recreation Use

Each alternative would have result in a slight change to the number of recreation users, which 

includes pack and saddle stock service days. Alternative 1 would reduce the number of people 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-54 February 2013

Okanogan-Wenatchee National Forest

visiting the Pasayten by 1,800, since pack and saddle stock outfitter guides would be eliminated. 

Alternatives 2 and 4 would slightly increase, and Alternative 3 would slightly decrease the 

overall number of people in the Pasayten. The following table includes the number of visitor 

days, outfitted and non-outfitted currently and by alternative, in the Pasayten. Non-oufitted 

days are included to provide context and intensity for the direct and indirect effects of the 

alternatives.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-55 February 2013

Okanogan-Wenatchee National Forest

Figure 3.2-12. Total Visitor Days and Outfitted Days in the Pasayten, Comparing Current to Alternatives

Current or Alternative Pack and Saddle Stock 

Users

Hikers Total

Current

Total Visitor Days 5,610 13,090 18,700

Pack and Saddle Stock OG Service 

Days

1,800 0 1,800

Percent of total 32% 0% 10%

Alternative 1

Total Visitor Days 3,810 13,090 16,900

Pack and Saddle Stock OG Service 

Days

0 0 0

Percent of total 0% 0% 0%

Percent Change From Current 

Total

-32% 0% -10%

Percent Change from Current 

Service Days

-100% 0%

Alternative 2

Total Visitor Days 5,810 13,090 18,900

Pack and Saddle Stock OG Service 

Days

2,000 0 2,000

Percent of total 34% 0% 11%

Percent Change From Current 

Total

+4% 0% +1%

Percent Change from Current 

Service Days

+11% 0%

Alternative 3

Total Visitor Days 4,810 13,090 17,900

Pack and Saddle Stock OG Service 

Days

1,000 0 1,000

Percent of total 21% 0% 6%

Percent Change From Current 

Total

-14% 0% -4%

Percent Change from Current 

Service Days

-44% 0%

Alternative 4

Total Visitor Days 5,996 13,090 19,070

Pack and Saddle Stock OG Service 

Days

2,170 0 2,170

Percent of total 36% 0% 12%

Percent Change From Current 

Total

+6% 0% +2%

Percent Change from Current 

Service Days

+20% 0%

The following figures display this information in graph form. The non-outfitted use is included 

to provide context and intensity of the effects of each alternative.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-56 February 2013

Okanogan-Wenatchee National Forest

Figure 3.2-13. Total Visitor Days in Pasayten, by Alternative

Figure 3.2-14. Total Number of Pack and Saddle Stock Days in Pasayten, by Alternative 

The following figure displays the approximate number of stock days in the Pasayten, by 

alternative. Refer to the Wilderness Report in the analysis file for the calculations. 

0

5000

10000

15000

20000

25000

Current Alt. 1 Alt. 2 Alt. 3 Alt. 4

Total Number of Visitor and Service Days

Non-Outfitted Visitor

Days

Pack and Saddle Stock

Outfitted Service Days

0

1000

2000

3000

4000

5000

6000

7000

Current Alt. 1 Alt. 2 Alt. 3 Alt. 4

Pack and Saddle Stock Days

Non-Outfitted Visitor

Days

Pack and Saddle Stock

Outfitted Service Days
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-57 February 2013

Okanogan-Wenatchee National Forest

Figure 3.2-15. Approximate Number of Stock Days in Outfitted and Non-outfitted Parties in Pasayten 

Annually, and Percent Change from Current

Non-Outfitted 

Stock Days

Outfitted Stock 

Days

Total Stock Days Percent Change 

From Current

Current 6,350 3,150 9,500

Alternative 1 6,350 0 6,350 -33%

Alternative 2 6,350 3,500 9,850 +4%

Alternative 3 6,350 1,750 8,100 -15%

Alternative 4 6,350 3,780 10,130 +7%

The following table includes the use information for the Lake Chelan-Sawtooth Wilderness.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-58 February 2013

Okanogan-Wenatchee National Forest

Figure 3.2-16. Total Visitor Days and Outfitted Days in the Lake Chelan-Sawtooth, Comparing Current to 

Alternatives

Current or Alternative Pack and Saddle Stock Users Hikers Total

Current

Total Visitor Days 12,810 23,790 36,600

Pack and Saddle Stock 

OG Service Days

715 0 715

Percent of total 6% 0% 2%

Alternative 1

Total Visitor Days 12,095 23,790 35,885

Pack and Saddle Stock 

OG Service Days

0 0 0

Percent of total 0% 0% 0%

Percent Change from 

Current Total

-6% 0% -2%

Percent Change from 

Current Service Days

-100%

Alternative 2

Total Visitor Days 12,815 23,790 36,605

Pack and Saddle Stock 

OG Service Days

720 0 720

Percent of total 6% 0% 2%

Percent Change from 

Current Total

0.0% 0% 0.0%

Percent Change from 

Current Service Days

0.7%

Alternative 3

Total Visitor Days 12,415 23,790 36,205

Pack and Saddle Stock 

OG Service Days

320 0 320

Percent of total 3% 0% 1%

Percent Change from 

Current Total

-3% 0% -1%

Percent Change from 

Current Service Days

-55%

Alternative 4

Total Visitor Days 12,920 23,790 36,710

Pack and Saddle Stock 

OG Service Days

825 0 825

Percent of total 6% 0% 2%

Percent Change from 

Current Total

+1% 0% +0.13%

Percent Change from 

current Service Days

+15%

The information for the Lake Chelan-Sawtooth is displayed in the following figures.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-59 February 2013

Okanogan-Wenatchee National Forest

Figure 3.2-17. Total Recreation Use in Lake Chelan-Sawtooth, by Alternative

Figure 3.2-18. Total Number of Pack and Saddle Stock Days in Lake Chelan-Sawtooth, by Alternative

The following figure shows the approximate number of stock days in the Lake Chelan-Sawtoth, 

by alternative. Refer to the Wilderness Report in the analysis file for the calculations. 

Current Alt. 1 Alt. 2 Alt. 3 Alt. 4

0

5000

10000

15000

20000

25000

30000

35000

40000

Total Visitor and Service Days

Non-Outfitted Visitor

Days

Pack and Saddle Stock

Outfitted Service Days

0

2000

4000

6000

8000

10000

12000

14000

Current Alt. 1 Alt. 2 Alt. 3 Alt. 4

Pack and Saddle Stock Days

Non-Outfitted Visitor

Days

Pack and Saddle Stock

Outfitted Service Days
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-60 February 2013

Okanogan-Wenatchee National Forest

Figure 3.2-19. Approximate Number of Stock Days in Outfitted and Non-outfitted Parties in Lake 

Chelan-Sawtooth, Annually, and Percent Change from Current

Non-Outfitted 

Stock Days

Outfitted Stock 

Days

Total Stock Days Percent Change 

From Current

Current 20,162 1,260 21,422

Alternative 1 20,162 0 20,162 -6%

Alternative 2 20,162 1,260 21,422 0%

Alternative 3 20,162 560 20,722 -3%

Alternative 4 20,162 1,470 21,632 +1%

Campsite Size and Condition

The size of the largest existing outfitter-guide campsites would likely change slightly under each 

alternative. Pack and saddle stock outfitter guides would be eliminated under Alternative 1, so 

there would be no effects to these camps from outfitter-guide use. 

None of the alternatives would allow outfitter-guides to create new campsites, so the current 

conditions pertaining to campsite inter-visibility and audibility, and distance between campsites 

would not change.

Alternative 2 would limit outfitters to not increasing the amount of barren core, and using no 

more than 5,250 square feet in larger camps. This alternative would allow exclusive use of the 

five existing assigned for exclusive use by outfitters (Bald Mountain, Beaver Camp, Sheep 

Mountain, Crow Lake, and Whistler Camp). Restricting non-outfitter use in assigned sites may 

help to accelerate the recovery of the portion of barren core off-limits to outfitters. 

Alternative 3 would set the barren core limit at 2,800 square feet, keep three existing assigned 

sites (Sheep Mountain, Crow Lake, and Whistler Camp) and prohibit outfitters from using the 

Bald Mountain and Beaver Creek because of their proximity to wetlands. 

Alternative 4 would allow the outfitters to use existing barren core at established campsites, but 

not increase the amount. Camp management plans would be developed for all five assigned 

sites, and for all campsites with over 5,250 square feet of barren core. 

The following table shows each of the campsites with over 2,800 square feet of barren core in 

the Pasayten and Lake Chelan-Sawtooth that are used by the pack and saddle stock outfitter 

guides, the existing amount of barren core, the amount that could be used by the outfitters, and 

which sites would be closed to public use (assigned sites). A narrative description of each 

assigned site is included in the alternative descriptions below. A list of the consistently used 

campsites in included in Appendix A. Outfitter-guides would be allowed (with approval) to use 

any established campsite large enough to accommodate the size of their party.

The amount of barren core in any campsite with less than 2,800 square feet existing would not 

change as a result of pack and saddle stock outfitter-guide use under any alternative. Refer to 

Appendix A for a list of all campsites. 
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Figure 3.2-20. Existing Amount of Barren Core in Established Camps Exceeding 2,800 and Amount That Could Be Used by Outfitters in Each 

Alternative.

Camp

Name

Existing 

square 

feet of 

Barren 

Core

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Amount of 

Barren Core 

Outfitters 

Could use

Assigned 

outfitter 

camp?

Amount of 

Barren Core 

Outfitters 

Could use

Assigned 

outfitter 

camp?

Amount of 

Barren Core 

Outfitters 

Could use

Assigned 

outfitter 

camp?

Amount of 

Barren Core 

Outfitters 

Could use

Assigned 

outfitter 

camp?

3 Fools* 2,800 n/a n 2,800 n No OG Use n 2,800 n

Bald Mountain * 3,900 n/a n 3,900 y No OG Use n/a 3,900 y

Beaver Creek* 6,747 n/a n 5,250 y No OG Use n/a 6,747 y

Chewuch 3,000 n/a n 3,000 n No OG Use n/a 3,000 n

Corral Lake 3,500 n/a n 3,500 n 2,800 n 3,500 n

Cougar Lake* 2,916 n/a n 2,916 n 2,800 n 2,916 N

Crow Lake* 9,610 n/a n 5,250 y 2,800 y 9,610 Y

Crow Lake 2* 7,000 n/a n 5,250 n 2,800 n 7,000 n

Fred’s Lake* 5,400 n/a n 5,250 n No OG Use n/a 5,400 n

Goat Lakes Basin 

2*

3,000 n/a n 3,000 n 2,800 n 3,000 n

Peeve Meadow* 5,640 n/a n 5,250 n No OG Use n/a 5,640 n

Sheep 

Mountain*

8,879 n/a n 5,250 y 2,800 y 8,879 y

Whistler Basin 4,020 n/a 4,020 n No OG Use n 4,020

Whistler* 3,254 n/a n 4,020 y 2,800 y 4,020 y

TOTAL* 69,666 68,656 19,600 69,666

Bike West** 2,900 n/a n 2,900 n 2,800 n 2,900 n

Twin Springs 1** 3,071 n/a n 3,071 n 2,800 n 3,071 N

Mule Shoe 2** 3,000 n/a n 3,000 n 2,800 n 3,000 n

Mule Shoe 

North**

4,200 n/a n 4,200 n 2,800 n 4,200 n

Silver Lake** 4,540 n/a n 4,540 n No OG Use n/a 4,540 n

Surprise Lake** 3,500 n/a n 3,500 n No OG Use n/a 3,500 n

TOTAL 21,211 21,211 11,200 21,211

*Pasayten Wilderness

**Lake Chelan-Sawtooth Wilderness
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Alternative 1

There would be no pack and saddle stock outfitter-guides under Alternative 1, therefore there 

would be no effects to wilderness character from outfitter-guide activities. However this 

alternative would result in a slight improvement in wilderness character, specifically in the 

natural quality and opportunities for solitude. It would not provide the commercial services 

necessary for wilderness appropriate recreation. The elimination of pack and saddle stock 

outfitter guides would reduce impacts from grazing, and slightly improve water quality, and 

slightly reduce streambank erosion and soil impacts at stock watering and gathering locations. 

There would be localized improvements in the opportunities for solitude at some established 

campsites because the reduction in the sights and sounds of people would make the areas feel 

more remote. Opportunities for solitude or primitive and unconfined recreation would also 

improve since the number of pack and saddle stock users in each wilderness would be reduced. 

People needing the services of pack and saddle stock outfitter guides would not be able to travel 

into the wilderness and benefit from the opportunities for solitude, or primitive and unconfined 

recreation.

Untrammeled and Undeveloped Qualities

Alternative 1 would have no effect on the untrammeled or undeveloped qualities of the 

Pasayten or Lake Chelan-Sawtooth wildernesses. As discussed in the Affected Environment 

section above, these qualities are influenced by intentional manipulation of wilderness 

ecosystems, or use of motorized or mechanical equipment or transportation methods. These 

qualities are discussed in the cumulative effects section below, since other past, present, and 

reasonably foreseeable future actions have affected these qualities.

Natural Quality

The reduction (32% in the Pasayten and 6% in the Lake Chelan-Sawtooth) in the number of 

people and pack and saddle stock with this alternative may have minor, localized beneficial 

impacts to the natural quality of the Pasayten and Lake Chelan-Sawtooth wildernesses. 

Fewer stock would graze in wetlands and potentially cause stream bank erosion at watering 

sites and trail crossings. More detail is included in the Botany, Water, and Aquatic resource 

sections of this chapter.

Opportunities for Solitude or Primitive and Unconfined Recreation

Use Levels and Encounters

This alternative would result in a reduction in the number of pack and saddle stock users in 

the Pasayten and Lake Chelan-Sawtooth wildernesses. The reduction in use (32% in the 

Pasayten and 6% in the Lake Chelan-Sawtooth) could improve this wilderness quality for 

some. The number of encounters on trails would be reduced, and would be most noticeable 

in the portions of the wildernesses more frequently used by the pack and saddle stock 

outfitters. This could have a beneficial effect on the opportunity for solitude in the Spanish 

Creek/Remmel Lake and Larch Pass/Sheep Mountain areas.
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Campsite Size and Condition

Non-outfitted pack and saddle stock users would continue to use the existing campsites 

discussed in the Affected Environment section and listed in Figures A-1 and A-2. The use 

would be less frequent and for shorter durations. This, coupled with potentially smaller 

average party sizes (because private parties tend to be smaller than outfitter-guide parties), 

could increase the rate of recovery, and give the most beneficial improvement to the 

opportunities for solitude or primitive and unconfined recreation and natural character of 

both wildernesses compared to Alternatives 2, 3, and 4. The camps with a barren core larger 

than the standard and guideline would continue to be out of compliance with the standard, 

however the overall frequency of use, especially of those favored by outfitters, may 

decrease, potentially accelerating the rate of recovery. Full recovery of these areas could 

take decades of non-use for vegetation to regrow, and for trees with exposed roots to die, 

and fall down. The actual rate of measurable changes in the size of barren core cannot be 

estimated, since all sites would continue to be used to some extent, and revegetation would 

depend on frequency and duration of use, and camping practices of non-outfitted users. 

Pasayten

The most popular portions of the Pasayten, including Spanish Camp/Remmel Lake and 

Larch Pass to Sheep Mountain would still be frequented by non-outfitted pack and 

saddle stock users. The Pasayten Airport would still receive some non-outfitted stock 

use, but the limited amount of forage, and lack of any destination lakes would generally 

continue to result in light use. The Pasayten River drainage would also receive some 

stock use, especially at Whistler Camp along the Middle Fork Pasayten. Use here would 

be much lighter than in Spanish Camp/Remmel Lake, or Sheep Mountain/Corral Lake 

because forage is somewhat limited. Stock use at Hidden Lakes would be light due to 

lack of forage. Tatoosh Buttes has ample forage but stock use would continue to be 

limited because the trail is difficult, and water supply is limited.

The effects of Alternative 1 on the expected future conditions of the existing assigned 

sites are described below. There would be no effects to the approximate 2.7 acres of 

existing barren core from pack and saddle stock outfitter-guides at these campsites, but 

the sites would still be used by non-outfitted parties. 

Outfitter Camps

The Bald Mountain Camp would likely receive little use because it is off the main 

trail. People would have to pass several established campsites before reaching Bald 

Mountain. They would likely stay at the campsites normally used by the public now. 

The site would have a higher potential for recovery since the number of people and 

the stock at the campsite over a season would be reduced.

The Sheep Mountain Camp is also located off the main trail, and approximately 20 

miles from the trailhead. This would be a longer ride than most people make in a 

day. The site would have a higher potential for recovery since the number of people 

and the stock at the campsite over a season would be reduced.

The Crow Lake Camp was used by the public prior to the outfitter establishing a 

camp there, so it may be used more frequently than Bald Mountain and Sheep 
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Mountain. Since the average party size would likely be smaller, this camp would not 

likely increase in size. Future use would likely be confined to the existing area.

The Beaver Creek Camp is located off the main trail, and the average visitor would 

not find the location. The site would have a higher potential for recovery since the 

number of people and the stock at the campsite over a season would be reduced.

Whistler Camp would still receive pack and saddle stock use since it is located near 

the main trail, in an area where grazing is limited. The average party size and 

duration of use would be less than the current use, as with the other campsites. This 

camp would not likely increase in size, and future use would likely be confined to the 

existing area.

Lake Chelan-Sawtooth

As in the Pasayten, people would continue to use the 1.1 acres of barren core in existing 

campsites however there may be a reduction in the number of campsites and the 

frequency of use. The most popular campsites, including those currently used by 

outfitters, would still be used by people with pack and saddle stock.

Stock Containment and Loose Grazing

Impacts within stock containment areas in campsites currently used by outfitter-guides could 

potentially reduce in size, since the average non-outfitted group has fewer stock than 

outfitted groups. This would have a beneficial effect on opportunities for solitude because of 

the improvement in camp conditions, especially in the amount of barren core.

There would be no loose grazing outfitted stock, however non-outfitted stock users may still 

use this technique since it minimizes impacts, and is the suggested method in Leave-NoTrace principles. There would be a reduction in the number of animals grazing, however, so 

encounters with stock away from camps or on trails, stock traveling though occupied 

campsites, and the sound of bells on loose grazing herds would all be reduced. This would 

have a beneficial impact on opportunities for solitude.

Meeting the Need for Commercial Services

This alternative would not provide the commercial pack and saddle stock services needed for

wilderness recreation. People who require the services of an outfitter-guide would not be 

able to travel into the wilderness, and would not have access to this historic type of 

wilderness recreation, or be able to enjoy the opportunities for solitude or primitive and 

unconfined recreation offered there.

Effects Common to Alternatives 2, 3, and 4

Untrammeled and Undeveloped Qualities

Alternatives 2, 3, or 4 would have no effect on the untrammeled or undeveloped qualities of the 

Pasayten or Lake Chelan-Sawtooth wildernesses. As discussed in the Affected Environment 

section above, these qualities are influenced by intentional manipulation of wilderness 

ecosystems, or use of motorized or mechanical equipment or transportation methods. These 
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qualities are discussed in the cumulative effects section below, since other past, present, and 

reasonably foreseeable future actions have affected these qualities.

Natural Quality

The mitigation measures listed in Chapter 2 would reduce impacts to the natural quality of 

wilderness character as follows: These would all be effective in reducing impacts since they 

would be part of the terms and conditions of the special use permits, and therefore required of 

the pack and saddle stock outfitter guides.

Stock Grazing and Containment

8a. Using loose grazing as the preferred method for stock would reduce impacts caused by 

stock contained for long periods of time on high lines, hitch rails, in corrals, or tied to trees 

by dispersing the impacts. Restrictions on loose grazing would minimize potential damage 

to vegetation and soil when conditions are too wet, or when grazing has been heavy.

8b. Designating and approving the location of overnight stock handling facilities would 

avoid impacts from these facilities placed too near streams, lakes, wetlands, and other 

sensitive resources.

8c. Requiring supplemental feed under certain conditions would reduce the potential for 

damaging from grazing stock to vegetation and soil when an area is too wet, has been 

overgrazed, or there are other resource concerns.

8d. Prohibiting overnight picketing of stock in subalpine meadows would minimize soil 

disturbance and damage to vegetation in meadows.

8e. Designating suitable grazing areas during times of high use would minimize potential 

damage to vegetation and impacts to plant communities from overgrazing.

8g. Requiring outfitter-guides to pack in and supply all necessary feed when range 

conditions do not allow grazing of pack stock eliminate potential damage to resources by 

not allowing stock to graze.

Vegetation and Soils

10a. Prohibiting the cutting or removal of green trees and other live vegetation (other than 

for approved maintenance on system trails), and minimizing trampling or other damage to 

vegetation beyond what is likely to recover in one growing season would reduce potential 

impacts to live vegetation.

10b. Replacing or smoothing out soils displaced by activities such as latrine construction or 

pawing by stock to the extent practical would reduce soil damage within campsites.
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10c. Identifying travel routes to minimize impacts to wet soil and meadow areas would help 

reduce damage to areas of wet soil and meadows caused by stock creating or increasing 

braded trails through wetlands.

Invasive Species

13a. Outfitters removing any plant material attached to vehicles, shoes, clothing, or the 

bodies of pack and saddle stock would prevent the spread and introduction of invasive 

species. 

13b. Using supplemental feed that is commercially processed, weed-free certified 

processed hay cubes and certified weed-free hay (36 CFR 261.58(t) would prevent the 

spread and introduction of invasive species. 

13c. Feeding commercially-processed feed or hay that is certified weed-free for several 

days prior to trip departure would reduce the risk of spreading invasive species. .

13d. Outfitters following a weed identification and mapping program under Forest Service 

direction would help target noxious weed populations for control or eradication.

13e. Outfitters surveying campsites for weeds, and assisting in control measures as directed 

by the Forest Service would help target noxious weed populations for control or 

eradication.

Opportunities for Solitude or Primitive and Unconfined Recreation

The following mitigation measures would reduce impacts to the opportunities for solitude or 

primitive and unconfined recreation. These would all be effective in reducing impacts since they 

would be part of the terms and conditions of the special use permits, and therefore required of 

the pack and saddle stock outfitter guides.

Campsites

1a. Approving all camp locations prior to use, and using only established campsites large 

enough to accommodate the party size when faced with an emergency or occupied 

campsite would help reduce impacts to opportunities for solitude by avoiding too many 

outfitters in one area, creating new campsites, or increasing the size of existing campsites.

1b. Camp Management Plans would reduce potential impacts to opportunities for solitude 

by managing large campsites to ensure they do not increase in size, and to prevent cashing 

of supplies or equipment. Limiting new facilities in assigned sites to those needed for 

resource protection, and not soling for comfort and convenience would keep the campsites 

as undeveloped as possible, and protect opportunities for solitude by reducing the visual 

impact of campsites.

1c. Limiting the amount of barren core the outfitters could use to 5,250 square feet 

(Alternative 2) or 2,800 square feet (Alternative 3), or to the existing amount (Alternative 
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4), and developing camp management plans for all sites with more than 5,250 square feet 

(Alternatives 2 and 4) or 2,800 (Alternative 3) would reduce potential impacts to 

opportunities for solitude by managing large campsites to ensure they do not increase in 

size.

1d. In Alternative 4, allowing outfitter-guides to use existing barren core in established 

campsites would keep the condition and size of the campsites on a stable trend.

1e. Requiring the outfitters to use existing barren core, and not create new of additional 

barren core or bare mineral soil would minimize impacts to opportunities for solitude by 

keeping barren core as small as possible. The impact of the campsites on the feeling of 

remoteness would not increase. Temporary increases as a result of camp restructuring or 

restoration, with no net increase in the amount of barren core, would ensure nondegradation of the wilderness, while allowing alternations to be made in campsites to 

address resource concerns. It also recognizes that the amount of barren core in any given 

campsite would vary from year to year, based on weather, non-outfitted use patterns, and 

vegetation growth.

1f. Prohibiting outfitters from exposing roots on any trees would reduce potential impacts 

to opportunities for solitude by not allowing increase in the impacted area around trees in 

campsites.

1g. Prohibiting outfitters from creating new campsites would prevent degradation of the 

wilderness, or potential impacts to opportunities for solitude from an increase in campsite 

density.

Campsite Use Limitations

2a. Limiting outfitted pack and saddle stock use at Hidden Lakes, Spanish Camp/Remmel 

Lake, Corral Lake/Crow Lake would reduce potential impacts to opportunities for solitude in 

these popular destination spots by limiting the number of outfitted stock parties.

2b, c, d, e, & g. Limiting pack and saddle stock use to drop camps only at Silver Lake, 

Buckskin Lake, Ferguson Lake, Fred Lake, Doris Lake, Black Lake, Oval Lakes, North Lake, 

Louis Lake, Star Lake, Tuckaway Lake, Bernice Lake, and Surprise Lake would reduce 

potential impacts to opportunities for solitude in these popular destinations spots by 

limiting the number of outfitted stock parties. This would reduce crowding, and decrease 

the chance that campsites would not be available for non-outfitted parties, and avoid 

potential impact from stock. .

2f. Prohibiting pack and saddle stock outfitter-guide camping at Twisp Pass or Libby Lake 

would prevent any impacts to opportunities for solitude, or impacts from outfitted stock. 

2h. Requiring that all non-assigned sites be available on a “first-come, first-served” basis, 

and removing all equipment and materials at the end of each trip would reduce potential 

impacts to opportunities for solitude or primitive and unconfined recreation by allowing 

any party to make camp in any unoccupied campsite (exclusive of assigned sites), and not 
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allowing outfitters to leave camps set up between trips, therefore making the site 

unavailable to non-outfitted parties when the site is unoccupied.

2i. Requiring stock to be tied on high lines and fed from nose or feed bags in campsites 

within the Chelan Ranger District portion of the Lake Chelan-Sawtooth Wilderness would 

reduce impacts to the opportunities for solitude by avoiding encounters with loose stock 

and avoid littering stock containment areas with feed. 

Campfires and Firewood

3 c. Prohibiting the cutting of standing trees, including snags would avoid potential impacts 

to opportunities for solitude from stumps or damaged trees around campsites decreasing 

the feeling of remoteness.

3d.Allowing firewood to only be stored at assigned sites, and requiring it to be uncovered 

and out of sight of any Forest Service system trail, and prohibiting skidding of firewood with 

stock would reduce potential impacts to opportunities for solitude by reducing the visual 

impact of assigned sites.

Regulations

4a. Requiring outfitters and their clients to comply with all applicable rules and regulations 

would ensure compliance with some specific forest plan standards and guidelines that 

minimize impacts to wilderness character. Refer to Appendix D for a list of regulations. 

4b. Requiring outfitters to review regulations with clients would ensure they understand 

the rules and increase compliance with the rules, minimize impacts to wilderness character. 

Refer to Appendix D for a list of regulations. 

Leave-no-trace

5a. Requiring the outfitters to follow Leave-No-Trace principles would reduce potential 

impacts to opportunities for solitude or primitive and unconfined recreation by reducing 

the sights and sounds of outfitter-guide parties as they travel on trails, camp, and allow 

stock to graze. It would also reduce residual impacts to campsites, leaving areas in a more 

natural-looking condition.

5b. Requiring the outfitters to review leave-no trace practices with clients, including those 

at drop camps would reduce potential impacts to opportunities for solitude or primitive 

and unconfined recreation by reducing the sights and sounds of outfitter-guide parties as 

they travel on trails, camp, and allow stock to graze. It would also reduce residual impacts 

to campsites, leaving areas in a more natural-looking condition 

Trails

6a. Limiting outfitters to existing trails wit well-established tread, and prohibit constructing, 

placing, or maintaining any kind of trail without authorization would reduce potential 
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impacts to opportunities for solitude by preventing outfitters from increasing trail density 

and unauthorized trail construction.

6b. Restricting trail maintenance to Forest Service system trails and access trails to 

established camps would reduce potential impacts to opportunities for solitude by 

preventing outfitters from increasing trail density and unauthorized trail construction.

Sanitation and Litter

7a. Requiring proper management of human waste would reduce potential impacts to 

opportunities for solitude by improving campsite conditions. 

7b. Requiring heavy concentrations of stock manure near campsites or in other areas 

where stock have been tied or held to be scattered away from open water would reduce 

potential impacts to opportunities for solitude by improving campsite conditions and 

protect water quality

7c & d. Requiring proper disposal of hunting refuse and dead stock to be disposed of away 

from campsites, trails, and sources of water would reduce potential impacts to 

opportunities for solitude by improving campsite and trailside conditions, and protect 

water quality.

Party Size

9 a & c. Limiting party size, only allowing oversized parties that meet the limitations in the 

forest plan standards and guidelines, and not allowing cripples, colts, or unbroken stock on 

trips would reduce potential impacts to opportunities for solitude by reducing encounters 

with outfitted stock parties on trails, decreasing impacts from grazing stock, and reducing 

impacts to campsite conditions.

Alternative 2

Alternative 2 would be essentially the same as the existing use, so the current effects to 

wilderness character described under the Affected Environment section would continue. There 

would be a minor beneficial impact to opportunities for solitude compared to the existing 

condition, however. The Forest Plan amendments allowing outfitters to use existing campsites 

and restricting outfitters to use the same 5,250 square foot area of barren core in camps 

exceeding that size, along with the mitigation measures prohibiting outfitters from creating new 

camps, or increasing the size of existing camps, would have a minor beneficial impact to 

opportunities for solitude. Opportunities for primitive and unconfined recreation would be 

maintained for those needing the services of an outfitter-guide, but would continue the current 

minor, localized adverse impacts on solitude by maintaining the current number of outfitterguide pack and saddle stock use and activities such as campsite location and grazing in the 

wilderness. This alternative would provide enough commercial services to meet the low end of 

the range of minimum extent necessary. Refer to the Needs Assessment in Appendix B for a 

discussion of the minimum extent necessary. 
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Natural Quality

There would be no changes in the natural quality in the Pasayten and Lake Chelan-Sawtooth 

wilderness areas since there would be virtually no change in the number of people and pack 

and saddle stock compared to current numbers (refer to Figure 3.10-8 and Figure 3.10-12). 

There would be no increase in grazing pressure on plant communities, or increase in the risk 

of introduction and spread of invasive species. This level of grazing would not alter plant 

communities, or increase impacts to sensitive or rare plant species. There would continue to 

be isolated spots of damage to stream banks, but not at a level that would degrade aquatic 

habitat or water quality. 

More details are included in the Botany, Water, Aquatic, Range, and Invasive Species reports.

Opportunities for Solitude or Primitive and Unconfined Recreation

Use Levels and Encounters

There would be virtually no change in the number of people using pack and saddle stock with 

this alternative (4% in the Pasayten and 0.7% in the Lake Chelan-Sawtooth) compared to the 

existing condition, so for other users, the opportunities for solitude would not change from 

the existing condition. People would continue to encounter people with stock, especially in 

those areas frequented by pack and saddle stock outfitter-guides. Campsite occupancy 

would remain unchanged from the current condition. 

Campsite Size and Condition

The outfitter guide activities would continue to reduce opportunities for solitude in the 

localized areas near campsites because the sights and sounds of their camps and activities 

would decrease the feeling of remoteness. The level of impact would be the same as the 

existing condition, but more than Alternative 1.

Outfitters would be restricted to only using identified, established campsites, and not 

increasing the amount of barren core at any established site. They would not be permitted 

to create new travel routes, or expose roots on trees. 

The forest plan amendment restricting the amount of barren core the outfitters could use 

would result in a slight improvement in the opportunities for solitude compared to the 

existing condition. In campsites where the barren core exceeds 5,250 square feet, the 

outfitters would not be permitted to use in excess of 5,250 square feet of the barren core 

area, and would reuse the same portion each time. 

The current assigned sites, Bald Mountain, Sheep Mountain, Beaver Creek, Crow Lake, and 

Whistler, would continue as assigned. These campsites would be closed to the public; use 

would be closely monitored and controlled to accelerate their recovery. The other existing 

campsites listed in Figures E-1 and E-2 would also be used by the outfitters, but would also 

be open to the public. 

There could be improvements at campsites with barren cores exceeding 5,250 square feet 

as the unused portions begin to revegetate, although recovery would be more effective at 

assigned sites as opposed to non-assigned sites because the public could continue to use the 
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entire area. The revegetation at some camps would be slow because of the short, harsh 

growing season, and the possibility that non-outfitted users would continue to use the area. 

Other sites would recover more quickly based on the amount of non-outfitted use they 

receive and site conditions. 

The amendment allowing outfitter-guides to use existing campsites within 200 feet of 

meadows, streams, lakes, and special interest areas would continue the current impacts to 

opportunities for solitude since the existing campsites would be used. 

Pasayten

Pack and saddle stock outfitter-guides would continue to use the existing campsites in 

the Pasayten. Most of their activity would be in the Spanish Camp/Remmel Lake area 

(Bald Mountain and Beaver Creek assigned sites), Sheep Mountain/Corral Lake area 

(Sheep Mountain and Corral Lake assigned sites), Middle Fork of the Pasayten (Whistler 

Camp assigned site), and in the Tatoosh Buttes/Hiddlen Lakes area. 

The effects of Alternative 2 on the conditions of the assigned sites currently used by 

outfitters are described below. A complete list of camps used by the outfitters, 

including barren core and number of damaged trees, is in Appendix A. 

The current conditions at non-assigned sites would not change with implementation of 

this alternative since they would continue to be used by both the outfitter-guides and 

the public. Camp management plans would be made for Crow Lake 2 (currently with 

7,000 square feet of barren core), Fred’s Lake (with 5,400 square feet of barren core), 

and Peeve Meadow (with 5,640 square feet of barren core). The camp management 

plans would identify the 5,250 square feet of barren core the outfitters could use on 

visit. The amount of barren core would not be expected to decrease, however, due to 

the non-outfitted use.

The Bald Mountain Camp would continue to have a barren core of 

approximately 3,900 square feet. A camp management plan would be 

developed and followed to prevent creating additional barren core, exposing 

more roots on trees, and creating additional travel routes. The camp would be 

closed to public use, so further degradation should not occur.

The Sheep Mountain Camp has an existing barren core of 8,879 square feet. A 

camp management plan would be developed and followed, identifying 5,250 

square feet of barren core area the outfitters can use which would prevent 

creating additional barren core, exposing more tree roots, and creating 

additional travel routes. The entire camp would be closed to the public, so the 

remaining unused 3,625 square feet of barren core would begin to recover. 

The Crow Lake Camp, located in the Sheep Mountain/Corral Lake area, has an 

existing barren core of 9,610 square feet. As with the other assigned sites, a 

camp management plan would be developed, identifying 5,250 square feet of 

barren core the outfitters can use. This would prevent creating additional 

barren core, exposing more tree roots, and creating additional travel routes. 
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The entire camp would be closed to the public, so the remaining unused 4,360 

square feet of barren core would begin to recover. 

The Beaver Creek Camp has an existing barren core of 6,747 square feet. A 

camp management plan would be developed and followed, identifying 5,250 

square feet of barren core area the outfitter-guide can use which would prevent 

creating additional barren core, exposing more roots on trees, or creating travel 

routes. The entire camp would be closed to the public, so the additional 1,497 

square feet of barren core would begin to recover. 

Whistler Camp has an existing barren core of 3,254 square feet. The camp size 

and condition would not change with this alternative because outfitter-guides 

would be prohibited from creating additional barren core, exposing more tree 

roots, or creating additional travel routes by outfitter-guides. 

Lake Chelan-Sawtooth

The pack and saddle stock outfitter-guides would continue to operate in the Lake 

Chelan-Sawtooth Wilderness. Most of their trips would be to Williams Lake, Oval 

Lakes, Baldy Mountain area, and Wolf Creek. There are no outfitter-guide campsites 

with over 5,250 square feet of barren core in the Lake Chelan-Sawtooth Wilderness. 

The amount of barren core at these campsites would not change with implementation 

of Alternative 2. 

Under Alternative 2, a total of 9,482 square feet (two-tenths of an acre) of barren core in 

the Pasayten Wilderness would no longer be affected by any use because this area would 

be closed to use by both outfitter-guides and the general public (assigned sites). The 

amount of time recovery of these areas would take would depend on the microclimate of 

each campsite. In addition, 1,528 square feet of undesignated barren core in the Pasayten 

would no longer be affected by outfitter-guides, but impacts from the general public would 

still continue because the undesignated barren core would not be closed to the general 

public (see cumulative effects). This totals 11,010 square feet, or approximate three-tenths 

of an acre scattered across the Pasayten, that would no longer be impacted by pack and 

saddle stock outfitter-guides. Approximately 105,571 square feet of barren core, or 2.4 

acres would continue to be used by the pack and saddle stock outfitter-guides. There are 

no outfitter camps in the Lake Chelan-Sawtooth with more than 5,250 square feet, so the 

amount of barren core used by the outfitters in this wilderness would not change from the 

existing condition; 48,534 square feet, or 1.1 acres. 

Figures A-1 and A-2 in Appendix A list the camps consistently used by the outfitters, 

including the amount of barren core and number of damaged trees. These camps would 

continue to be used for full-service and drop camps. The mitigation measures included in 

the alternative would be effective at regulating outfitter-guide activities to meet the 

amended standards and guidelines. 

Stock Confinement and Loose Grazing

Loose grazing would be the preferred method for caring for stock in the wilderness areas 

(see Mitigation Measure 8a, page 2-15). This would limit the amount of time stock are 

confined in camp, thus reducing the size of and amount of disturbance in confinement area. 
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Okanogan-Wenatchee National Forest

More confinement can generally be equated to more impact because it concentrates impact 

and contributes to restless behavior (Leave No Trace, 2001).

People would continue to encounter or hear grazing stock, so impacts to opportunities for 

solitude from stock would continue. People may see stock in meadows, on trails, or near 

campsites, and may hear the bells used to help locate the herds. These encounters would 

likely be infrequent, based on the very limited reports of such encounters over the past 

decade. The 4% increase in service days compared to the existing condition would likely not 

cause a noticeable increase in these encounters. 

Meeting the Need for Commercial Services

This alternative would provide enough commercial services to meet the low end of the range 

of minimum extent necessary. If the need increases due to the aging population, the 

alternative would fall short of meeting the need (upper end of the minimum extent 

necessary range Pack and saddle stock wilderness recreation would be accessible to the 

portion of the population needing the services due to physical limitations, or lack of skill and 

equipment. Those needing the services of an outfitter would be able to travel into the 

wilderness and enjoy the opportunities for primitive and unconfined recreation.

Alternative 3

Alternative 3 would have a minor improvement in wilderness quality compared to the existing 

condition, but not as much of an improvement as Alternative 1. One forest plan amendment 

would prohibit outfitters from using existing campsites within 200 feet of wetlands, streams, 

lakes, and special interest area while allowing use of existing camps within 200 feet of 

meadows. Another amendment would require that they use the same 2,800 square foot area of 

barren core in camps exceeding that size. A third amendment would reduce the pack and 

saddle stock outfitter-guide party size to 12 heartbeats (people and stock). The mitigation 

measures would prohibit outfitters from creating new camps, or increasing the size of existing 

camps. All these components would have an increase the opportunities for solitude and natural 

qualities of the wilderness compared to the existing condition. The alternative would not meet 

the low end of the range of the minimum extent necessary, so opportunities for primitive and 

unconfined recreation would be reduced from current levels for people requiring the services of 

an outfitter-guide.

Natural Quality

The natural quality of the Pasayten and Lake Chelan-Sawtooth wilderness areas would be 

improved from the existing condition with this alternative. There would be a 14% decrease 

in the number of people using pack and saddle stock in the Pasayten, and 3% decrease in the 

Lake Chelan-Sawtooth, but these small decreases would not be enough to change current 

conditions. 

The forest plan amendment prohibiting the outfitter-guides from using camps within 200 

feet of wetlands, streams, lakes, and special interest areas while allowing use of camps 

within 200 feet of dry meadows would reduce the likelihood of outfitter-guide impacts to 

wetlands, lakes, and streams. Loose grazing stock could still access wetlands, streams, and 

lakes, but the heaviest impact would occur in close proximity to campsites, so prohibiting 
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outfitter-guide use of these campsites would reduce impacts. Approximately 42 campsites 

would be closed to outfitters, including the currently assigned Bald Mountain and Beaver 

Creek Camps. The current impacts to vegetation, soil, water quality, and aquatic habitat 

from outfitter-guide activities in the 42 campsites would cease, although non-outfitted use at 

these cites would likely continue. 

This reduced amount of stock grazing would reduce impacts to plant communities, and 

sensitive or rare plants compared to the existing condition, but not as much as the effects of 

Alternative 1. There would continue to be isolated spots of damage to stream banks, but not 

at a level that would degrade aquatic habitat or water quality. Invasive species may be 

introduced and spread by pack and saddle stock, but the mitigation measures requiring 

cleaning equipment prior to wilderness entry and for certified weed-free feed would reduce 

the risk. 

More detail is included in the Botany, Water, Aquatic, Range, and Invasive Species resource 

sections of this chapter.

Opportunities for Solitude or Primitive and Unconfined Recreation

Use Levels and Encounters

The number of people using pack and saddle stock would be reduced from the existing 

condition with this alternative (14% in the Pasayten, and 3% in the Lake ChelanSawtooth). The reduction in the Lake Chelan-Sawtooth would likely go unnoticed in 

terms of encounters and campsite occupancy, but people in the Pasayten may notice a 

slight decrease in encounters on the trails and campsite occupancy. 

The forest plan amendment reducing the party size for pack and saddle outfitter guide 

groups could have a beneficial impact to the opportunities for solitude compared to the 

existing condition. No outfitted group would exceed a total of 12 people and stock, with 

the exception of the occasional authorized oversized party. This would substantially 

reduce the encounters with large pack strings on trails, and result in fewer pack stock in 

and around camps. This benefit may be reduced or eliminated if the outfitters make 

multiple trips to and from camps in order to provide the service clients expect while not 

exceeding the smaller party size, which could increase the number of encounters 

between outfitted and non-outfitted groups on trails.

Campsite Size and Condition

The pack and saddle stock outfitter-guides would be prohibited from using approximately 

46 existing campsites due to their proximity to wetlands, streams, lakes, or special 

interest areas (within 200 feet), including the assigned sites at Bald Mountain and Beaver 

Creek. Sheep Mountain, Whistler, and Crow Lake camps would remain assigned sites. All 

assigned campsites would be closed to the public, and use would be closely monitored 

and controlled to accelerate the recovery of areas outside the designated barren core. 

The other existing campsites listed in Figures A-1 and A-2 would also be used by the 

outfitters, but would also be open to the public. 

Outfitters would be restricted to only using identified, established campsites, and not 

increasing the amount of barren core at any established site. They would not be 
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permitted to create new travel routes, or expose roots on trees. In campsites where the 

barren core exceeds 2,800 square feet, the outfitters would not be permitted to use in 

excess of 2,800 square feet of the barren core area, and would be required to reuse the 

same portion each time. 

The effect of the amendments would be a minor to moderate improvement in the 

opportunities for solitude or primitive and unconfined recreation of both wilderness areas 

compared to the existing condition because the smaller campsites and smaller party sizes 

would help the areas feel more remote by reducing the sights and sounds of the outfitter 

camps and groups. 

There would be some slow improvements at the assigned sites as the unused portions 

begin to revegetate. The revegetation at some camps could be slow because of the short, 

harsh growing season, and the likelihood that non-outfitted users would continue to use 

the area. No new camps, travel routes, or exposed roots on trees would be permitted by 

outfitters, so the overall amount of Wilderness affected by outfitter-guides would not 

increase.

The current conditions at non-assigned sites would not change with implementation of 

this alternative since they would continue to be used by both the outfitter-guides and the 

public. Camp management plans would be made for all camps with more than 2,800 

square feet of barren core (all campsites listed in Figure 3.2-20 not closed to outfitterguide use). The camp management plans would identify the 2,800 square feet of barren 

core the outfitters could use on visit. The amount of barren core would not be expected 

to decrease in non-assigned sites, however, due to the non-outfitted use (refer to 

cumulative effects discussion).

The intensity of the impacts to the opportunities for solitude or primitive and unconfined 

recreation and natural qualities would be lower with this alternative compared to 

Alternatives 2 or 4, since less existing barren core would be used by outfitters, potentially 

allowing for vegetative recovery at existing campsites. The difference between the 

alternatives would be negligible at the wilderness scale, and minor to moderate at the 

local level. 

Pasayten

Pack and saddle stock outfitter-guides would continue to use the existing campsites in 

the Pasayten. Most of their activity would be in the Spanish Camp/Remmel Lake area 

(Bald Mountain and Beaver Creek assigned sites), Sheep Mountain/Corral Lake area 

(Sheep Mountain and Corral Lake assigned sites), Middle Fork of the Pasayten (Whistler 

Camp assigned site), and in the Tatoosh Buttes/Hiddlen Lakes area. 

The Bald Mountain Camp would be closed to outfitter-guides. It would likely 

receive little use because it is off the main trail. People would have to pass 

several established campsites before reaching Bald Mountain. They would likely 

stay at the campsites normally used by the public now. The site would have a 

higher potential for recovery since the number of people and the stock at the 

campsite over a season would be reduced.
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The Sheep Mountain Camp has an existing barren core of 8,879 square feet. A 

camp management plan would be developed and followed, identifying 2,800 

square feet of barren core area the outfitter can use. Outfitter-guide activities 

that would perpetuate the barren core on the additional area would not be 

allowed. The camp would be closed to the public, so the additional 6,079 square 

feet of barren core would begin to recover. 

The Crow Lake Camp has approximately 9,160 square feet of barren core. Two 

thousand eight hundred square feet would be identified for the outfitter to use. 

A camp management plan would be developed to identify and monitor the barren 

core. Outfitter-guide activities that would perpetuate the barren core on the 

additional area would not be allowed. This camp would not be closed to the 

public, so the recovery of the additional 6,360 square feet would depend on the 

activities on non-outfitted pack and saddle stock users and hikers.

The Beaver Creek camp would be closed to outfitter-guides. It is located off the 

main trail, and the average visitor would not find the location. The site would 

have a higher potential for recovery since the number of people and the stock at 

the campsite over a season would be reduced.

Whistler Camp has approximately 4,020 square feet of barren core. A camp 

management plan would be developed to identify the 2,800 square feet of barren 

core the outfitter could use. Outfitter-guide activities that would perpetuate the 

barren core on the additional barren core would not be allowed. The camp would 

be closed to the public, so the additional 1,220 square feet of barren core would 

begin to recover. 

Lake Chelan-Sawtooth

The pack and saddle stock outfitter-guides would continue to operate in the Lake 

Chelan-Sawtooth Wilderness. Most of their trips would be to Williams Lake, Oval 

Lakes, Baldy Mountain area, and Wolf Creek. There are no outfitter-guide campsites 

with over 2,800 square feet of barren core in the Lake Chelan-Sawtooth Wilderness. 

The amount of barren core at these at these campsites would not change with 

implementation of Alternative 3. 

Under Alternative 3, a total of 13,659 square feet (three-tenths of an acre) of barren core in 

the Pasayten Wilderness would no longer be affected by any use because this area would 

be closed to use by both outfitter-guides and the general public (assigned sites). 

Approximately 79,665 square feet of undesignated barren core at campsites in the 

Pasayten, and 17,874 square feet in the Lake Chelan-Sawtooth would no longer be affected 

by outfitter-guides, but impacts from the general public would still continue because the 

undesignated barren core would not be closed to the general public (see cumulative 

effects). The amount of time recovery of these areas would take would depend on the 

microclimate of each campsite. The total amount of barren core the outfitters would use in 

the Pasayten Wilderness in Alternative 3 would be approximately 38,029 square feet, or 0.9 

acres. In the Lake Chelan-Sawtooth, they would use approximately 30,660 square feet, or 

0.7 acres. . 
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Okanogan-Wenatchee National Forest

Figures A-1 and A-2 in Appendix A list the camps consistently used by the outfitters, 

including the amount of barren core and number of damaged trees. These camps would 

continue to be used for full-service and drop camps. The mitigation measures included in 

the alternative would be effective at regulating outfitter-guide activities to meet the 

amended standards and guidelines. 

Stock Confinement and Loose Grazing

Loose grazing would be the preferred method for caring for stock in the wilderness areas 

(see Mitigation Measure 8a). This would limit the amount of time stock are confined in 

camp, thus reducing the size of and amount of disturbance in confinement area. More 

confinement can generally be equated to more impact because it concentrates impact and 

contributes to restless behavior (Leave No Trace, 2001).

There would be a 52% reduction in service days with this alternative compared to the 

current amount. People would continue to encounter or hear outfitted stock grazing, so 

impacts to opportunities for solitude from stock would continue, but at a noticeably 

reduced level. People may see stock in meadows, on trails, or near campsites, and may hear 

the bells used to help locate the herds. These encounters would likely be infrequent, based 

on the very limited reports of such encounters over the past decade, and would be less 

frequent than with implementation of Alternatives 2 or 4. 

Meeting the Need for Commercial Services

The alternative would not meet the low end of the range of the minimum extent necessary, 

so opportunities for primitive and unconfined recreation would be reduced from current 

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

wilderness recreation would be accessible to about half of the people needing the services 

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

the opportunity to experience the primitive and unconfined recreation offered. 

Alternative 4

Alternative 4 would result in minor localized impacts to wilderness character compared to the 

existing condition because the 20% increase in service days. The outfitter-guide activities would 

impact opportunities for solitude in and around campsites, and along trails because the sights 

and sounds of their activities and clients would detract from the remoteness of those localized 

areas. The forest plan amendments allowing the outfitters to use existing campsites within 200 

feet of meadows, streams, lakes, and key interest areas, and to use the existing barren core at 

any campsite without increasing the barren core would prevent degradation of wilderness 

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

barren core.

Opportunities for primitive and unconfined recreation would be maintained for those needing 

the services of an outfitter-guide, but would increase the current minor, localized adverse 

impacts on solitude by maintaining the current number of outfitter-guide pack and saddle stock 

use and activities such as campsite location and grazing in the wilderness. This alternative 

would provide enough service days to meet the upper end of the range of minimum extent 

necessary. Refer to the Needs Assessment in Appendix B for a discussion of the minimum 

extent necessary. 
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Natural Quality

The outfitter-guide activities would continue the current minor, localized impacts to the 

natural quality in wildernesses. The impacts would be the greatest with this alternative 

compared to Alternatives 1, 2, and 3. There would be a 20% increase service days in the 

Pasayten and a 6% increase in the Lake Chelan-Sawtooth. Even with this increase, the 

impacts to the natural quality would be minor because the dispersed, loose-grazing stock 

would not alter plant communities, and would only slightly increase impacts to sensitive or 

rare plant species. There would continue to be isolated spots of damage to stream banks, 

but not at a level that would degrade aquatic habitat or water quality. 

More details are included in the Botany, Water, Aquatic, Range, and Invasive Species reports.

Opportunities for Solitude or Primitive and Unconfined Recreation

Use Levels and Encounters

There would be small increases in the number of people using pack and saddle stock with 

this alternative compared to the current condition (6% in both the Pasayten and the Lake 

Chelan-Sawtooth). For other users, the opportunities for solitude would not be noticeable 

from the existing condition. People would continue to encounter people with stock, 

especially in those areas frequented by pack and saddle stock outfitter-guides. Campsite 

occupancy would increase slightly, but not enough to make finding established campsites 

difficult for non-outfitted recreationists. 

Campsite Size and Condition

The existing campsites would continue to be used by the outfitter-guides. Bald Mountain, 

Sheep Mountain, Beaver Creek, Crow Lake, and Whistler would remain assigned sites. 

These campsites would be closed to the public; use would be monitored and controlled. 

The other existing campsites listed in Figures E-1 and E-2 would also be used by the 

outfitters, but would also be open to the public. 

Outfitters would be restricted to only using identified, established campsites, and not 

increasing the amount of barren core at any established site. They would not be permitted 

to create new travel routes, or expose roots on trees. 

The effect of the barren core and campsite location amendments would result in no 

degradation to the opportunities for solitude, from the current minor, localized impacts. 

The impacts would be greater than Alternative 1, 2, or 3 because of the increase in service 

days. The amendment allowing outfitter-guides to use existing campsites within 200 feet of 

meadows, streams, lakes, and special interest areas would maintain the current impacts to 

opportunities for solitude since the existing campsites would be used. 

The current conditions at non-assigned sites would not change with implementation of this 

alternative since they would continue to be used by both the outfitter-guides and the public. 

Camp management plans would be made for Crow Lake 2 (currently with 7,000 square feet 

of barren core), Fred’s Lake (with 5,400 square feet of barren core), and Peeve Meadow 

(with 5,640 square feet of barren core). The camp management plans would identify the 
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Okanogan-Wenatchee National Forest

existing barren core, and be used to ensure the outfitters are not increasing the barren 

areas. The amount of barren core could increase from use by non-outfitted recreationist, 

however. 

Pasayten

Pack and saddle stock outfitter-guides would continue to use the existing campsites in 

the Pasayten. Most of their activity would be in the Spanish Camp/Remmel Lake area 

(Bald Mountain and Beaver Creek assigned sites), Sheep Mountain/Corral Lake area 

(Sheep Mountain and Corral Lake assigned sites), Middle Fork of the Pasayten (Whistler 

Camp assigned site), and in the Tatoosh Buttes/Hiddlen Lakes area. 

The effects of Alternative 4 on the conditions of the assigned sites are described below. 

A complete list of camps used by the outfitters, including barren core and number of 

damaged trees, is in the full wilderness report in the analysis file.

The Bald Mountain Camp, an assigned site, would continue to have a barren core of 

approximately 3,900 square feet. The camp size and condition would not change 

with this alternative because outfitter-guides would be prohibited from creating 

additional barren core, exposing more tree roots, or creating additional travel routes 

by outfitter-guides. A camp management plan would be developed and followed to 

monitor conditions. The camp would be closed to public use, so further degradation 

should not occur.

The Sheep Mountain Camp, an assigned site, has an existing barren core of 8,879 

square feet. The camp size and condition would not change with this alternative 

because outfitter-guides would be prohibited from creating additional barren core, 

exposing more tree roots, or creating additional travel routes by outfitter-guides. A 

camp management plan would be developed and followed to monitor conditions. 

The camp would be closed to public use, so further degradation should not occur.

The Crow Lake Camp, located in the Sheep Mountain/Corral Lake area, would 

continue to have a barren core of approximately 9,610 square feet. The camp size 

and condition would not change with this alternative because outfitter-guides would 

be prohibited from creating additional barren core, exposing more tree roots, or 

creating additional travel routes by outfitter-guides. A camp management plan 

would be developed and followed to monitor conditions. The camp would be closed 

to public use, so further degradation should not occur.

The Beaver Creek Camp, an assigned site has an existing barren core of 

approximately 6,747 square feet. The camp size and condition would not change 

with this alternative because outfitter-guides would be prohibited from creating 

additional barren core, exposing more tree roots, or creating additional travel routes 

by outfitter-guides. A camp management plan would be developed and followed to 

monitor conditions. The camp would be closed to public use, so further degradation 

should not occur.

Whistler Camp, an assigned site, has an existing barren core of approximately 4,020 

square feet. The camp size and condition would not change with this alternative 
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Okanogan-Wenatchee National Forest

because outfitter-guides would be prohibited from creating additional barren core, 

exposing more tree roots, or creating additional travel routes by outfitter-guides. A 

camp management plan would be developed and followed to monitor conditions. 

The camp would be closed to public use, so further degradation should not occur.

Lake Chelan-Sawtooth

The pack and saddle stock outfitter-guides would continue to operate in the Lake 

Chelan-Sawtooth Wilderness. Most of their trips would be to Williams Lake, Oval Lakes, 

Baldy Mountain area, and Wolf Creek. Barren core would not increase from outfitterguide activity at any campsite. 

Under Alternative 4, the existing 117,694 square feet of barren core (2.7 acres) in the 

Pasayten outfitter camps and 48,534 square feet (1.1 acres) in the Lake Chelan-Sawtooth 

outfitter camps would continue. Since the outfitters would be allowed to use all existing 

barren core, there would be reduction. 

Figures A-1 and A-2 in Appendix A list the camps consistently used by the outfitters, 

including the amount of barren core and number of damaged trees. These camps would 

continue to be used for full-service and drop camps. The mitigation measures included in 

the alternative would be effective at regulating outfitter-guide activities to meet the 

amended standards and guidelines. 

Stock Confinement and Loose Grazing

Loose grazing would be the preferred method for caring for stock in the wilderness areas 

(see Mitigation Measure 8a, page 2-15). This would limit the amount of time stock are 

confined in camp, thus reducing the size of and amount of disturbance in confinement area. 

More confinement can generally be equated to more impact because it concentrates impact 

and contributes to restless behavior (Leave No Trace, 2001).

People would continue to encounter or hear grazing stock, so impacts to opportunities for 

solitude from stock would continue. People may see stock in meadows, on trails, or near 

campsites, and may hear the bells used to help locate the herds. These encounters would 

likely be infrequent, based on the very limited reports of such encounters over the past 

decade. The 20% increase in service days in the Pasayten, and the 15% increase in the Lake 

Chelan-Sawtooth, compared to the current levels, would likely cause a noticeable increase 

in encounters in the areas frequented by the outfitters, but would still comply with the 

encounter standard and guidelines since the current encounter levels are so far below the 

standard. 

Meeting the Need for Commercial Services

This alternative would fully provide the upper range of the minimum amount of commercial 

services needed for wilderness recreation and increase the opportunities for primitive and

unconfined recreation. Pack and saddle stock wilderness recreation would be accessible to 

the portion of the population needing the services due to physical limitations, or lack of skill 

and equipment. Those needing the services of an outfitter would be able to travel into the 

wilderness and enjoy the opportunities for primitive and unconfined recreation.
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Okanogan-Wenatchee National Forest

Cumulative Impacts of all Alternatives

The spatial boundary for the cumulative effects analysis in the Pasayten Wilderness is the entire 

Pasayten and the trailheads leading into the wilderness. Similarly, the boundary for the Lake 

Chelan-Sawtooth Wilderness is the entire Lake Chelan-Sawtooth and the trailheads. The 

temporal boundary for both areas is from the early 1900s through 2023, when the 10-year 

permits would expire. At that point, there would be no further direct or indirect effects to 

wilderness character for pack and saddle stock outfitter-guides, so any cumulative effects would 

be eliminated.

Past Actions

Past actions that have had influenced and are still impacting wilderness character are 

described under the Historic Activities section above. 

Present Actions

Trail Maintenance

The Forest Service is continuing to maintain between 350 and 500 miles of trail each year in the 

Pasayten and 85 to 90 miles in the Lake Chelan-Sawtooth. The maintenance is allowing people 

to access the most popular destinations in each wilderness. Providing maintained trails 

concentrates use on those trails, but leaves the vast majority of both wilderness areas 

untouched, creating a beneficial impact on the opportunities for solitude in the wilderness.

Restoration and Education Activities

Restoration and education activities are ongoing in the Pasayten and Lake Chelan-Sawtooth, and 

are having a beneficial impact on the opportunities for solitude of the wildernesses by improving 

campsite conditions, educating non-outfitted recreationists about Leave-No-Trace techniques 

and wilderness ethics, and monitoring levels of use throughout the wilderness areas. . Some 

ongoing activities are listed below. More details are included in the analysis file.

Provide up-to-date trail information at Forest Service offices and on the Forest website.

Discuss camp access trails with outfitters to develop and maintain only one main access trail 

into camps.

Work with outfitter who uses Bald Mountain camp to manage stock trails between camp 

and grazing area.

Collect use information by permit system, including date, duration, type of use, area, etc. for 

the Pasayten.

Evaluate campsites for potential impacts to threatened and endangered species.

Information about wilderness ethic and resource information, in addition to rules and 

regulations, is posted at all trailheads, and available to all groups. It is also available at 

Forest Service Offices.

Information is provided on Wilderness Permits.

Wilderness ethics and resource information is included on the Forest Service web site.

Leave-No-Trace camping techniques are taught by wilderness rangers in the field.

Handouts detailing Leave-No-Trace camping techniques are available at Forest Service 

offices, and on Forest Service and outfitter websites.

Lead wilderness ranger and wilderness stock ranger attended Leave-No-Trace training.
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Okanogan-Wenatchee National Forest

Outfitter-Guide Permit Administration

Outfitter-Guide permit administration is continuing, with an emphasis on ensuring positive 

working relationships with the outfitters, and compliance with all rules and regulations. This is 

helping ensure that the outfitters’ activities do not grade wilderness character. The following 

list highlights some of the ongoing work:

Working to maintain positive relationships with outfitters through annual meetings with 

individual outfitters to discuss performance, operations, and concerns.

Hosting annual spring meeting with all outfitters to discuss upcoming Forest Service 

activities, outfitter concerns, and Forest Service concerns.

Campsites are discussed with outfitters, and field reviews with Forest Service employees 

and outfitters help address camp management issues. Campsite conditions are also 

discussed and evaluated in annual performance evaluation meetings.

Drop camps are discussed at annual performance evaluation meetings, and drop camps are 

visited by Forest Service employees to assess camp management, location, and compliance 

with permits.

Permit administrators on the Chelan and Methow Valley Ranger Districts are working 

together in the field, in meetings, and in correspondence with outfitters to provide crossunit coordination.

Other Outfitters

Four companies: National Outdoor Leadership School (NOLS), Outward Bound, Wilderness 

Ventures, and YD Adventures operate outfitted and guided backpacking/mountaineer/ 

wilderness education trips in the Pasayten and Lake Chelan-Sawtooth Wilderness areas. 

Combined, they have approximately 3,150 service days in the Pasayten, and 1,400 days in the 

Lake Chelan-Sawtooth. Many of their activities overlap in location and time with the pack and 

saddle stock outfitter-guides, but some are in portions of the wilderness areas either off-limits 

to the pack and saddle stock, or in areas not frequented by them. 

This type of commercial use has less of an impact on wilderness quality than pack and saddle 

stock activities. They use some of the same campsites, but since they do not have stock, stock 

impacts do not occur. Campsites are smaller, most are in compliance with existing standards 

and guidelines regarding barren core and damaged trees, and most of the activities occur in 

portions of the wilderness not commonly used by non-outfitted users. Some of the companies 

occasionally resupply camps using pack and saddle stock, but the rendezvous locations are in 

existing hardened campsites, and the stock do not stay overnight (unless the distance from the 

trailhead requires a one night layover). 

The activities are having a negligible to minor local impact on the opportunities for solitude. 

Non-Outfitted Recreation Use

There are about 16,900 visitor days in the Pasayten and 35,885 in the Lake Chelan-Sawtooth 

each year independent of outfitter guides (backpacking, mountaineering, wilderness education 

and pack and saddle stock outfitters). The use is having localized, minor impacts to 

opportunities for solitude because of established campsites and encounters on trails. The 

campsites and encounters are diminishing the feeling of remoteness, however encounters are 

not exceeding Forest Plan standards and guideline levels, the 2009 Wilderness Study found that 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-83 February 2013

Okanogan-Wenatchee National Forest

the majority of people do not feel crowded in either wilderness. More details are included in 

the current condition section of this report.

Cabins and Buildings

The wilderness has, and continues to be, essentially without permanent improvements and 

human occupation. Several buildings are present in these wildernesses. In the Pasayten, there 

are four cabins used for Forest Service wilderness administration (Spanish Camp, two at Stub 

Creek, and Pasayten Airport in the Pasayten Wilderness), an unstaffed lookout and radio 

repeater building at Monument 85 on the international border with Canada, a snow survey 

cabin along Lightning Creek (visited infrequently by the US Geologic Survey), and four buildings 

at the abandoned Tungsten Mine not used for administration, but as a recreation destination. 

In the Lake Chelan-Sawtooth, there is a cabin along War Creek that is a recreation destination, 

but not used for administration. Other dilapidated trapper cabins are scattered across both 

wilderness area, but are in varying states of collapse, and are unusable. 

The effect of cabins is moderate and local, impacting the undeveloped quality of the 

wildernesses. They can be an intrusion on a visitor’s experience. In some areas, most notably 

the Spanish Camp and Hidden Lakes, where current visitation is relatively high, and pack and 

saddle stock outfitter guides is also high, the cumulative effect of the presence of these cabins 

can diminish experiences of some visitors. However, other visitors may not perceive the 

presence of cabins as a negative effect on their experience. In fact, their visit may be enhanced 

by the historic cabins, or not perceived to be in contrast to the environment.

Reasonably Foreseeable Future Actions

Trail Maintenance

Although not reasonably foreseeable future actions under NEPA, it is reasonably foreseeable 

that the Forest Service will annually maintain between 350 and 500 miles of trail in the Pasayten 

Wilderness, and 85 to 90 miles in the Lake Chelan-Sawtooth. This will keep people concentrated 

in the currently popular portions of wilderness and minimize impacts to the vast majority of 

either wilderness area. The pack and saddle stock outfitter guides will use these maintained 

trails to access campsites.

Restoration Activities

Although not reasonably foreseeable future actions under NEPA, it is reasonably foreseeable 

that restoration activities will continue on existing outfitter and non-outfitter campsites in both 

wilderness areas. The type and intensity of the restoration will depend on the Forest Service 

budget, but these activities will continue to have minor, beneficial effects on the opportunities 

for solitude. It is reasonably foreseeable that the list of restoration activities included in the 

Present Action section will continue, in addition to new ones initiated to resolve any emerging 

situations.

Wildfires

Although not reasonably foreseeable future actions under NEPA, wildland fires are expected 

into the future. Fire suppression activities such as fire line and helispot will continue. These will 

be rehabilitated, but the continued fire suppression will adversely impact the untrammeled and 

natural qualities of the wilderness.
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Okanogan-Wenatchee National Forest

Recreation Use

There will be increasing demand for recreation in the coming years. The technical report 

Outdoor Recreation in the Pacific Northwest and Alaska: Trends in Activity Participation (Hall et 

al, 2009), predicts that since the population of Washington will increase, the number of people 

recreating will also increase, all other factors being even. There will be increases in population 

in all age groups, and younger people are still showing strong interest in outdoor recreation. 

The popularity of recreation activities near water is expected to grow, as is the use of popular 

day use areas. Word-of-mouth recommendations and media exposure will spread interest in 

these popular areas, and crowding and conflict will likely increase (Hall et al, 2009). 

In 2003, the Washington State Recreation and Conservation Office (RCO) completed a report 

that projected participation rates of nature-based activities in Washington State over a 10-year 

and 20-year period based on participation data from the 1999-2000 RCO survey (IAC 2003). 

These projections, shown in Figure 3.2-21, took into account NSRE data and projections for the 

Pacific Northwest Region, demographic trends in Washington State, the local supply of lands 

available for recreation activities, and other factors.

Figure 3.2-21. RCO Recreation Participation Projections as a Percent of Change in the Number of 

People Participating in the Future Compared to 1999-2000 Survey Results (IAC 2003)

Activity Projected % growth in # of participants (2010-2020)

Hiking & Backpacking +13%

Equestrian +3%

These projections were used to estimate the number of people who will be recreating in the 

Pasayten and Lake Chelan-Sawtooth in 2023.

Figure 3.2-22. Current Number of Visitor days by User Group in the Pasayten, Estimated Increase, 

and Future Number of Visitor Days.

User Group Current Visitor 

Days*

Estimated Future 

Increase

Estimated Number of 

Visitor Days in 2023

Backpackers 13,090 13% 14,792

Stock Users 5,610 3% 5,778

TOTAL 18,700 20,570

*Includes current outfitter-guide service days

Figure 3.2-23. Current Number of Visitor days by User Group in the Lake Chelan-Sawtooth, Estimated 

Increase, and Future Number of Visitor Days.

User Group Current Visitor 

Days*

Estimated Future 

Increase

Estimated Number of 

Visitor Days in 2023

Backpackers 23,790 13% 26,883

Stock Users 12,810 3% 13,194

TOTAL 36,600 40,077

*Includes current outfitter-guide service days

It is reasonably foreseeable that the number of hiking/backpacking outfitter-guide service days 

will be the number recommended in the 2012 Needs Assessment (USDA Forest Service, 2012). 

Refer to page B-42 for details. Adding the potential outfitter-guide service days (pack and 

saddle stock and backpacking) to these totals shows the approximate number of visitor days, 

what percentage would be outfitted, and the percent changes compared to current levels.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-85 February 2013

Okanogan-Wenatchee National Forest

Figure 3.2-24. Cumulative Number of Visitor Days by User Group in the Pasayten in 2023, by Alternative

Current or Alternative Pack and Saddle Stock Users Hikers Total

Current

Total Visitor Days 5,610 13,090 18,700

Visitor Days Outfitted 1,800 3,150 4,950

Percent of total 32% 24% 26%

Alternative 1

Total Visitor Days 3,988 14,782 18,770

Visitor Days Outfitted 0 3,150 3,150

Percent of total 0% 21% 17%

Percent Change from Current 

Total

-29% +13% +0.4%

Alternative 2

Total Visitor Days 5,988 14,782 20,770

Visitor Days Outfitted 2,000 3,150 5,150

Percent of total 33% 21% 25%

Percent Change from Current 

Total

+7% +13% +11%

Alternative 3

Total Visitor Days 4,924 14,782 19,770

Visitor Days Outfitted 1,000 3,150 4,150

Percent of total 20% 21% 21%

Percent Change from Current 

Total

-12% +13% +6%

Alternative 4

Total Visitor Days 6,158 14,782 20,940

Visitor Days Outfitted 2,170 3,150 5,320

Percent of total 35% 21% 25%

Percent Change from Current 

Total

+10% +13% +25%
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-86 February 2013

Okanogan-Wenatchee National Forest

This same information is used in the following graphical display. The outfitter-guide days for 

pack and saddle stock, and hiking/backpacking are combined into “Outfitter Service Days”. The 

“Stock Users” and “Hikers” are not outfitted.

Figure 3.2-25. Cumulative Recreation Use in Pasayten by 2023, Outfitted and Non-Outfitted

The information for the Lake Chelan-Sawtooth Wilderness is displayed below.

0

5000

10000

15000

20000

25000

30000

Alt. 1 Alt. 2 Alt. 3 Alt. 4

Visitor/Service Days

Outfitter Service Days

Non-Outfitted Stock Users

Non-Outfitted Hikers
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-87 February 2013

Okanogan-Wenatchee National Forest

Figure 3.2-26. Number of Visitor Days by User Group in the Lake Chelan-Sawtooth in 2023, by 

Alternative

Current or Alternative Pack and Saddle Stock Users Hikers Total

Current

Total Visitor Days 12,810 23,790 36,600

Visitor Days Outfitted 715 0 715

Percent of total 6% 0% 2%

Alternative 1

Total Visitor Days 12,479 26,883 39,362

Visitor Days Outfitted 0 1,400 1,400

Percent of total 0% 5% 4%

Percent Change from Current 

Total

-3% +13% +8%

Alternative 2

Total Visitor Days 13,199 26,883 40,082

Visitor Days Outfitted 720 1,400 2,120

Percent of total 5% 5% 5%

Percent Change from Current 

Total

+3% +13% +10%

Alternative 3

Total Visitor Days 12,799 26,883 39,682

Visitor Days Outfitted 320 1,400 1,720

Percent of total 3% 5% 4%

Percent Change from Current 

Total

-0.1% +13% +8%

Alternative 4

Total Visitor Days 13,304 26,883 40,187

Visitor Days Outfitted 825 1,400 2,225

Percent of total 6% 5% 5%

Percent Change from Current 

Total

+3% +13% +10%

This same information is used in the following graphical display . The outfitter-guide days for 

pack and saddle stock, and hiking/backpacking are combined into “Outfitter Service Days”. The 

“Stock Users” and “Hikers” are not outfitted.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-88 February 2013

Okanogan-Wenatchee National Forest

Figure 3.2-27. Cumulative Recreation Use in the Lake Chelan-Sawtooth by 2023, Outfitted and NonOutfitted

Cumulative Effects on Wilderness Character

Alternatives 1, 2, 3, and 4

Wilderness character is a reflection of the four wilderness qualities discussed throughout this 

report. Beneficial impacts to one quality may be offset by adverse impacts to another in terms 

of evaluating overall character. Evaluating the scale and intensity of the impacts comparatively 

provides the necessary framework for drawing conclusion about the overall effects to the 

character.

The effects to wilderness character of any of the alternatives when considered cumulatively 

with all past, present, and reasonably foreseeable future actions, are virtually identical. Overall, 

the cumulative effects of any of the alternatives to wilderness character would be minor. The 

untrammeled, undeveloped, and natural qualities have been improving since the elimination of 

commercial livestock grazing, although are still being affected by wildfire suppression, and fish 

stocking. The opportunities for solitude or primitive and unconfined recreation would be 

slightly improved by trail maintenance and campsite restoration projects. On the other hand, 

the projected increase in overall recreation use in the coming years would have a minor adverse 

impact to this quality. 

The cumulative effect of all past, present, and reasonably foreseeable future actions will be an 

improving trend in wilderness character. 

Untrammeled and Undeveloped Qualities

There are no cumulative effects to the untrammeled and undeveloped qualities of the Pasayten 

or Lake Chelan-Sawtooth wilderness areas because there would be no direct or indirect effects 

from any of the alternatives. Some past, present, and reasonably foreseeable future actions are 

affecting these qualities. Fire suppression and fish stocking would continue to have a negative 

0

5000

10000

15000

20000

25000

30000

35000

40000

45000

Alt. 1 Alt. 2 Alt. 3 Alt. 4

Visitor/Service Days

Outfitter Service Days

Non-Outfitted Stock Users

Non-Outfitted Hikers
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-89 February 2013

Okanogan-Wenatchee National Forest

impact on the untrammeled quality, but the elimination of commercial livestock grazing is 

having a major wilderness-wide, beneficial impact on the untrammeled quality as wilderness 

ecosystems are allowed to function without wide-scale impacts to plant communities and soil 

properties. 

Natural Quality

The cumulative effect of the past, present, and reasonably foreseeable future actions, and any 

of the alternatives would be a continued improving trend in the natural quality of both the 

Pasayten and Lake Chelan-Sawtooth wilderness areas. The natural quality of both wilderness 

areas is continuing on the wide-spread, upward trend that began with the elimination of 

commercial livestock grazing and party-size controls that have limited the size of recreational 

stock herds. Grazing by outfitted and non-outfitted pack and saddle recreational livestock 

would not alter plant communities, or impact vegetation more that could recover within one 

year. Therefore, the cumulative effect would be a continuing upward trend in vegetative 

condition. The ongoing trail maintenance will minimize erosion on trails, protecting 

streambanks and water quality. The outfitter-guide activities in Alternatives 2, 3, or 4 would 

have localized impacts to the natural quality but the impacts would be minor because the 

dispersed, loose-grazing stock would not alter plant communities, and would only slightly 

increase impacts to sensitive or rare plant species. There would continue to be isolated spots of 

damage to stream banks, but not at a level that would degrade aquatic habitat or water quality. 

Opportunities for Solitude or Primitive and Unconfined Recreation

The reasonably foreseeable future increases in non-outfitted recreation use, commercial 

backpacking/hiking outfitters, and Alternatives 2, 3, or 4 could potentially decrease the 

opportunities for solitude as popular destinations become more crowded. The cumulative 

effect of the elimination of pack and saddle stock outfitter-guides under Alternative 1 coupled 

with the potential increases in non-outfitted recreationists would be virtually no change in the 

current number of people in the Pasayten, and an 8% increase in the Lake Chelan-Sawtooth. 

The cumulative effect with Alternative 2 would be an 11% increase in the Pasayten, and a 10% 

increase in the Lake Chelan-Sawtooth; with Alternative 3, a 6% increase in the Pasayten and an 

8% increase in the Lake Chelan-Sawtooth; with Alternative 4, there would be a 25% increase in 

the Pasayten and a 10% increase in the Lake Chelan-Sawtooth. Considering these small 

increases and the fact that the majority of people did not find the wilderness areas crowded 

(Burnes, et al., 2010), the cumulative effect of all actions and any of the alternatives would be a 

virtually unnoticeable decrease in opportunities for solitude resulting from increased 

encounters with other people. 

Visitor behaviors in the past have left effects upon the landscape that persist and add to the 

effects of current use. Some areas still show impacts from over 50 years ago, even when 

current use is not adding to this effect. The outfitter-guide use in Alternatives 2, 3, and 4, in 

addition to non-outfitted use is a cumulative perpetuation of impacts at some existing sites. 

This effect is only present in a very small percentage of the landscape and only a small number 

of visitors are affected.

In the Pasayten, hikers, and pack and saddle stock users would continue to favor different 

locations. Pack and saddle stock users would be more common in the Spanish Camp/Remmel 

Lake area, and in the Sheep Mountain/Corral Lake area. The Pasayten Airport would still receive 

some stock use, but the limited amount of forage, lack of a destination lake would generally 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-90 February 2013

Okanogan-Wenatchee National Forest

result in light use. The Pasayten River drainage would also receive some stock use, especially at 

Whistler Camp and at the lakes along the Middle Fork Pasayten. Use here would be much 

lighter than in Spanish Camp/Remmel Lake, or Sheep Mountain/Corral Lake because forage is 

somewhat limited. Stock use at Hidden Lakes would be light due to lack of forage. Tatoosh 

Buttes has ample forage but stock use outside of hunting season would be limited because the 

trail is difficult, and water supply is limited.

In the Lake Chelan-Sawtooth, hikers and pack and saddle stock users would continue to use the 

popular destinations in the Lake Chelan-Sawtooth. Day hikes and horseback rides would 

continue, with the Twisp River Horse Camp providing a hub for non-outfitted pack and saddle 

stock activity in the Twisp River. The pack and saddle stock outfitters would continue to use the 

established camps, which would also be used by non-outfitted parties.

The outfitter-guides would be limited in the amount of barren core they could use based on the 

alternative (5,250 square feet in Alternative 2; 2,800 in Alternative 3) in campsites where the 

existing amount exceeds that level. In camps with less barren core, the outfitters would be 

prohibited from creating new barren core, exposing additional roots on trees, or creating new 

travel routes. In Alternative 4, the outfitters could use all existing barren core, but would be 

prohibited from creating additional barren core, exposing additional roots on trees, or creating 

new travel routes. 

In the assigned sites (Bald, Beaver Creek, Crow Lake, Sheep Mountain and Whistler camp in 

Alternatives 2 and 4; Crow Lake, Sheep Mountain, and Whistler in Alternative 3, all in the 

Pasayten) this would result in slow recovery of excess barren core in Alternatives 2 or 3, or no 

increase in the amount of barren core. There would also be no increase in the number of trees 

with exposed roots or user created travel routes. Since these camps would be closed to the 

public, there would be no cumulative effect with non-outfitted use.

In all other campsites, the cumulative effect of the outfitted and non-outfitted use could be 

increasing barren core, more damaged trees, and new travel routes, depending on the use 

pattern of the non-outfitted users. This could result in minor to moderate, localized impacts to 

the opportunities for solitude if camp conditions degrade, detracting from the remoteness of 

the areas. Effects of the pack stock use to be permitted under this analysis, when added to past 

conditions and effects of present and reasonably foreseeable future actions are negligible at the 

wilderness scale. 

Current commercial hiking/backpacking activities in the Pasayten and Lake Chelan-Sawtooth 

have the potential to cumulatively affect opportunities for solitude where the use overlaps with 

pack and saddle stock outfitter guides activities. The only areas where overlap occasionally 

occurs is at Hidden Lakes in the Pasayten and Oval Lakes in the Lake Chelan-Sawtooth, so the 

cumulative effect on opportunities for solitude are very similar to those described under the 

current condition. Encounter levels would not exceed Forest Plan standards and guidelines, and 

there may be times when pack and saddle stock and other outfitter-guides occupy camps in the 

same vicinity. 

At the wilderness scale, the cumulative effects of all past, present, and reasonably foreseeable 

future actions are not likely to decrease the opportunities for solitude, although there may be 

site-specific locations where effects are more intense. Management actions such as campsite 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-91 February 2013

Okanogan-Wenatchee National Forest

restoration, along with education efforts to change visitor practices and improved outfitterguide permit administration, have maintained an upward trend in wilderness character through 

the slow correction of past effects, and minimize potential for new effects. Actions in the 2000 

Recreation Activity Review such as addressing the network of trails in concentrated use areas, 

monitoring campsites, improving special use permit administration, increasing leave-no-trace 

education efforts all support this trend. 

Meeting the Need For Commercial Services

The cumulative effect of the present and reasonably foreseeable future commercial 

backpacking/hiking services and the pack and saddle stock outfitter-guide levels in Alternatives 

2 and 4 would fall within the range of the minimum extent necessary to provide for wilderness 

recreation, as identified in the Needs Assessment (USDA, 2012). The need would be partially

met, cumulatively with Alternative 3, and to a lesser degree with Alternative 1, since only 

hiking/backpacking outfitter-guide services would be available.

CONSISTENCY FINDINGS

Wilderness Act

All four alternatives would comply with the Wilderness Act. All alternatives would help manage 

pack and saddle stock outfitter-guide activities to protect the wilderness character by allowing 

only local, minor to moderate impacts to the opportunities for solitude or primitive and 

unconfined recreation and natural qualities. Impacts would be concentrated, and the vast 

majority of both the Pasayten and Lake Chelan-Sawtooth would be free from any impacts from 

outfitter-guide use to these qualities. In Alternatives 2 and 4, the amount of commercial 

services provided would fall within the range of the minimum extent necessary to provide for 

wilderness recreation, as identified in the Needs Assessment (USDA, 2012, and Appendix B). 

Alternative 3 would offer some commercial services, but less than the minimum extent 

necessary. 

Forest Service Manual

All four alternatives would comply with Forest Service Manual 2300, and the Wilderness 

Management Model. There continues to be an upward trend in the condition natural quality, 

and in opportunities for solitude and primitive and unconfined recreation. This is moving the 

condition of the wilderness areas towards a higher level of wilderness character. 

Forest Plan Standards and Guidelines

Conditions would still exist in the Pasayten and Lake Chelan-Sawtooth that do not comply with 

some of the standards and guidelines in the Forest plans but not as a result of authorizing pack 

and saddle stock operations. Implementation of Alternative 1 would eliminate pack and saddle 

stock outfitter-guides from wilderness, pack and saddle outfitter-guide activities would not have 

any effect on standards and guidelines. Alternatives 2, 3, and 4 would amend the Forest Plans, 

and pack and saddle stock outfitter-guide activities would be fully compliant with the amended 

plans. As with Alternative 1, conditions would still exist that do not comply with existing 

standards and guidelines as a result of past actions, but would not be a result of pack and saddle 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-92 February 2013

Okanogan-Wenatchee National Forest

stock outfitter-guide activities. In fact issuance of the pack and saddle stock outfitter-guide 

permits would help to restore areas that are currently not meeting the amended Forest Plan 

standards and guidelines.

Wenatchee Forest Plan

These standards and guidelines apply to the portion of the Lake Chelan-Sawtooth Wilderness on 

the Chelan Ranger District.

Wilderness Standards and Guidelines

Pristine (pages IV-69 to IV-71): Pack and saddle stock outfitter-guides are not allowed to 

operate within the Pristine WROS areas, so these standards and guidelines do not apply to their 

activities.

Some of the standards and guidelines are common to Primitive, Semi-Primitive, and Transition 

Wilderness Recreation Opportunity Spectrums (WROS). All the standards and guidelines from 

pages IV-71 to IV-76 are listed below. Ones unique to particular WROS are noted, otherwise the 

standard and guideline applies to all. 

a. Physical-Biological Standards

(1) Vegetation

(a) Primitive: Area of vegetation loss, and compacted bare mineral soil at any campsite 

should not exceed 400 square feet. Semi-Primitive: Area of vegetation loss, and 

compacted bare mineral soil at any campsite, should not exceed 625 square feet. 

Transition: Area of vegetation loss, and compacted bare mineral soil at any campsite, 

should not exceed 1000 square feet. These standards would be amended with any 

of the action alternatives, and outfitter-guide activities would comply with the 

amended standard. Mitigation measure 1.c and 1.d. require compliance with the 

amended standard.

(b) Primitive: There should be no loss of trees at any site and fewer than four trees with 

exposed roots per impacted site. Semi-Primitive: There should be no loss of trees at 

any site and only six trees per site with roots exposed or which show signs of human 

use impact. Transition: There should be no loss of trees at any site and only ten trees 

per site with roots exposed or which show signs of human use impact. Mitigation 

measure 1.e would ensure prohibit outfitters from exposing any additional roots on 

trees in established wilderness campsites. Mitigation measure 3.b prohibits 

outfitters from cutting or damaging any trees, including snags. 

(c) Primitive: No noticeable, long-term modification of natural plant succession as a 

result of livestock grazing or human activity. Semi-Primitive and Transition: There 

should be no long-term modification of plant succession and only short-term 

modification due to human activity or livestock grazing that can recover in one 

growing season. The botany analysis of the alternatives found that none would 

have long-term modifications of natural plant succession. Refer to FEIS pages 269.

(d) Dead trees or dead, woody debris may be utilized for campfires in amounts that can 

be replaced annually through natural accumulation. Mitigation measures 3.a and 3.b 

address firewood; limiting campfires to areas with sufficient down wood and 

prohibiting cutting dead trees or snags.
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Okanogan-Wenatchee National Forest

(2) Soils

(a) Displacement and erosion of soil resulting from human activity will be limited to a 

rate that approximates natural processes. The soil analysis of the alternatives found 

that the outfitter-guide activities would comply with this standard. Refer to FEIS 

pages 168.

(b) Primitive: Soil compaction should not exceed limits which will prevent natural plant 

establishment and growth except at well established campsites. Semi-Primitive and 

Transition: Soil compaction should not exceed limits which will prevent natural plant 

establishment and growth, except at desired campsites, and in designated trailheads. 

The soil analysis of the alternatives found that the outfitter-guide activities would 

comply with this standard. Refer to FEIS page 3-168.

(3) Water Quality

There should be no change in water quality except for temporary changes that return to 

normal when activity ceases. The water resource analysis found compliance with this 

standard. Refer to FEIS pages 182.

(4) Air Quality

Air Quality will not be degraded as a result of campfire smoke, or Forest Service 

Management activities outside of wilderness in Class I areas. The air quality analysis 

found compliance with this standard. Refer to FEIS page 3-376.

(5) Fish and Wildlife

(a) Visitor use may temporarily displace wildlife, but should not displace wildlife from 

critical habitat during critical periods. The Biological Evaluation for aquatic and 

terrestrial species found the activity “may affect, but will not likely adversely affect” 

threatened and endangered species. In addition, mitigation measures 12 a-f direct 

specific outfitter-guide activities to ensure compliance with the standard.

(b) Semi-Primitive and Transition: Riparian areas should appear to be unchanged by 

human or livestock use. Mitigation measures 12 a through g would control outfitterguide activities in riparian area, and ensure that campsites do not increase in size, 

and that additional trees are not damaged. 

(c) Semi-Primitive and Transition: Displacement of wildlife due to visitor use may be 

significant but should be of short duration to assure a natural ecosystem is 

maintained. Visitor use should not decrease habitat effectiveness for one species 

more than 20 percent. Mitigation measure 11.a prohibits feeding, harassing, or 

disrupting wildlife, ensuring compliance with this standard.

(6) Scenery

(a) Primitive and Semi-Primitive: Campsites will occasionally be visible from other 

campsites. Transition: Campsites will be visible at times from other campsites. 

Mitigation measure 1.f prohibits outfitters from creating new campsites. The 

wilderness analysis found the existing condition complies with this standard (FEIS 

page 3-46) and the mitigation measure ensures outfitter-guide activities will not 

alter this compliance.

(b) Primitive and Semi-Primitive: Human activity should remain subordinate in 

foreground viewing and not recognizable in middle-ground viewing. Transition: 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-94 February 2013

Okanogan-Wenatchee National Forest

Human activity should remain generally subordinate in foreground viewing and not 

recognizable in middle-ground viewing. Mitigation measure 1.f prohibits outfitters 

from creating new campsites. The wilderness analysis found the existing condition 

complies with this standard (FEIS page 3-377) and the mitigation measure ensures 

outfitter-guide activities will not alter this compliance.

(7) Livestock Allotments 

This standard applies to commercial livestock permits, not outfitter-guide special use 

permits. 

b. Social Standards

(1) Encounters

Primitive: There should be an 80 percent probability that not more than either seven 

parties or seven individuals traveling alone will be encountered per day during the 

primary use season. Semi-Primitive: There should be an 80 percent probability that not 

more than either ten parties or ten individuals traveling alone, will be encountered per 

day during the primary use season. Transition: There should be an 80 percent probability 

that no more than either 10-20 parties or 10-20 individuals traveling alone, will be 

encountered per day during the primary use season. Generally encounters should not 

exceed 10, however, in unique situations, encounters may reach 20 per day. The 

encounter analysis showed that all alternatives would comply with this standard. Refer 

to FEIS pages 3-70, 3-74, and 3-78. 

(2) Party Size

The maximum party size shall not exceed 12 people and 18 animals in the Lake ChelanSawtooth Wilderness. Mitigation measure 9.a specifies that the outfitters will adhere to 

the party size limitation, with provisions for oversized parties, following specifications 

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

(3) Campsites

Primitive: There shall be no more than one campsite visible or audible from any 

campsite, or closer than 500 feet in open country. Semi-Primitive: There shall be no 

more than two campsites visible or audible from any campsite, or closer than 500 feet in 

open county. Transition: There shall be no more than three campsites visible or audible 

from any one campsite, or closer than 500 feet in open country. Mitigation measure 1.f 

prohibits outfitters from creating new campsites. The wilderness analysis found the 

existing condition complies with this standard (FEIS page 3-46) and the mitigation 

measure ensures outfitter-guide activities will not alter this compliance (3-60).

(4) Livestock

Primitive: Grazing stock is permitted except in established camp areas. Repeated stock 

use in cross-country travel by a single route shall be discouraged. Semi-Primitive and 

Transition: Grazing of stock is permitted except in established camp areas. Mitigation 

measures 8. a-g pertain to stock grazing and containment. Mitigation measure 6a 

requires outfitters to remain on existing trails, and prohibits new trail construction. 

This would prevent the establishment of new cross-country trails.
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Okanogan-Wenatchee National Forest

(5) Pets

Primitive and Semi-Primitive: Pets must be under reliable voice control or physical 

restraint. Pets may be banned from this class for protection of wildlife or to avoid other 

resource impact. Transition: Pets must be under reliable voice control or physical 

restraint. Pets may be banned from this class for protection of wildlife or to avoid other 

biological or social impact. Visitors will be encouraged to leave pets at home in areas of 

higher visitor use. Mitigation measure 11g requires outfitters to maintain control of 

dogs at all times, and not menace or annoy other visitors, stock or wildlife.

c. Managerial Standards

(1) Regulations and Information

(a) Primitive: Posting of information and regulations regarding this class will be located 

at trailheads. Semi-Primitive: Posting of information and regulations regarding this 

class will generally be done at trailheads. Some regulatory signing may be posted at 

key locations such as lakeshores and campsites to help gain user compliance. 

Transition: Posting of information and regulations will generally be posted at 

trailheads but some regulatory signing may be necessary in key impact areas, or areas 

where there is potential for use conflicts. These standards do not apply to outfitterguides.

(b) Primitive: Formal orders and permits may be required to achieve management 

objectives. Semi-Primitive and Transition: Formal orders and permits may commonly 

be used to achieve management objectives in this class. These standards do not 

apply to outfitter-guides.

(c) Ranger patrols and administrative contacts will occur. Personnel involved in project 

work or monitoring will be present. Management personnel should conform to party 

size limitations and social standards for this class (refer to Forest Plan for full text of 

standards and guidelines for Primitive, Semi-Primitive, and Transition). This standard 

does not apply to outfitter-guides.

(d) Primitive: Signs will be kept to the minimum to protect Wilderness resource. No signs 

will be provided to indicate destinations. This standard does not apply to outfitterguides.

(e) Primitive: Visitor travel routes may be noticeable, but should appear as wildlife trails. 

Mitigation measures 6.a & b limit outfitter-guide use to existing trails, prohibiting 

unauthorized construction or maintenance of trails. 

(2) Trails

Primitive: System trails are present in this class generally at low density. Some user 

developed trails may exist, but are not encouraged for use and rarely upgraded to system

trails. If user-developed trails become well established, management action should be 

taken to rehabilitate damage and discontinue use. Reroutes of existing trails may be 

done to protect resources or to meet wilderness objectives. New trail construction in 

trailless drainages or to new destinations must be considered in the Forest planning 

process. Semi-Primitive and Transition: The managed trail system should be maintained 

or constructed toward more and most difficult trail standards. However, trails classified 

easiest may exist in areas of gentle terrain and valley bottoms. A variety of user 
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Okanogan-Wenatchee National Forest

restrictions may be implemented to resolve negative resource impacts. Outfitter-guides 

are not allowed to construct trails without authorization, so their activities will not 

impact trail density. Management of the trail system does not apply to outfitter-guides.

(3) Resource Protection Facilities

Primitive: Facilities that are essential for resource protection and visitor safety are 

appropriate in this class. Only native or natural appearing construction materials will be 

used. There will be no facilities provided for user comfort or convenience. There are no 

assigned sites in the portion of the Lake Chelan-Sawtooth Wilderness covered by this 

standard. Mitigation measure 1g prohibits construction of facilities at non-assigned 

sites.

Semi-Primitive and Transition: Facilities will be as natural appearing as possible or will be 

constructed out of native material. No facilities will be constructed for user convenience 

or comfort. Facilities will be placed so as to concentrate heavy impact on areas previously 

impacted and on sites capable of withstanding high impacts. There are no assigned sites 

in the portion of the Lake Chelan-Sawtooth Wilderness covered by this standard. 

Mitigation measure 1g prohibits construction of facilities at non-assigned sites.

General Wilderness Management (Wenatchee Forest Plan pages IV-227 through IV232)

Recreation

1. Visual Quality Objective; Preservation, except as authorized by the Wilderness Act. 

Outfitter-guides are prohibited from creating new camps, increasing the amount of 

barren core in campsites, creating new trails, cutting down snags, or damaging trees, 

all of which could impact the visual quality. 

2. Management activities and work projects will be planned and implemented in 

accordance with Wilderness Management Standards and Guidelines, and criteria 

identified in Wilderness Recreation Opportunity Spectrum Classes. This does not 

pertain to outfitter-guides.

3. Forest-wide Standards and Guidelines for Cultural Resources apply. The outfitter-guide 

activities would have no impact on cultural resources since there would be no ground 

disturbing activities. Refer to the Heritage Resources Section, 3.12.

4. Recreation use related facilities, such as toilets or corrals, established to protect 

wilderness resources, will be constructed or reconstructed in accordance with 

Wilderness Recreaiton Opportunity Spectrum (WROS) Class Criteria. There are no 

assigned sites in the portion of the Lake Chelan-Sawtooth Wilderness covered by this 

standard. Mitigation measure 1g prohibits construction of facilities at non-assigned 

sites.

5. Facilities and campsites, where appropriate, will be managed to minimize social and 

biological resources impacts. The resource and social impact analysis found that 

campsites used by the outfitters are having minor localized impacts. Refer to resource 

sections in Chapter 3.

6. Management actions will be implemented to control or restrict visitor use when user 

impacts result in a change in biological or social resource conditions that approach limits 

of acceptable change. This does not apply to outfitter-guide permitted activities. 
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Okanogan-Wenatchee National Forest

7. Wilderness Ranger contacts with recreation visitors for educational, instructive, and 

informative purposes will generally be made outside wilderness or in high visitor use 

areas. This standard and guideline does not apply to outfitter-guides.

8. Permits or authorization to providers of commercial recreation opportunities will be 

issued when appropriate to the goals of wilderness management and where compatible 

with the WROS class and existing visitor use of an area. The analysis found the pack 

and saddle stock outfitter-guide activities are compatible with the WROS classes and 

would not exceed the wilderness capacity. Refer to Appendix B.

9. Trail construction and reconstruction will occur to protect biological resource values and 

to meet wilderness management objectives. Mitigation measure 6a prohibits 

outfitters from constructing new trails, so this standard does not apply to their 

activities.

10. Trail reconstruction or construction specification will meet trail objectives and conform 

with specifications of the appropriate WROS class in which the trail is located. 

Mitigation measure 6b limits trail maintenance performed by outfitter-guides to 

system trails, and requires compliance with trail standards, and Forest Service 

approval prior to work.

11. The trail system will be maintained and operated as appropriate to trail objectives and 

the appropriate WROS class for the area accessed by the trial. This does not apply to 

outfitter-guide activities. 

Wildlife and Fish

These standards and guidelines do not apply to outfitter-guide activities. 

Range

These standards and guidelines do not apply to outfitter-guide activities. 

Water

The standards and guidelines that pertain to outfitter-guide activities are the forest-wide 

standards and guidelines on page IV-94 and IV-95. The Water analysis found the activities 

comply with the Clean Water Act (Washington Administrative Code, Chapters 173-201 and 

202), and would follow the Best Management Practices (mitigation measures) to protect 

water quality.

Soil

These standards do not apply to outfitter-guide activities. 

Air

The air quality analysis found compliance with this standard. Refer to FEIS page 3-376.

Minerals and Geology

These standards do not apply to outfitter-guide activities. 

Lands

These standards do not apply to outfitter-guide activities. 

Additional standards and guidelines for General Wilderness are found in the Wenatchee Forest 

Plan on pages E-3 through E-23. Those not already address above, and those that apply to 
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outfitter-guide activities, and listed below. Standards and guidelines not listed do not apply to 

outfitter-guide activities.

1. If monitoring of on-site conditions indicates that wilderness resource values are being 

degraded or hanged to a point that limits of acceptable change are being closely 

approached, management action must be implemented to reverse the declining trends. 

The Wilderness analysis found wilderness character is on a stable or improving trend, 

and that limits of acceptable change are not being approached. The exception is the 

size of the bare mineral soil area within camps, but the alternatives would comply 

with the forest plan amendment included in the alternative.

2. Recreation visitors should not be permitted to cache or store equipment, personal 

property or supplies in wilderness. Outfitter-guides must comply with CFR regulations, 

including prohibitions on caching.

3. Deviation or waivers from party size limitation may be approved by District Rangers. 

Mitigations measure 9a specifies that requests for oversized parties will be evaluated 

following direction in the Forest Plans.

4. Care should be taken to avoid the introduction of non-native plant species into 

wilderness. To minimize the possibility of accidental introduction through saddle and 

pack animal feed, the use of hay and unprocessed grain will be prohibited. Mitigation 

measures 14 a through e address invasive species. Measure 13b prohibits use of nonprocessed feed.

5. The areas surrounding campsites should be closely monitored for the presence of a near 

natural component of dead, deteriorating, wood debris. Area lacking this component 

will be closed to campfires until natural accumulative recovers and excess wood is 

available. Mitigation measure 3a specifies that campfires are allowed only where 

there is sufficient downed firewood. 

6. Horse and pack animal users should follow, at a minimum, the following practices: 

avoid picketing or tying animal to feed in one location for a long period of time. 

Hobble animals or allow them to road free during feeding periods. Mitigation 

measure 8a states that loose grazing is the preferred method.

Do not graze, hitch, tether , or hobble any pack or saddle livestock with 200 feet 

slope distance of the shoreline of any lake. Mitigation measure 8i prohibits this 

grazing within 200 feet of lakeshores.

Tie stock on well-placed high lines during periods when not feeding. Feed animals in 

nose bags or feed bags to avoid littering a site. Mitigation measure 8j requires 

these in campsites on the Chelan Ranger District portion of the Lake ChelanSawtooth Wilderness.

7. Horse and pack animals users should generally be encouraged to pack in their basic feed 

supply for a trip, relying on available forage as a supplement. In heavily used areas and 

areas where forage is in short supply, the total feed needs of the animals should be 

packed in. Mitigation measure 8g requires outfitters to pack in feed when forage 

conditions do not allow loose grazing.

8. Human activity should not influence the natural quality of any waters within wilderness 

beyond temporary changes that return to normal when activity ceases. The water 

analysis found that pack and saddle stock outfitter-guide activities would result in 

short term decreases in water quality, but that natural conditions would return when 

activities cease.
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Okanogan-Wenatchee National Forest

9. Areas used by recreation visitors will be closely monitored for evidence of accelerated 

erosion. Water sources and water bodies near campsites should be observed for 

evidence of soap, other chemicals, and biological contaminants that may be introduced 

by human activity. The Monitoring Plan includes specific monitoring activities for 

campsites in riparian areas, and for compliance with terms and conditions of special 

use permits. 

10. Outfitter-guide permits should be issued or continued when there is a demonstrated 

public need or demand, permitted use is compatible with general public use, and 

permitted use can occur in an area without exceeding the carrying capacity of an area. 

The number of permits issued and amount of use should be evaluated periodically to 

assure an appropriate balance is maintained between general public use and outfitted 

use. These were addressed in the 2012 Needs Assessment, Appendix B.

11. Outfitter-guide camps should be located away from other popular visitor campsites to 

reduce social resource impact. The pack and saddle stock outfitter-guides would be

restricted to using designated campsites on the Chelan Ranger District portion of the 

Lake Chelan-Sawtooth Wilderness. This would reduce social resource impacts.

12. Outfitter-guide permittees should actively assist in the education of wilderness visitors, 

with the scope of their operations. This was a criterion in evaluating the need for pack 

and saddle stock outfitter-guides in Wilderness. Refer to the 2012 Needs Assessment 

in Appendix B.

13. Recreation visitors should be encouraged to protect visual and scenic quality by 

following a few basic principles.

Locate campsites away from and out of site of trails, lakeshores, other campsites, 

and other points of interest. 

Tie or high line horses and pack animals out of sight of trails, lakeshores, campsites 

and other pints of interest.

Leave no trace or evidence of their visit.

Use equipment that is earth tones in color.

Outfitter-guides are required to use existing campsites, and not increase the size of 

campsites. Mitigation measures 5 a and b require the outfitters to follow Leave-NoTrace techniques.

14. Facilities and structures built for protection or resource values should be located to the 

extent practical in areas where visual impact will be minimal. Mitigation measure 1b 

specifies that new facilities should be constructed to minimize impacts to visual 

quality.

Okanogan Forest Plan Wilderness Standards and Guidelines (MA15B)

These standards and guidelines apply to MA15B in the Pasayten Wilderness and to the portion 

of the Lake Chelan-Sawtooth Wilderness on the Methow Valley Ranger District. Pack and saddle 

stock outfitter-guides are not allowed to operate in MA15A, the trailless portion of wilderness.

Planning

MA15B-21A The visual quality objective is preservation. All alternatives comply. Refer to FEIS 

page 3-286.
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Okanogan-Wenatchee National Forest

MA15B-21B Primitive recreation opportunities shall be provided. The outfitter-guides provide 

primitive recreation opportunities. All alternatives comply. Refer to FEIS page 1-18.

MA15B-21C Use of nature and natural materials for facilities shall dominate. Use of dimensional 

and non-nature material should remain subtle to the wilderness user. Outfitters are only 

allowed to construct facilities at assigned sites, and the facilities can only be for resource 

protection, not for comfort or convenience. Facilities must be constructed of native materials. 

Mitigation measure 1.b.

MA15B-21D All human activities shall follow a non-degradation policy. The Wilderness analysis 

disclosed the effects of the alternatives on the four components of wilderness character, and 

found none will degrade wilderness. 

MA15B-21E Use data gathering should emphasize voluntary registration system at trailheads or 

contacts at offices and trailheads rather than contacts within wilderness. This standard does 

not apply to outfitter-guides.

MA15B-21F Except for emergency orders, Forest orders pertaining to wilderness regulation shall 

be discussed with concerned publics prior to adoption. This standard does not apply to 

outfitter-guides.

Facilities

MA15B-21G Facilities for visitor use shall only be provided for protection of the wilderness 

resource and as a last resort, only after trying information and education, indirect management 

methods, or regulation use. Outfitters are only allowed to construct facilities at assigned sites, 

and the facilities can only be for resource protection, not for comfort or convenience. Facilities 

must be constructed of native materials. Mitigation measure 1b.

Wilderness Standards and Guidelines: Use Administration 

MA15B-21H Minimum impact techniques shall be used. Mitigation measures 5.a & b require 

outfitters to follow Leave-No-Trace principles.

MA15B-21I The number and types of encounters between users should be controlled by limiting 

trailhead parking, maintaining or increasing the amount of difficult access, or by separating uses. 

This does not apply to outfitter-guide activities.

MA15B-21J Campsites should be located within forested areas on litter, where possible. Sites 

should be located to take advantage of topographic or vegetative screening. The outfitters are 

required to use existing campsites, most of which have existing barren core devoid of litter. 

Mitigation measure 1.a requires all camp locations to be approved prior to use. Measures 1.c, 

d, and e specify the amount of barren core that can be used and prohibit increasing the 

amount of barren core. Measure 1.g prohibits outfitters from creating new campsites. 

MA15B-21K There should be an 80 percent probability of two or fewer campsites being visible 

or audible from any campsite. The encounter analysis found all alternatives would comply 

with this standard and guideline. Refer to FEIS pages 3-44 and 3-60.
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Okanogan-Wenatchee National Forest

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

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

protect wilderness values. Alternatives 2 and 4 would amend this standard to allow outfitters 

to use established campsites within these zones. Alternative 3 would allow outfitters to use 

established campsites within 200 feet of dry meadows but prohibit camping within 200 feet of 

wetlands, lakes, streams, and key interest areas. 

MA15B-21M Leaving or storing equipment, personal property, or supplies unattended for more 

than 48 hours shall be prohibited. Written exceptions may be granted by the District Ranger 

upon request. Mitigation measure 4.a specifies that the outfitter-guides must comply with all 

rules and regulations, including 36 CFR 261.57f prohibiting caching. Mitigation measure 1.b 

allows equipment to be left at assigned camps during the operating season, but required 

removal at the end of each season.

MA15B-21N Maximum party size shall be 12 people and 18 head of stock. Written exceptions 

may be granted when:

1) Application is made to the District Ranger,

2) Campsites and travel routes are capable of physically and socially absorbing such use.

3) Use will not occur during heavy use periods.

4) There will be no more than one oversized party at a time on a trail or popular use route or 

in a destination area.

5) The oversized group will not occupy most of a destination area.

6) Travel will be in groups not exceeding 12 people or 18 head of stock and separated in time 

on the same trail.

7) For commercial parties, all oversized groups shall be considered temporary use.

Mitigation measure 4.a specifies that the outfitter-guides must comply with all rules and 

regulations, including 36 CFR 261.58f prohibiting parties over 12 people and 18 head of stock. 

Mitigation measures 9 a-c specify the provisions for oversided parties. 

MA15B-21O There should be at least an 80 percent probability of not more than seven 

encounters per day between groups while traveling on trails during all use periods. Encounter 

analysis found all alternatives comply with this standard and guideline. Refer to FEIS pages 3-

70, 3-74, and 3-78.

MA15B-21P Pets may be restricted by CFR for the protection of wildlife or to decrease resource 

impacts. Working stock dogs may be exempt from restrictions. Mitigation measure 11g 

requires outfitters to maintain control of dogs at all times to avoid menacing or annoying 

other visitors, stock or wildlife.

MA15B-21R Only those camp structures and facilities necessary for the outfitter guide to 

properly meet their public service in a manner compatible with the wilderness environment 

shall be authorized. For commercial parties, all oversized groups shall be considered temporary. 

Outfitters are only allowed to construct facilities at assigned sites, and the facilities can only 

be for resource protection, not for comfort or convenience. Facilities must be constructed of 

native materials. Mitigation measure 1.b.
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Okanogan-Wenatchee National Forest

MA15B-21S Grazing, hitching, tethering, or hobbling recreation pack and saddle stock within 200 

feet slope distance of the shoreline of any lake shall be prohibited. Mitigation measure 4.a 

specifies that outfitters will comply with all rules and regulations, including 36 CFR 261.57 a 

and e: grazing any pack or saddle animals within 200 feet slope distance of any lake, and 36 

CFR 261.58a; hitching, tethering, or hobbling any pack or saddle animals within 200 feet slope 

distance of any lake. This is repeated in mitigation measure 8i.

MA15B-21T Possessing or transporting unprocessed hay or grain livestock feed shall be 

prohibited. Written exceptions may be granted by the District Ranger upon request for State or 

Federally approved weed-free feed. Mitigation measure 4.a requires compliance with 

regulation 36 CFR 261.58t; possessing or transporting any livestock feed other than processed 

grain.

MA15B-21U All camp structures and facilities shall be temporary in nature and shall be located 

away from main trails, streams, lakes, key interest features, and non-outfitted public use areas. 

Outfitters are only allowed to construct facilities at assigned sites, and the facilities can only 

be for resource protection, not for comfort or convenience. Facilities must be constructed of 

native materials. Mitigation measure 1.b.

MA15B-21V The number and location of reserved (base) camps shall be specified in individual 

special use authorizations, based on the availability of good camp- sites, the needs of the 

outfitter guide, and the needs of the non-outfitted public. The special use authorization shall 

describe allowable structures and facilities, maintenance requirements, and use periods for each 

reserved camp. Assigned sites (reserved) are described in the alternative descriptions and 

evaluated in the Wilderness analysis. In addition, mitigation measure 1.b addresses facilities 

and excess barren core at these campsites.

MAl5B-21W All structures and facilities at outfitter camps shall be dismantled at the end of the 

annual use season. Storage of dismantled structures and facilities may be allowed at locations 

specified in special use authorizations. Outfitters are only allowed to construct facilities at 

assigned sites, and the facilities can only be for resource protection, not for comfort or 

convenience. Facilities must be constructed of native materials. Mitigation measure 1.b.

MA15B-21X Spike camps may be authorized under special use authorizations, but shall be 

unreserved. Mitigation measure 2.h specifies that non-assigned sites are available on a “firstcome, first-served” basis.

MA15B-21Y Management control necessary to protect the ecological and social elements 

throughout the area may be evident outside wilderness, particularly at trailheads and boundary 

portals. This does not apply to outfitter-guide operations.

MA15B-21Z Forest Service information services shall be designed to help meet management 

area objectives rather than to promote use. This does not apply to outfitter-guide operations.

MA15B-21AA Periodic to moderate presence of personnel engaged in monitoring or project 

work may be evident Project work should be scheduled during low use periods where 

practicable. This does not apply to outfitter-guide operations.
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Okanogan-Wenatchee National Forest

Trails

MA15B-21BB Trails shall be constructed, reconstructed, and maintained to the difficulty level 

appropriate to the target user group. Trails should generally be more difficult to most difficult. 

This does not apply to outfitter-guide operations. Mitigation measures 6 a&b prohibit 

outfitters from constructing, placing or maintaining any trails without authorization.

MA15B-21CC Trails or trail segments not necessary to meet area objectives shall be allowed to 

brush in or shall be returned to as near a natural condition as possible. This does not apply to 

outfitter-guide operations.

MA15B-21DD System trails shall not access all attraction features, such as lakes. When trail 

access is constructed to attraction features, only spur trails shall be constructed. This does not 

apply to outfitter-guide operations.

MA15B-21EE User created travel routes shall not be readily apparent or should appear to be 

wildlife trails. There shall be no maintenance of user created travel routes. Average user created 

travel route density shall be less than 0.8 miles per section. Mitigation measures 6 a&b 

prohibit outfitters from constructing, placing or maintaining any trails without authorization. 

User created travel route densities will not change as a result of outfitter-guide activities.

MA15B-21FF User created travel routes shall not be shown on Forest Service maps or trail 

guides. This does not apply to outfitter-guide operations.

MA158-21GG Bridges shall only be provided or replaced when: I) no other route or crossing is

reasonably available, 2) the crossing, during the primary season of public use, cannot be 

negotiated afoot safely, or cannot be forded by horses safely, 3) unacceptable bank damage will 

occur from visitors seeking a crossing, or 4) flood waters frequently destroy or damage less 

sturdy structures. This does not apply to outfitter-guide operations.

MA15B-21HH A maximum of two directional signs with a maximum of two route locations per 

sign may be placed at trail junctions. Distances shall not be provided, except that existing signs 

meeting this direction may remain until replacement is needed. This does not apply to 

outfitter-guide operations.

Fish and Wildlife Standards and Guidelines

MA15B-6A Fish and wildlife indigenous to the wilderness shall be maintained with emphasis on 

Threatened and Endangered Species. This does not apply to outfitter-guide operations.

MA15B-3A In the Pasayten Wilderness, only the following lakes shall be aerially stocked:

Airview Eagle Halfmoon Ramon

Buckskin Fawn Heather Remmel

Cathedral, Lower Ferguson Hidden Remmel, N.

Cathedral, Upper Four Point Hopkin Sheep

Covial Fox Lease Smith

Cougar Freds Peep Sight Tungsten

Crow Frosty Ptarmigan

Dead Glory Quartz
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Okanogan-Wenatchee National Forest

This does not apply to outfitter-guide operations.

MA15B-3B Cleaning of debris that impedes the migratory movements of fish on primary 

spawning streams may be permitted. This does not apply to outfitter-guide operations.

MA15B-6B Visitor use shall not decrease habitat effectiveness for any species by more than 20 

percent. Mitigation measures 11 a-f restrict outfitter-guide operations to ensure compliance 

with this standard and guideline.

MA15B-3C Only those barren waters where scientific and research values will not be eliminated 

shall be considered for stocking. This does not apply to outfitter-guide operations.

MA15B-6C Temporary exclosure structures may be used to determine the impact of wildlife on 

wilderness values. This does not apply to outfitter-guide operations.

MA15B-6D Visitor use shall not displace wildlife from critical areas during critical periods. 

Mitigation measure 11.a prohibits outfitters from feeding, harassing, or disrupting wildlife.

Vegetation Standards and Guidelines

MA15B-22A There should be no long-term modification of natural plant succession as a result of 

human activities on areas outside campsites, administrative sites, and designated trail tread. 

Acceptable modifications are those which can recover in one growing season. The Botany 

analysis found that none of the alternatives would result in a long-term modification of 

natural plant succession.

MA15B-22B Vegetation loss should not exceed 400 square feet (one percent of any acre) at any 

impacted site. This standard and guideline would be amended in each alternative. Refer to 

alternative descriptions on FEIS pages 2-9, 2-12, and 2-15. Outfitter-guide activities would 

comply with amended standard.

MA15B-22C There should be no loss of trees from recreation activities. Mitigation measure 3.b 

prohibits cutting damaging any standing trees, including live trees and snags.

MA15B-22D There should be fewer than four trees with exposed roots per impacted sites. 

Mitigation measure 1.e prohibits outfitters from creating newly exposed roots at any 

campsite. Some existing campsites have more than four trees with exposed roots as a result 

of use prior to implementation of the Forest Plan.

MA15B-22E Standing snags should be left, except where removal is necessary to protect major 

bridges and administrative facilities. Removal of snags during fire suppression efforts shall be 

determined on a case by case basis. This has limited application to outfitter-guides, however 

mitigation measure 3.b prohibits outfitters from cutting snags.

MA15B-22F Vegetative impacts along trails shall be confined to the planned location and to 

meet individual trail objectives. This does not apply to outfitter-guide operations.
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Okanogan-Wenatchee National Forest

MA15B-22G Firewood gathering may be permitted for use on site and shall be limited to dead 

and down material. Firewood gathering shall be restricted where necessary. Use of small fires 

and self-contained stoves shall be encouraged. Mitigation measures 3.a-c regulate outfitterguide collection, use, and storage of firewood. Mitigation measure 5.a requires outfitters to 

follow leave-no-trace practices, which address campfires and stoves.

Range Standards and Guidelines: Planning

MA15B-11A Domestic livestock grazing allotments shall be limited to those allotments under 

permit at the time of the establishment of the wilderness. This does not apply to outfitterguide operations.

MA15B-11B The forage resource shall be utilized in conformance with all wilderness resource 

values. The Range analysis found that outfitter-guide pack stock grazing complies with this 

standard. Refer to FEIS page 356.

MA15B-11C AMPs shall document the need for use of motorized vehicles, motorized 

equipment, or other forms of mechanical transport based on the rule of practical necessity and 

reasonableness. This does not apply to outfitter-guide operations.

Range Standards and Guidelines: Improvements

MA15B-11D New structural and non-structural improvements necessary to protect the range 

and/or wilderness resource, rather than to increase the number of livestock, may be 

constructed. This does not apply to outfitter-guide operations.

MA15B-11E New or existing improvements shall be of materials which harmonize with the 

wilderness character of the areas long as the use of such materials does not greatly increase 

costs to permitees. This does not apply to outfitter-guide operations.

MA15B-11F Existing, necessary range improvements may be maintained. Those determined 

unnecessary shall be phased out. This does not apply to outfitter-guide operations.

Noxious Weeds Standards and Guidelines 

MA15B-12A Noxious weeds may be controlled when they threaten lands outside wilderness or 

when they are spreading within wilderness, provided control is possible without causing serious 

adverse impacts to wilderness values. Mitigation measures 13.a-e prevent the establishment 

and spread of noxious weeds as a result of outfitter-guide activities. 

Soil and Water Standards and Guidelines 

MA15B-13A Displacement and erosion of soil resulting from human activity shall be limited to a 

rate that closely approximates the natural process. The Soil analysis found compliance with 

this standard and guideline. Refer to FEIS page 3-168.

MA15B-13B Soil compaction from human activities should not prevent natural plant 

establishment and growth except at some campsites, administrative facilities, and in designated 

tread. The Soil analysis found compliance with this standard and guideline. Refer to FEIS page 

3-168.
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Okanogan-Wenatchee National Forest

MA15B-13C Human activities should not degrade water quality except for temporary changes 

where water quality returns to its normal level when the activity ceases. The Water Resources 

analysis found compliance with this standard. Refer to FEIS page 3-182.

MA15B-13D The existing level of Big Hidden Lakes shall be retained by maintaining the upper 

diversion ditch and middle diversion dam, using primitive hand methods. No repairs shall be 

made on the lower dam. This does not apply to outfitter guides.

Minerals Standards and Guidelines 

MA15B-15A Access to existing valid claims and/or leases shall be by methods which create the 

least lasting impact on the wilderness resource, while still meeting the needs of the claimant 

and staying within applicable laws and regulations. This does not apply to outfitter guides.

Lands Standards and Guidelines

MA15B-16A The USDI, Geological Survey stream gauging station at Andrews Creek shall be 

removed. This does not apply to outfitter guides.

Facilities Standards and Guidelines

MA15B-18A The War Creek Administrative Site shall not be retained for administrative 

purposes. Management of the War Creek Site shall be determined following a cultural resource 

evaluation. This does not apply to outfitter guides.

MA158-18B The Spanish Camp, Stub Creek, Big Home, and Pasayten Airport Administrative Sites 

shall be retained for administrative purposes. Site plans shall be developed and only necessary 

structures shall be retained. This does not apply to outfitter guides.

MA15B-18C The Pasayten Airstrip shall remain closed to aircraft use The Federal Aviation 

Association shall be encouraged to remove the airstrip from aircraft charts. The airstrip shall be 

allowed to revegetate naturally. This does not apply to outfitter guides.

MA15B-18D Monument 83 and Slate Peak Lookouts should be retained. Additional lookouts 

shall not be constructed. This does not apply to outfitter guides.

MA15B-18E Permanent communication facilities should be retained at Monument 83. 

Additional permanent communication facilities shall not be installed. This does not apply to 

outfitter guides.

MA15B-18F Existing inventoried helispots shall not be improved or maintained and shall be 

allowed to revegetate naturally. This does not apply to outfitter guides.

MA15B-18G Remote automated weather stations shall not be installed. This does not apply to 

outfitter guides.

Protection Standards and Guidelines: Fire and Fuels

MA15B-19A The preferred suppression strategy for lightning caused wildfires is confinement 

The Appropriate Suppression Response Implementation Plan shall be used to confirm that 

confinement is a viable option. A contain or control strategy should be used if wildfires: 1) 

threaten significant cultural resources or capital investments, 2) have the potential to cross the 
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Okanogan-Wenatchee National Forest

U S/Canadian border, 3) threaten Management Areas with more restrictive fire management 

direction, or4) will result in unacceptable off site impacts. This does not apply to outfitter 

guides.

MA15B-19B When containment or control action is the selected fire management strategy, 

wilderness suppression guidelines shall be applied. This does not apply to outfitter guides.

MA15B-19C Planned ignition shall not be used to initiate prescribed fire in wilder- ness areas. 

This does not apply to outfitter guides.

MA15B-19D Prescribed fire ignited by lightning may be used to meet wilderness fire 

management objectives of: 1) reducing the risks and consequences of wild- fire within the 

wilderness or escaping from the wilderness, and 2) permitting lightning caused fires to play, as 

nearly as possible, their natural ecological role within wilderness. This does not apply to 

outfitter guides.

MA15B-19E A prescribed fire plan shall be approved prior to the use of prescribed fire in the 

wilderness. Decisions to declare any lightning fire in the Pasayten Wilderness a prescribed 

natural fire will follow the direction in the Pasayten Wilderness Prescribed Natural Fire Plan. A 

prescribed fire plan shall be approved prior to the use of prescribed fire in the Lake ChelanSawtooth Wilderness. This does not apply to outfitter guides.

Protection Standards and Guidelines: Insect and Disease

MA15B-19F Insect or disease outbreaks shall not be artificially controlled unless it is necessary 

to prevent unacceptable resource damage to resources on adjacent lands or an unnatural loss to 

the wilderness resource. If control becomes necessary, it shall be carried out by measures that 

have the least adverse impact on the wilderness resource and are compatible with wilderness 

Objectives. This does not apply to outfitter guides.

3.3 RECREATION

The section below is a summary of the Recreation Report which is available in the project 

analysis file (Zbyszewski, 2012c).

REGULATORY FRAMEWORK

Wilderness regulations and analysis are discussed in section 3.2 of this chapter. For areas 

outside of wilderness, both the Okanogan and Wenatchee Forest Plans (USDA Forest Service 

1989b and 1990) contain other recreation goals and standards and guidelines. A general goal is 

to encourage, establish, and sustain a diverse and balanced spectrum of quality recreation 

opportunities, services, and facilities. Forest-wide standards and guidelines in the Okanogan 

Forest Plan specifically applying to outfitter-guides are:

8-10 Annual review of recreation special use authorizations shall emphasize health, 

safety, and resource protection (page 4-38).
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8-11 Recreation special use authorizations shall conform with the goals of the 

Management Area (page 4-39).

8-12 Give priority to authorizations needed to provide public service.

The Wenatchee Forest Plan has no forest-wide standards and guidelines specific to outfitterguides, but does give specific direction for outfitter-guides in wilderness. These are included in 

the Wilderness section of Chapter 3

The Northwest Forest Plan and PACFISH, which amended both the Okanogan and Wenatchee 

Forest Plans, include standards and guidelines addressing outfitter-guide activities. The 

standards and guidelines for riparian reserves and riparian conservation areas are discussed in 

the Aquatics section. Those for late successional reserves are discussed in the Terrestrial 

Wildlife section, and those for survey and manage species in Aquatics, Terrestrial Wildlife, and 

Botany. 

Specific regulatory frameworks by management area are discussed below by the five recreation 

subsections below.

ANALYSIS METHODS AND DATA SOURCES

The analysis area is divided into seven sub-sections:

Pasayten Wilderness

Lake Chelan-Sawtooth Wilderness

North Cascades

Sawtooth Backcountry

Bear/Ramsey/Volstead

Middle Methow and

Alta Lake

The Pasayten and Lake Chelan-Sawtooth Wilderness Areas are analyzed in the wilderness 

section of this FEIS; this section focuses on the other portions of the analysis area.

This section analyzes and discloses the effects pack and saddle stock activities have on 

recreation opportunities in each sub-section. Since the outfitter-guides are only a portion of 

overall recreation use (3% off all use and 15% of pack and saddle stock use), the environmental 

effects of all recreation use, and how those effects change with the alternatives, are included in 

the cumulative effects section. 

Pack and Stock Outfitter-Guide Activities

Pack and saddle stock outfitter-guide activities are constantly monitored as part of the special 

use permit administration process (see outfitter-guide monitoring information in the analysis 

file). This process generates information about compliance with permit terms and conditions, 

camp conditions, use patterns, grazing practices, and other permit and resource information. 

This information was used to evaluate effects on recreation, and for compliance with Forest Plan 

standards and guidelines.
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Total Recreation Use Levels

Visitor days used for this analysis were obtained from the National Visitor Use Monitoring 

Results for Okanogan National Forest, (USDA Forest Service 2001d) for the North Cascades, 

Upper Methow, Middle Methow, and Alta Lake. The visitor day estimates for the Sawtooth 

Backcountry are based on trailhead registration and visitor counts. This area was not 

adequately sampled in the National Visitor Use Monitoring Program in 2000, so the use 

estimates were substantially lower than field observations. Refer to the registration and 

observation in the analysis file.

All these areas were sampled again in the 2005 and 2010 National Visitor Use Monitoring 

Program. These data was not disaggregated to give use estimates for the specific sub-sections 

in this analysis, so the 2000 data were used.

Service Days

Use data has been compiled using the most accurate data available. The number of service days 

in the existing pack and saddle stock outfitter-guide permits plus the number of days in the 

priority use pool are used as the current service days. The number of service days actually used 

varies from year to year. Reliable records are available for the past 10 to 20 years. Some data 

gaps and margins of error exist due to data interpretations. Reports of use provided by the 

outfitters occasionally recorded vague or unknown destination locations. The data is the best 

information available, and has a level of accuracy that is more than adequate for this analysis. 

More detailed use data, or data that goes back farther in time, is not essential and is not critical 

to the analysis of recreation attributes. Any improvements to recreation that may be unknown 

as a result of not having more precise data, or data that goes farther back in time, are not likely 

to affect the decision making process. Current conditions and future uses are the most relevant 

factors to consider. 

Comparisons of Outfitted and Non-outfitted Use

The number of service days in the existing pack and saddle stock outfitter-guide permits plus the 

number of days in the priority use pool and the total recreation use information from the 2000 

NVUM survey (USDA, 2001d) were used to calculate the comparisons of outfitted to nonoutfitted use. The number of service days varies from year to year, as does the total number of 

recreationists (outfitter and non-outfitted), so these percentages are merely estimates, and do 

not represent an exact reflection of the relationship between outfitted and non-outfitted use in 

any given year. This is the best available data, however, since the Forest Service calculates 

overall use numbers once every five years. More accurate percentage calculations are not 

essential or critical to the analysis of recreation attributes. Any impacts to recreation that may 

be unknown as a result of not having more precise data are not likely to affect the decision 

making process because they would be localized and minor in context of impacts from overall 

use. Current conditions and future uses are the most relevant factors to consider.

Future Estimates of Recreation Use Levels

The number of visitor days expected in the future was calculated using projected changes 

included in the Washington State Comprehensive Outdoor Recreation Planning (SCORP) 

publication “Estimates of Future Participation in Outdoor Recreation in Washington State” 

(Interagency Committee for Outdoor Recreation 2003). These projected changes were for the 

10-year period between 2004 and 2014. These same figures were applied to the current visitor 

days to generate the anticipated number in 2023.
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Best Available Science

The best available science was used for this analysis, including the methodology and data 

sources described above, to describe the ecological and social conditions within the analysis 

area, and the potential effects of the proposed outfitter-guide use on resources and people.

NORTH CASCADES

Regulatory Framework

This area includes Management Areas 4, 5, 7, 10, 17, and 25, in addition to Late Successional 

Reserves, Administratively Withdrawn, and Riparian Reserves, from the Okanogan Forest Plan, 

as amended by the Northwest Forest Plan. 

The goal for Management Area 4 is to: [p]rovide semi-primitive non-motorized recreation 

opportunities during summer and fall seasons (4-61).

The goal for MA 5 is to: [p]rovide opportunities for recreation and viewing scenery in a roaded 

natural setting with a visual quality objective of retention or partial retention (4-65).

The goal for MA 7 is to: [p]reserve the high quality scenic setting within the North Cascades 

Scenic Highway, while providing recreational opportunities (4- 70).

The goal for MA 10 is to: [o]ptimize habitat condition and perpetuate a healthy mountain goat 

population (4-76).

The goal for MA 17 is to: [p]rovide a variety of developed recreation opportunities in a roaded 

setting (4-98).

The goal for MA 25 is to: [i]ntensively manage the timber and range resources using both evenaged and uneven-aged silvicultural practices (4-103).

Management Area specific standards and guidelines that apply to outfitter guides are:

MA4-8E The numbers and types of encounters between users shall be controlled.

MA7-8F Easy Pass, Rainy Lake, Lake Ann, Blue Lake, and Washington Pass Trails shall be 

closed to horse use.

MA7-11A Recreation livestock grazing shall be permitted except for the meadows at 

Rainy Lake turnoff and Whistler Basin.

There are no specific standards and guidelines pertaining to outfitter-guides in management 

areas 5, 10, 17, or 25.
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Affected Environment

The North Cascades portion of the analysis area includes the area adjacent to the Pasayten 

Wilderness to the south and west, and to the north of the Lake Chelan-Sawtooth Wilderness. It 

includes the North Cascades Scenic Highway Corridor and the Harts Pass area, in addition to 

others. There are about 72,500 visitor days in this area each year; 45% are hiking, 35% are 

driving for pleasure, 5% are riding mountain bikes, and 15% are using pack animals.

Historic Activities

The following past actions have effects that are continuing, and overlapping effects from the 

pack and saddle stock outfitter-guides.

State Route 20

The highway was completed in the early 1970s. Construction of the highway facilitated 

development of recreation in this area, including the use by outfitter-guides permitted here. 

Several recreation sites were constructed shortly after highway completion: six trailheads 

(Canyon Creek, East Creek, Easy Pass, Rainy Pass, Bridge Creek, and Cutthroat Lake); two 

campgrounds (Klipchuck and Lone Fir); the Rainy Pass picnic area; and Washington Pass 

Overlook. Each trailhead has an outhouse, parking area, and bulletin boards. Trails were also 

constructed from these trailheads, or, in some cases, the trailheads tied into existing trails. The 

campgrounds have restrooms, water systems, and campsites with picnic tables and fire grates.

The Washington State Department of Transportation (WSDOT) has maintained the highway 

since it was completed. Maintenance activities have included plowing snow, cleaning ditches, 

maintaining culverts, removing hazard trees, maintaining the road surface, and other ongoing 

highway maintenance activities.

Trails and Trail maintenance

The trails in this area were established by people traveling to popular destinations, such as 

lakes, miners accessing claims, and cattle and sheep grazers and their livestock. The Pacific 

Crest Trail was designated in 1968, and quickly became a popular route. The trails in the area 

have been maintained for decades, and have created this popular recreation area.

Mining

The area, particularly the Harts Pass portion, has a rich history of mining. In the early 1900s, 

gold was discovered in the Slate Creek area, and the towns of Barron and Chancellor were 

established. The gold rush faded within a few years, and the towns were abandoned. Mining 

activity continued, with relatively large exploration and mining activity occurring in the Indiana 

and Allen Basins, and at the Azurite Mine. Small mining operations on placer mines, and surface 

claims also continued. These activities kept roads and trails open that are still used by hikers, 

mountain bike riders, and pack and saddle stock users.

Timber harvest/road construction

Timber harvest and associated road construction has occurred in the Goat Creek area since the 

mid-1900s. The roads provided access for people looking for opportunities to drive, collect 

firewood, mountain bike, and other road-related recreation activities.
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Grazing

Sheep and cattle were grazed in livestock grazing allotments starting in the early 1900s. The 

allotments included Harts Pass Sheep Allotment, Goat Cattle Allotment, and Boulder Allotment. 

The Harts Pass allotment was waived back to the Forest Service in 2000, but the other 

allotments are still active. There are residual and continuing effects to vegetation from grazing 

scattered through the sub-unit, but only area where these effects overlap with current pack and 

saddle stock outfitter guide activities is near the Harts Pass Trailhead. 

Current Conditions

Recreation in the North Cascades Area

The North Cascades area can be divided into six major recreation areas. Map 3.3-1 shows the 

location of these areas. 

North Cascades Scenic Highway

The North Cascades Scenic Highway (State Highway 20) passes through the Methow Valley 

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

and northern portion of the greater Seattle area during the late spring, summer and early 

fall. The Scenic Corridor includes the slopes on either side of the highway, bounded by the 

upper-most ridges as seen from the highway, and includes 89,545 acres. The highway is 

not plowed in the winter, and is typically open to wheeled vehicles from April 30 to 

December 1. The Department of Transportation stops plowing the North Cascades Scenic 

Highway around the first of December, and usually reopens the highway in time for the 

opening day of fishing season at the end of April. Dates vary from year to year depending 

on the weather and snowpack.

Trails and trailheads along the highway corridor are crowded, especially on weekends and 

holidays from the time the snow melts in early June to early July, until late fall. Encounters 

between groups on trails are frequent. The existing amount of parking at trailheads is 

usually adequate to meet the demand, although it is not uncommon for some parking lots 

to fill to capacity at times. The Blue Lake trailhead is often full on weekends and holidays, 

with parking overflowing onto the shoulders of the highway. The Cutthroat Creek trailhead 

is also full from time-to-time, but the long access road between the highway and the 

trailhead (approximately one mile) allows people to park along the access road, and avoid 

parking on the highway shoulders. The other trailhead parking areas are large enough to 

accommodate current use.

Cedar Creek/Early Winters

Cedar Creek/Early Winters is situated west of Highway 20 and east of the highway corridor. 

The Cedar Creek Trail, and trails and roads around the Early Winters Campground and the 

nearby Freestone Inn receive the most use. A current outfitter-guide offers day rides in this 

sub-area that begin and end on private land, but travel onto National Forest System land 

for a portion of the ride.

West Fork Methow

The West Fork Methow area is north of the scenic corridor. The West Fork Methow trail is 

popular for hikers, mountain bikers, and horseback riders. The trail intersects with the 

Pacific Crest Trail about nine miles from the trailhead.
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Harts Pass

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

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

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

trail to the Slate Peak Lookout. The trailheads in are frequently filled beyond capacity on 

weekend days in July and August, resulting in parking overflowing onto the road.

Goat Creek

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

destination is the Goat Peak Lookout, which is located at the end of a 2 1⁄2 trail. There are 

no other trails or trailheads in the area.

Chewuch

A small sliver of land in the Chewuch watershed, adjacent to wilderness is included in this 

area. Several trailheads are located in this section, but use associated with these is within 

the Pasayten. Effects of the alternatives are evaluated and included in the wilderness 

section of this analysis.

Pack and Saddle Stock Outfitter-Guide Activities

Pack and saddle stock outfitter-guides have used the North Cascades area regularly, with 733 

service days. Of these, approximately 168 are overnight pack trips, and 605 are day rides that 

originate from an outfitter’s property. 

Figure 3.3-1. Current Number of Visitor Days by User Group in North Cascades and Number of Pack and 

Saddle Stock Outfitter-Guide Service days.

User Group Total Visitor days Outfitter-guide 

service days

% of Total Visitor Days

Hikers 54,465 0 0%

Driving For Pleasure* 10,675 0 0

Pack and Saddle Stock 

Overnight Use

168

Saddle Stock Day Rides 605

Total Pack and Saddle 

Stock Use

5,415 773 14%

Mountain Bikers 1,945 0 0%

Total 72,500 773 1%

*This figure does not include those driving across the North Cascades Scenic Highway without stopping at 

a trailhead.

Outfitter Camps including Base Camps

Appendix A includes a list of campsites used by pack and saddle stock outfitter guides in this 

area, and a map showing their locations. Outfitters may use other camps but tend to return to 

the same sites. Outfitter-guides currently operate two base camps in the North Cascades, one 

near the Andrews Creek trailhead and one near the Billygoat trailhead. Both camps have 

corrals, unloading ramps, hitch rails, and watering troughs. Though used throughout the 

season, camps are primarily used during the high hunt to house stock being used to service drop 

camps, or as a staging area for multiple groups heading into the Pasayten Wilderness. 
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Environmental Consequences

Direct and Indirect Effects

The following figure shows the number of visitor days and pack and saddle stock outfitter-guide 

days by alternative in the North Cascades Sub-Area. Overall use days, even though they are not 

part of the pack and saddle outfitter-guide effects, are shown to provide context.
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Figure 3.3-2. Number of Visitor Days in the North Cascade by Alternative.

Current or Alternative Pack and 

Saddle Stock 

Users

Hikers Driving For 

Pleasure

Mountain 

Biker Riders

Total

Current

Total Visitor Days 5,415 54,465 10,675 1,945 72,500

Pack and Saddle Stock OG 

Service Days

773

(168 overnight

605 day rides)

0 0 0 773

Percent of total 14% 0% 0% 0% 1%

Alternative 1

Total Visitor Days 4,642 54,465 10,675 1,945 71,727

Pack and Saddle Stock OG 

Service Days

0 0 0 0 0

Percent of total 0% 0% 0% 0% 0%

Percent Change From 

Current Total

-14% 0% 0% 0% -1%

Percent Change From 

Current Service Days

-100%

Alternative 2

Total Visitor Days 5,292 54,465 10,675 1,945 72,377

Pack and Saddle Stock OG 

Service Days

650

(200 overnight

450 day rides)

0 0 0 650

Percent of total 12% 0% 0% 0% 1%

Percent Change From 

Current Total

-2% 0% 0% 0% +0.2%

Percent Change From 

Current Service Days

-16%

Alternative 3

Total Visitor Days 5,182 54,465 10,675 1,945 72,267

Pack and Saddle Stock OG 

Service Days

540

(180 overnight

360 day rides)

0 0 0 540

Percent of total 10% 0% 0% 0% 1%

Percent Change From 

Current Total

-4% 0% 0% 0% -0.3%

Percent Change from 

Current Service Days

-30%

Alternative 4

Total Visitor Days 5,992 54,465 10,675 1,945 73,077

Pack and Saddle Stock OG 

Service Days

1,350

(200 overnight

1,150 day rides)

0 0 0 1,350

Percent of total 19% 0% 0% 0% 2%

Percent Change From 

Current Total

+11% 0% 0% 0% +1%

Percent Change From 

Current Service Days

+75%
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Alternatives 1, 2, 3, and 4

There would be virtually no effect on non-outfitted recreationists, or any noticeable difference 

in the effects of any of the alternatives on recreation. Approximately 66 to 85% of all the pack 

and saddle stock outfitter-guide service days in this sub-section would be for day rides that 

begin and end on private land, and occur on trails seldom used by the non-outfitted public. The 

slight changes in overall use or pack and saddle stock use aside from the day rides associated 

with each alternative would likely go unnoticed by non-outfitted recreationists since the 

changes in use would range from minus 1% to plus 1%. Trails and trailheads would still be 

crowded, especially on weekends and holidays from the time the snow melts in early June to 

early July, until fall. Parking capacity at the trailheads would continue to meet the demand, 

except for occasional days, or time periods. The likelihood that not enough parking would be 

available to meet demand would be greatest in the Harts Pass area. 

Outfitted stock would be prohibited on the Easy Pass, Rainy Lake, Lake Ann, Blue Lake, and 

Washington Pass trails, eliminating conflict with non-stock users (mitigation measure 6.c). 

Outfitted stock would be prohibited from grazing in the meadows by the Rainy Lake turnoff and 

in Whistler basin, eliminating impacts to vegetation in these meadows (mitigation measure 8h). 

Cumulative Effects

The geographic boundary for cumulative effects is the sub-unit boundary, with effects 

considered up to 2023, the length of time of the proposed permits and recreation effects from 

the permits under this analysis would cease. Past actions with effects still overlapping pack and 

saddle stock outfitter-guide use are discussed under Current Conditions. All present, and 

reasonably foreseeable future actions listed at the beginning of this chapter were considered in 

this cumulative effects analysis. Those that overlap pack and saddle stock outfitter-guide effects 

are discussed below.

Present Actions

Road Maintenance

WSDOT maintenance activities include plowing snow, cleaning ditches, maintaining culverts, 

removing hazard trees, maintaining the road surface, and other highway maintenance duties. 

The highway maintenance allows the continued use of the area by recreationists, including the 

outfitter-guides permitted under this analysis, usually from late April until early December.

Trail and Trailhead Maintenance

The Forest Service maintains about 66 miles of trail within the scenic corridor. The trailheads for 

these trails are also maintained in snow-free months. These trails provide access to some of the 

most spectacular scenery in Washington State. The trails also concentrate human use, leaving 

most of the corridor unaltered by human activities.

Campground Maintenance

The Lone Fir, Klipchuck, and Early Winters campgrounds are operated and maintained in snowfree months. The campgrounds have 86 campsites, providing camping for approximately 430 

people. These campgrounds help support the corridor as a destination.
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Outfitter-Guides

There are currently ten additional outfitter-guide special use permit holders operating in the 

sub-unit in the summer season. Over the past 5 years, there has been an average of 450 service 

days from these outfitter-guides, for a cumulative total of 1,223 service days when added to the 

outfitter-guide permits being analyzed in this document. This represents approximately 2% of 

the overall visitor days in this sub-unit. Refer to Figure 3.0-1 on pages 3-4 through 3-6 for 

specific information. 

Non-outfitted Recreation Use

About 71,727 visitor days occur in this area each year, independent of the pack and saddle stock 

outfitter-guides, not including visitors who do not stop on their way along the highway. Nonoutfitted recreational activities included driving for pleasure, hiking, and mountain biking.

Mining

Small mining operations on placer mines and surface claims continue to exist, but have very 

little effect on recreation activities. 

Grazing

The Goat and Boulder Allotments are still active, but there are few trails or established 

campsites within the allotments, so there are no cumulative effects to recreation opportunities. 

Reasonably Foreseeable Future Actions

Road Maintenance

WSDOT will continue to maintain the highway, including plowing snow, cleaning ditches, 

maintaining culverts, removing hazard trees, maintaining the road surface, and other ongoing 

highway maintenance duties. This will continue to provide access to recreationists, including 

the outfitter-guides that would be permitted through this analysis.

Trail and Trailhead Maintenance

The Forest Service will continue to maintain approximately 75 miles of trail within the highway 

sub-unit. The trails concentrate human use, leaving most of the area unaltered by human 

activities.

Campground Maintenance

The Lone Fir, Klipchuck, Early Winters, Harts Pass, and Meadows campgrounds will be operated 

and maintained in snow-free months, providing camping for 525 people at one time.

Outfitter Guides

Existing non-pack and saddle stock outfitter-guides are likely to continue to operate in the 

future, providing hiking, rock climbing, backcountry skills, and other recreational opportunities. 

Non-outfitted Recreation Use

The number of people recreating in the scenic corridor is expected to increase approximately 

100% over the next 10 years, based on the rapid increase between 1992 and 2004. The use in 

the rest of the sub-area is expected to increase at the rate projected in the report by the 

Interagency Committee on Outdoor Recreation (Interagency Committee for Outdoor Recreation, 

2003). The following table displays the approximate number of people expected to be 
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recreating in the sub-unit in 2023, when the outfitter-guide permits being analyzed in this 

analysis would expire. 

Figure 3.3-3. Number of Non-Pack and Saddle Stock Outfitted Visitor Days in the North Cascades 

Currently and Anticipated in 2023

User Group Approximate Current 

Number of Visitor Days

% Increase by 2022 Estimated Number of –

Visitor Days in 2023

Hikers in Scenic 

Corridor*

41,925 +100% 83,850

Hikers in Remainder of 

North Cascades* 

12,540 +13% 14,170

People w/Pack Animals 4,642 +3% 4,781

Driving for Pleasure 10,675 +10% 11,743

Mountain Bike Riders 1,945 +10% 2,140

Total 72,500 116,684

Alternatives 1, 2, and 3

None of the alternatives would have a noticeable or measurable effect on recreation in the 

North Cascades, since the anticipated change in the overall number of people recreating in 

there would be so small (1%). Therefore, there would be no cumulative effect on recreation 

with implementation of Alternative 1, 2, 3, or 4, when considering the past, present, and 

reasonably foreseeable future actions.
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Figure 3.3-4. Cumulative Effect on Visitor Days in the North Cascades Sub-Area with Each Alternative, 

Compared to Current, Projected to 2023 for all Recreation Uses

Current or 

Alternative

Pack and Saddle Stock 

Users

Hikers Driving for 

Pleasure

Mountain 

Bike Riders

Total

Current

Total Visitor Days 5,415 54,465 10,675 1,945 72,500

Visitor Days Outfitted 773 450 0 0 1,223

Percent of total 11% 0.1% 0% 0% 9%

Alternative 1

Total Visitor Days 4,781 98,020 11,743 2,140 116,684

Visitor Days Outfitted 0 450 0 0 450

Percent of total 0% 0.5% 0% 0% 0.4%

Percent Change from 

Current

-11% +80% 10% 10% +61%

Alternative 2

Total Visitor Days 5,431

(4,781+650=5,431)

98,020 11,743 2,140 117,334

Visitor Days Outfitted 650 450 0 0 1,100

Percent of total 12% 0.5% 0% 0% 1%

Percent Change from 

Current

+0.1% +80% 10% 10% +62%

Alternative 3

Total Visitor Days 5,321

(4,781+540=5,321)

98,020 11,743 2,140 117,224

Visitor Days Outfitted 540 450 0 0 990

Percent of total 10% 0.5% 0% 0% 0.1%

Percent Change from 

Current

+1% +80% 10% 10% +62%

Alternative 4

Total Visitor Days 6,671

(4,781+1,350=6,671)

98,020 11,743 2,140 118,034

Visitor Days Outfitted 1,350 450 0 0 1,600

Percent of total 20% 0.5% 0% 0% 1%

Percent Change from 

Current

+24% +80% 10% 10% +63%

Consistency Findings

All alternatives would be consistent with the standards and guidelines that are unique to the 

North Cascades sub-unit, and with those that are applicable to all areas. The unique standards 

and guidelines are address below. The ones applicable to all areas are discussed at the end of 

the Recreation section.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-120 February 2013

Okanogan-Wenatchee National Forest

MA4-8E: The numbers and types of encounters between users shall be controlled.

The number of service days in this sub-unit would be limited to the numbers disclosed in 

Figures 2-1, 2-2, and 2-3, controlling the number of outfitted pack and saddle stock outfitterguide clients and the permitted activities.

MA7-8F: Easy Pass, Rainy Lake, Lake Ann, Blue Lake, and Washington Pass Trails shall be closed 

to horse use.

Mitigation measure 6 c prohibits pack and saddle stock outfitter-guide activities on these 

trails.

MA7-11A: Recreation livestock grazing shall be permitted except for the meadows at Rainy Lake 

turnoff and Whistler Basin.

Mitigation measure 8 h prohibits outfitter-guide stock grazing in these meadows.

SAWTOOTH BACKCOUNTRY

Regulatory Framework

The Sawtooth Backcountry includes Management Area 4M on the Methow Valley District 

(Okanogan Forest Plan), and Management Area RE2a on the Chelan District (Wenatchee Forest 

Plan), as amended by the Northwest Forest Plan.

The Okanogan Forest Plan goals for MA 4M are to: [p]rovide year-round semi-primitive 

motorized recreational opportunities (4-63). The following standard and guidelines applies to 

outfitter-guide use:

MA4M-8E: The numbers and types of encounters between users should be controlled.

The Wenatchee Forest Plan states that the goals of RE2a are to: [p]rovide dispersed, unroaded 

recreation in a semi-primitive motorized recreation opportunity setting (IV-165). The 

Wenatchee Forest Plan has no management area specific management direction for outfitterguides.

Affected Environment

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

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

high-elevation lakes. It receives about 14,000 visitor days annually. There is a mix of motorized 

and non-motorized trail use originating at the Crater Creek or Foggy Dew trailheads on the 

Methow side, and the South Navarre, Safety Harbor Creek, and Summer Blossom trailheads on 

the Chelan side (see Map 1-7).

Use distribution is about 39% (5,460 visitor days) hiking, 18% (2,520 visitor days) use of pack and 

saddle stock (of which 16% has currently outfitted), 33% (4,620 visitor days) riding motorized 

trail bikes, and 10% (1,400 visitor days) riding mountain bikes. None of the hikers, trail bike 

riders, or mountain bike riders are clients of the pack and saddle stock outfitters included in this 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-121 February 2013

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analysis. Of the people who use pack and saddle stock in this area about 20% (800 visitor days) 

are outfitter-guide clients.

Historic Activities

The following past actions have effects that are continuing, and overlapping effects from the 

pack and saddle stock outfitter-guides.

Grazing

The Sawtooth Backcountry was included in commercial sheep and cattle grazing allotments 

beginning in the early 1900s. Large bands of sheep grazed the area annually. Many of the 

existing, large camps were established by the sheep herders. Some stock driveways and trails 

became popular hiking and riding trails.

Recreation and Trail Maintenance

People have been hiking and riding horses or motorcycles into this area for decades. The 

recreation use, combined with commercial grazing, established trails to the lakes and scenic 

destination points in the area. Some of these trails were identified as system trails, and have 

been maintained by the public and Forest Service.

Current Condition

Recreation Activities

The motorized bike trail system is a popular destination. Most people stay in or near the Foggy 

Dew campground and ride on loop trails that include the Foggy Dew trail, the Martin Creek trail 

to the Crater Creek trailhead, and the Forest Service road designated for dual use to bring riders 

back to the Foggy Dew campground. Most motorized bike use is day use.

The Crater Creek trailhead is often filled to capacity on weekends and holidays between 

Memorial Day and Labor Day. Encounters between groups along the trail network and 

destination locations are common. The most popular destination spots are the high elevation 

lakes in the area. It is a popular area for big groups since there are no party-size limitations. 

Some of the existing camps are large, but there are no standards and guidelines pertaining to 

the size or condition of these campsites, which are outside of wilderness.

Outfitter-Guide Activities

This area is regularly used by the pack and saddle stock outfitter guides, with 394 service days in 

the current permits and priority use pool. 

Figure 3.3-5. Current Number of Visitor Days by User Group in the Sawtooth Backcountry, and Number 

of Pack and Saddle Stock Outfitter-Guide Visitor days.

Use Group Total Visitor Days Outfitter-guide 

Service Days

Portion of Total

Hikers 5,460 0 0%

Use with Pack Animals 2,520 394 16%

Trail Bike Riders 4,620 0 0

Mountain Bikers 1,400 0 0

Total 14,000 394 3%
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Environmental Consequences

Direct and Indirect Effects

The following figure shows the number of visitor days, and pack and saddle stock outfitter-guide 

days by alternative in the Sawtooth Backcountry Sub-Area. Overall use days, even though they

are not part of the pack and saddle outfitter-guide effects, are shown to provide context.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-123 February 2013

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Figure 3.3-6. Number of Visitor Days and Service Days in the Sawtooth Backcountry Currently and by 

Alternative.

Current or Alternative Pack and Saddle 

Stock Users

Hikers Trail Bike 

Riders

Mountain 

Biker Riders

Total

Current

Total Visitor Days 2,520 5,460 4,620 1,400 14,000

Pack and Saddle Stock OG 

Service Days

394 0 0 0 394

Percent of total 16% 0% 0% 0% 3%

Alternative 1

Total Visitor Days 2,126 5,460 4,620 1,400 13,606

Pack and Saddle Stock OG 

Service Days

0 0 0 0 0

Percent of total 0% 0% 0% 0% 0%

Percent Change From 

Current Total

-16% 0% 0% 0% -3%

Percent Change From 

Current Service Days

0%

Alternative 2

Total Visitor Days 2,526 5,460 4,620 1,400 14,006

Pack and Saddle Stock OG 

Service Days

400 0 0 0 400

Percent of total 16% 0% 0% 0% 3%

Percent Change From 

Current Total

0.2% 0% 0% 0% 0%

Percent Change From 

Current Service Days

+2%

Alternative 3

Total Visitor Days 2,286 5,460 4,620 1,400 13,766

Pack and Saddle Stock OG 

Service Days

160 0 0 0 160

Percent of total 7% 0% 0% 0% 1%

Percent Change From 

Current Total

-9% 0% 0% 0% -1%

Percent Change From 

Current Service Days

-59%

Alternative 4

Total Visitor Days 2,931 5,460 4,620 1,400 14,441

Pack and Saddle Stock OG 

Service Days

805 0 0 0 805

Percent of total 27% 0% 0% 0% 6%

Percent Change From 

Current Total

+16% 0% 0% 0% +3%

Percent Change From 

Current Service Days

+104%
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-124 February 2013

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Alternative 1

With implementation of Alternative 1, there would be no pack and saddle stock outfitter-guide 

activity in the Sawtooth Backcountry, reducing current use by 394 visitor/service days. This 

would result in a 16% reduction in pack and saddle stock use from current conditions, which 

may be noticed by some non-outfitted recreationists, but since the overall recreational use 

reduction is only 5%, fewer encounters on trails and at popular destinations may go unnoticed.

Pack and Saddle Outfitter-Guides would no longer have any effects at camps, and all camps 

would be open and available to non-outfitted recreationists. 

Alternative 2

This alternative would basically maintain the existing number of people in the Sawtooth 

Backcountry, slightly increasing permitted use by 1% over the currently permitted use (14,006 as 

opposed to the existing 14,000). There would be 400 service days for pack and saddle stock 

outfitter-guides in the Sawtooth Backcountry. 

The pack and saddle stock outfitter-guides would continue to operate in the area, and nonoutfitted recreationists would likely encounter them at the established campsites and along the 

trails leading to the campsites. Peoples’ opportunity to experience isolation on the trails and at 

destination spots would remain similar to the current condition. The number of encounters 

with outfitters would be controlled since the number of service days would be limited to 400 

service days annually. The outfitter-guides would likely cause little change in campsite 

conditions because the number of service days would be very close to the current allowed use. 

However, since there are no restrictions on camps and camps sizes in the Sawtooth 

Backcountry, outfitted use may result in an increase in size, and new camps may be developed 

in the future.

Alternative 3

Alternative 3 would decrease permitted use in the Sawtooth Backcountry to 160 days, a 

decrease of 59% from the current permitted use. In context of total use, there would be a 9% 

reduction in pack and saddle stock use (outfitted and non-outfitted) in the area, and an overall 

reduction in visitor days of approximately 1%. 

Non-outfitted recreationists would have fewer encounters with outfitted groups because of the 

decline in service days compared to the current condition, or compared with Alternatives 2 and 

4. Outfitters would continue to use established campsites, but would likely not increase the size 

of existing sites, or create new ones. Non-outfitted recreationists would have more chance of 

experiencing isolation on trails and at popular destinations compared to the current condition, 

or Alternatives 2 or 4. The number of encounters with outfitters would be controlled since the 

number of service days would be limited to 160 service days annually.

Alternative 4

Alternative 4 would increase permitted use in the Sawtooth Backcountry to 805 days of 

permitted use, an increase of 104% over current permitted use. Comparing this to current 

conditions, this would result in a 16% increase in pack and saddle stock use, and a 3% increase in 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-125 February 2013

Okanogan-Wenatchee National Forest

all visitor days. Even though overall increases in encounter rates would most likely not be 

noticed, people would encounter more stock parties with this alternative compared to the 

existing condition. 

As with Alternatives 2 and 3, the pack and saddle stock outfitter-guides would continue to 

operate in this area. Non-outfitted recreationists would have a noticeable increase in 

encounters with outfitted parties on trails and at destination locations compared to the current 

condition, or with Alternatives 2 or 3. There would be a decrease in the possibility of 

experiencing isolation on trails and popular destinations. The existing camps would continue to 

be used by the outfitters. Since there are no restrictions on camps and camp sizes in the 

Sawtooth Backcountry, outfitted use may result in an increase in size, and new camps may be 

developed in the future.

Cumulative Effects

The spatial boundary for this recreation analysis is the entire Sawtooth Backcountry and the 

trails and trailheads leading into the Sawtooth Backcountry. The temporal boundary was from 

the early 1900s through 2023, when the 10-year permits would expire and all recreation effects 

from the permits would cease. Past actions with effects still overlapping pack and saddle stock 

outfitter-guide use are discussed under Current Conditions. All present and reasonably 

foreseeable future actions listed at the beginning of this chapter were considered in this 

cumulative effects analysis. Those that affect recreation are discussed below.

Present Actions

Trail Maintenance

The Forest Service maintains approximately 60 miles of trail in the Sawtooth Backcountry 

annually. This is allowing trail users to continue accessing the destination spots throughout the 

area.

Non-outfitted Recreation Use

Approximately 13,606 visitor days occur in the Sawtooth Backcountry each year, not including 

the pack and saddle stock outfitter-guides.

Outfitter-guides

National Outdoor Leadership School operates in the Sawtooth Backcountry under an outfitterguide special use permit. They guide clients on hiking/backpacking trips. An additional 200 

service days are available for temporary outfitter-guide use. In recent years, these days have 

been allocated to a mountain bike outfitter guide, additional hiking/backpacking guides, and 

trail running.

Reasonably Foreseeable Future Actions

Trail Maintenance

It is reasonably foreseeable that the Forest Service will continue maintaining approximately 60

miles of system trails throughout the area. This keep access open to the destination spots in the 

area.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-126 February 2013

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Non-outfitted Recreation Use

The number of people recreating in the Sawtooth Backcountry is expected to increase 12% by 

2022, when the outfitter-guide permits would expire. This is the rate projected in the report by 

the Interagency Committee on Outdoor Recreation (Interagency Committee for Outdoor 

Recreation, 2003). 

Figure 3.3-7 lists the current number of non-outfitted pack and saddle stock-outfitted 

recreationists and the estimated number for 2023.

Figure 3.3-7. Number of Non-Pack and Saddle Stock-Outfitted Visitor Days in Sawtooth Backcountry 

Currently and in 2023.

User Group Approximate Current 

Number of Non Outfitted 

Visitor Days

% Increase by 

2022*

Estimated Number of Non 

Pack and Saddle Stock –

Outfitted Visitor Days in 

2023

Hikers 5,460 +13% 6170

People w/Pack Animals 2,520 +3% 2,596

Trail Bike Riders 4,620 +10% 5,082

Mountain Bike Riders 1,400 +10% 1,540

Total 13,606 +11 15,388

*Interagency Committee for Outdoor Recreation 2003

The following figure displays the cumulative effect on visitor days for each alternative.
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Figure 3.3-8. Cumulative Effect on Visitor Days in the Sawtooth Backcountry Sub-Area with Each 

Alternative, Compared to Current, Projected to 2023 for all Recreation Uses

Current or 

Alternative

Pack and Saddle 

Stock Users

Hikers Trail Bike 

Riders

Mountain 

Bike Riders

Total

Current

Total Visitor Days 2,520 5,460 4,620 1,400 14,000

Pack and Saddle 

Stock OG Service 

Days

394 0 0 0 394

Percent of total 16% 0% 0% 0% 3%

Alternative 1

Total Visitor Days 2,202 6,170 5,082 1,540 14,994

Visitor Days 

Outfitted

0 0 0 0 0

Percent of total 0% 0% 0% 0% 0%

Percent Change 

from Current

-13% +13% 10% 10% +7%

Alternative 2

Total Visitor Days 2,602

(2,202+400=2,602)

6,170 5,082 1,540 15,394

Visitor Days 

Outfitted

400 0 0 0 400

Percent of total 15% 0% 0% 0% 3%

Percent Change 

from Current

+3% +13% 10% 10% +10%

Alternative 3

Total Visitor Days 2,362

(2,202+160=2,362)

6,170 5,082 1,540 15,154

Visitor Days 

Outfitted

160 0 0 0 160

Percent of total 7% 0% 0% 0% 1%

Percent Change 

from Current

-6% +13% 10% 10% +8%

Alternative 4

Total Visitor Days 3,007

(2,202+805=3,007)

6,170 5,082 1,540 15,799

Visitor Days 

Outfitted

805 0 0 0 805

Percent of total 27% 0% 0% 0% 6%

Percent Change 

from Current

+22% +13% 10% 10% +13%
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-128 February 2013

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Alternative 1

The cumulative effect of past, present, and reasonably foreseeable future actions on recreation 

activities would be a 7% increase in the overall number of people recreating, but an 13% 

decrease in the number of pack and saddle stock use. The overall increase would likely not be 

noticed by the people recreating there, but people may notice fewer stock parties. People 

would still encounter large pack and saddle stock groups on the trails and at destination spots. 

The camps would remain at the existing size, or possibly increase over time as a result of 

projected general increases in recreation.

Alternative 2

The cumulative effect Alternative 2 and the past, present, and reasonably foreseeable future 

actions on recreation activities would be a 10% increase in the overall number of people 

recreating in the area, including a 3% increase in pack and saddle outfitter-guide use. The 

increase would be larger than with Alternative 1, and people may encounter more groups in the 

area compared to the existing condition. This would make the area feel more crowded 

compared to the existing condition. 

The effect of this amount of use on the Sawtooth Backcountry would be that people would have 

a moderate chance of experiencing isolation on the trails and at popular destinations. Use 

would be concentrated on trails, and generally in established campsites. The existing camps 

would continue to be used by outfitters and outfitted recreationists. The conditions in these 

camps may change because there are no restrictions on camps and camp sizes in the Sawtooth 

Backcountry, outfitted use may result in an increase in size, and new camps may be developed 

in the future.

Alternative 3

The cumulative effect Alternative 3 and the past, present, and reasonably foreseeable future 

actions on recreation activities would be an 8% increase in the overall number of people 

recreating in the area, but a 6% decrease in the number of pack and saddle stock users in the 

area. People may not notice the small changes in overall recreation use, so the current 

recreation experience and opportunities would not change. 

People would have a reduced chance of seeing pack and saddle stock groups, but since the 

overall increase in use would be 8%, the chance of experiencing isolation on the trails and at 

popular destinations would change little from current conditions. Use would be concentrated 

on trails and generally in established campsites. Existing camps would continue to be used by 

outfitters and outfitted recreationists. The conditions in these camps may change because 

there are no restrictions on camps and camp sizes in the Sawtooth Backcountry, outfitted use at 

these camps may increase their size and new camps may be developed in the future.

Alternative 4

The cumulative effect of Alternative 4 and the past, present, and reasonably foreseeable future 

actions on recreation activities would be the largest increase in recreation use of any alternative 

because of the incremental effect of additional pack and saddle outfitter-guide use on top of 

projected increases in recreational use of this area over time. There would be approximately 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-129 February 2013

Okanogan-Wenatchee National Forest

13% more people overall, and 19% more stock users. This would be a noticeable change for 

most users. 

The effect of this amount of permitted use on the Sawtooth Backcountry would be that people 

would have a moderate chance of experiencing isolation on the trails and at popular 

destinations. Use would be concentrated on trails, and generally in established campsites. The 

existing camps would continue to be used by outfitted and non-outfitted recreationists. The 

conditions in these camps could increase in size, and new camps may be developed in the 

future.

Consistency Finding

All alternatives would be consistent with the standards and guidelines that are unique to the 

Sawtooth Backcountry sub-unit, and with those that are applicable to all areas. The unique 

standards and guidelines are address below. The ones applicable to all areas are discussed at 

the end of the Recreation section.

MA4M-8E: The numbers and types of encounters between users should be controlled.

The number of service days in this sub-unit would be limited to the numbers disclosed in 

Figures 2-1, 2-2, and 2-3, controlling the number of outfitted pack and saddle stock outfitterguide clients and the permitted activities.

BEAR/RAMSEY/VOLSTEAD

Regulatory Framework

This area includes Okanogan Forest Plan Management Areas 14, 25, and 26, as amended by 

PACFISH (see Aquatics section for PACFISH regulatory framework). The goal for MA 14 is to: 

[p]rovide a diversity of wildlife habitat, including deer winter range, while growing and 

producing merchantable wood fiber (4-83).

The goal for MA 25 is to: [i]ntensively manage the timber and range resources using both evenaged and uneven-aged silvicultural practices (4-103).

The goal for MA 26 is to: [m]anage deer winter range and fawning habitats to provide 

conditions which can sustain optimal numbers of deer indefinitely, without degrading habitat 

characteristics such as forage, cover, and soil (4-107).

The Okanogan Forest Plan has no management area specific standards and guidelines for 

recreation applicable to outfitter-guides in theBear/Ramsey/Volstead sub-area.

PACFISH has a standard and guideline that applies to recreation, which is analyzed in the 

Aquatics section of Chapter 3. 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-130 February 2013

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Affected Environment

The Bear/Ramsey/Volstead area is located east of the Methow River. There are about 1,000 

annual visitor days in this portion of the analysis area. There are no developed trailheads or 

trails used by pack and saddle stock outfitter-guides in this area.

Historic Activities

The following past actions have effects that are continuing, and overlapping effects from the 

pack and saddle stock outfitter-guides.

Timber sales/road construction

There have been numerous timber sales in the area over the past several decades. The roads 

constructed for these sales created opportunities that still exist for people to drive for pleasure, 

hunt, collect firewood, ride bikes, access hiking trails, and camp in undeveloped areas.

Current Condition

About 90% of recreation takes place during hunting season, with hunters hiking along the 

seasonally-closed road system or across hillsides. Although there are no developed recreation 

sites, some hunters set up dispersed camps in areas before roads are closed on October 1st of 

each year, or camp just outside the motorized closure area (about 70% of the use). About 20% 

pack camps into the motorized closure area, hiking or using pack and saddle stock. The 

remaining 10% of the annual use is people driving for pleasure in the area outside hunting 

season.

Dividing the visitor days between the types of recreation, there are 700 camping visitor days 

outside the motorized closure area, or having driven and set up a campsite prior to the closure. 

An additional 200 visitor days are people who pack camps into the motorized closure area either 

hiking or using pack and saddle stock. The remaining 100 people are driving for pleasure outside 

hunting season. Of the 200 who pack in camps, 48 visitor days have been associated with pack 

and saddle stock outfitter-guides.

Outfitter-Guide Activities

Pack and saddle stock outfitter-guide use in this area has been during the mule deer general 

firearm season each October. Outfitter-guides pack clients to camps in areas closed to 

motorized recreation during hunting season. These are all drop camps, with the outfitter-guides 

returning to pack the clients out at the end of the trip. There were 48 pack and saddle stock 

outfitter-guide service days in the Bear/Ramsey/Volsted area. 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-131 February 2013

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Figure 3.3-9. Current number of Visitor Days in Bear/Ramsey/Volstead by Use Group, and Number of 

Pack and Saddle Stock Outfitter-Guide Visitor days.

Use Group Total Visitor days OutfitterGuide Service 

Days

% of Total

Hunters camping outside closed area, or 

setting up camps early

700 0 0%

Hunters packing in camps using pack 

animals or hiking

200 48 24%

People driving for pleasure 100 0 0

TOTAL 1,000 48 5%

The Lightning Creek dispersed drop camp has been used during the general hunting season; it is 

one of the known camps used by pack and saddle stock outfitter guides in the 

Bear/Ramsey/Volstead area. There is also an established dispersed campsite in the Volstead 

Creek area. Outfitters may have used other camps periodically, but tended to return to these 

two sites.

Environmental Consequences

Direct and Indirect Effects

The following figure shows the number of visitor days, and pack and saddle stock outfitter-guide 

days by alternative in the Bear/Ramsey/Volstead Sub-Area. Overall use days, even though they 

are not part of the pack and saddle outfitter-guide effects, are shown to provide context.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-132 February 2013

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Figure 3.3-10. Number of Visitor days in Bear/Ramsey/Volstead area by Alternative.

Current or Alternative Hunters Packing in 

Camps with Pack 

and Saddle Stock 

or Hiking

Hunters Camping 

Outside Closure or 

Setting Up Camp 

Prior to Closure

Driving for 

Pleasure

Total

Current

Total Visitor Days 200 700 100 1,000

Pack and Saddle Stock OG 

Service Days

48 0 0 48

Percent of total 24% 0% 0% 3%

Alternative 1

Total Visitor Days 152 700 100 952

Pack and Saddle Stock OG 

Service Days

0 0 0 0

Percent of total 0% 0% 0% 0%

Percent Change From Current 

Total

-24% 0% 0% -5%

Percent Change from Current 

Service Days

-100%

Alternative 2

Total Visitor Days 252 700 100 1,052

Pack and Saddle Stock OG 

Service Days

100 0 0 100

Percent of total 40% 0% 0% 10%

Percent Change From Current 

Total

26% 0% 0% 5%

Percent Change From Current 

Service Days

+108%

Alternative 3

Total Visitor Days 202 700 100 1,002

Pack and Saddle Stock OG 

Service Days

50 0 0 50

Percent of total 25% 0% 0% 5%

Percent Change From Current 

Total

0% 0% 0% 0%

Percent Change From Current 

Service Days

+4%

Alternative 4

Total Visitor Days 252 700 100 1,052

Pack and Saddle Stock OG 

Service Days

100 0 0 100

Percent of total 40% 0% 0% 10%

Percent Change From Current 

Total

26% 0% 0% 5%

Percent Change From Current 

Service Days

108%
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-133 February 2013

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Alternative 1

Non-outfitted hunters could notice a reduction in the number of camps packed into the 

motorized closure area with implementation of Alternative 1 since there would be no pack and 

saddle stock outfitter-guide activity and 48 fewer visitor days than the existing condition. 

Outfitter-guides would have no effect on the recreational experience of this area, although this 

alternative would eliminate use by hunters who do not have the ability to hike or pack 

themselves into the area.

Alternatives 2 and 4

Alternatives 2 and 4 would both permit 100 visitor days, increasing pack and saddle stock 

outfitter-guide permitted use by 52 days, an increase of over 100% from the existing condition. 

This would allow outfitters to meet demand for recreationists either needing or desiring packing 

services to access this non-motorized hunting area. This additional use by outfitters may lead to 

the creation of new camps, and increased encounters between groups, but would not likely 

impact the quality of hunting because the overall increase is so small (see cumulative effects). 

Alternative 3

Alternative 3 would increase permitted use by 2 days from the existing, essentially resulting in 

no change. The number of people in the area, and the number packed into camps in the nonmotorized area would not change from the existing condition. Established camps would still be 

available, and very few new ones would be established. 

Cumulative Effects

The spatial boundary for this analysis is the entire Bear/Ramsey/Volstead area. The temporal 

boundary was from the early 1900s through 2023, when the 10-year permits would expire, and 

the effects of the permits would cease.

Past actions with effects still overlapping pack and saddle stock outfitter-guide use are discussed 

under Current Conditions. All present and reasonably foreseeable future actions listed at the 

beginning of this chapter were considered in this cumulative effects analysis. Those that affect 

recreation are discussed below.

Present Actions

Timber sales/road maintenance

There are no active timber sales in this area. Maintenance of the existing roads is ongoing, and 

keeping the existing recreation activities available.

Seasonal closures

This area is closed to motorized access from October 1 to March 31 to protect mule deer in the 

fall and, as a result it provides a non-motorized hunting area. This eliminates motorized hunting 

activities, and provides opportunities for pack and saddle stock outfitter-guides to provide 

services to clients who want to camp in the non-motorized area.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-134 February 2013

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Non-outfitted Recreation Use

Approximately 952 visitor days occur in the Bear/Ramsey/Volstead area each year, independent 

of the pack and saddle stock outfitter-guides. This use, combined with the pack and saddle 

stock outfitter-guide clients, makes up the total current recreation visitor days in the sub-unit. 

This use overlaps the pack and saddle stock outfitter-guide activities, but the cumulative use is 

very light, and is not degrading the quality of recreation opportunities in the area.

Grazing

The Ramsey and Beaver Horse and Cattle allotments are active and currently grazed. There 

Currently 110 cow/calf pairs graze the Volstead unit from late June to early August with a total 

of 186 AUMs. There are currently 322 AUMs in this area under a new AMP completed in 2007.

Reasonably Foreseeable Future Actions

Timber sales/road maintenance

There are no reasonably foreseeable timber sales in the area, however road maintenance will 

continue. This will maintain the existing recreation activities.

Grazing

The Ramsey and Beaver allotments will continue to be grazed at the current stocking level. 

Since the pack and saddle stock outfitter-guides do not loose graze their stock in this area, there 

would be no overlap of effects to forage utilization. 

Non-outfitted Recreation Use

The number of people recreating in the Bear/Ramsey/Volstead area is expected to decrease 

15% by 2022, dropping to approximately 834 visitor days per year, as projected by the 

Interagency Committee on Outdoor Recreation (Interagency Committee for Outdoor Recreation, 

2003). 

The following figure lists the current number of non-pack and saddle stock-outfitted 

recreationists, and the number that will likely be there in 2023.

Figure 3.3-11. Number of Non-Pack and Saddle Stock-Outfitted Visitor Days in Bear/Ramsey/Volstead 

Currently and in 2023.

User Group Approximate Current 

Number of Non Pack and 

Saddle Stock-Outfitted 

Visitor Days

% Change by 

2022*

Estimated Number of 

Non Pack and Saddle 

Stock –Outfitted Visitor 

Days in 2023

Hunters camping outside 

closed area, or setting up 

camps early

700 -6% 658

Hunters packing in camps 

using pack animals or hiking

152 -6% 143

People Driving for Pleasure 100 +10% 110

TOTAL 1,000 911

*Interagency Committee for Outdoor Recreation 2003

The following figure shows the cumulative effect on the number of people recreating in this subunit, by alternative.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-135 February 2013

Okanogan-Wenatchee National Forest

Figure 3.3-12. Cumulative Effect Number of Visitor days in Bear/Ramsey/Volstead area by Alternative.

Current or Alternative Hunters Packing in 

Camps with Pack 

and Saddle Stock 

or Hiking

Hunters Camping 

Outside Closure or 

Setting Up Camp 

Prior to Closure

Driving for 

Pleasure

Total

Current

Total Visitor Days 200 700 100 1,000

Pack and Saddle Stock OG 

Service Days

48 0 0 48

Percent of total 24% 0% 0% 3%

Alternative 1

Total Visitor Days 140 658 110 908

Pack and Saddle Stock OG 

Service Days

0 0 0 0

Percent of total 0% 0% 0% 0%

Percent Change From Current 

Total

-30% -6% +10% -9%

Alternative 2

Total Visitor Days 240 658 110 1,008

Pack and Saddle Stock OG 

Service Days

100 0 0 100

Percent of total 42% 0% 0% 10%

Percent Change From Current 

Total

20% -6% +10% +0.1%

Alternative 3

Total Visitor Days 190 658 110 958

Pack and Saddle Stock OG 

Service Days

50 0 0 50

Percent of total 26% 0% 0% 5%

Percent Change From Current 

Total

-5% -6% +10% -4%

Alternative 4

Total Visitor Days 240 658 110 1,008

Pack and Saddle Stock OG 

Service Days

100 0 0 100

Percent of total 42% 0% 0% 10%

Percent Change From Current 

Total

20% -6% +10% +0.1%

Alternative 1

The cumulative effect of Alternative 1 and the past, present, and reasonably foreseeable future 

actions would a 9% reduction in the number of people recreating in the area. This reduction 

would mostly occur during hunting season. The area would likely seem less crowded to the 

hunters, making camping spots easier to find, potentially fewer encounters with other hunters, 

and may improve the hunting experience.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-136 February 2013

Okanogan-Wenatchee National Forest

Alternatives 2 and 4

The cumulative effect of Alternatives 2 and 4, and the past, present, and reasonably foreseeable 

future actions would be virtually no change in the number of people recreating in the area 

compared to the current condition. There would be a 20% increase in outfitter-guide service 

days, therefore an increase in the number of people being packed into hunting camps in the 

non-motorized hunting area. The number of people hunting and camping in the area would still 

be small, and hunters and camps would be dispersed across hillsides and along roads, so the 

area would not feel crowded. The small increase may lead to creation of new camps, and the 

encounters between groups may increase.

Alternative 3

The cumulative effect of Alternative 3 would also be a 4% reduction in the number of people 

recreating in the area. This would likely be unnoticed by most people. The number of outfitterguide service days would be increased by 2 over the current condition, so there would be 

virtually no change in the number of people being packed into hunting camps. The area would 

remain uncrowded with a high quality hunting experience

Consistency Findings

Other than the Forest-wide findings at the end of this recreation section, no management area 

specific findings are required because the management areas in the Bear/Ramsey/Volstead SubArea contain no standards and guidelines specific to recreational use.

MIDDLE METHOW

Regulatory Framework

This subsection is divided between Management Areas 5, 10, and 25, in the Okanogan Forest 

Plan, as amended by the Northwest Forest Plan. These Management Areas are shown Map 1-9.

The goal for MA 5 is to: [p]rovide opportunities for recreation and viewing scenery in a roaded 

natural setting with a visual quality objective of retention or partial retention (4-65).

The goal for MA 10 is to: [o]ptimize habitat condition and perpetuate a healthy mountain goat 

population (4-76).

The goal for Management Area 25 is to: [i]ntensively manage the timber and range resources 

using both even-aged and uneven-aged Silvicultural practices (4-103).

Okanogan Forest Plan has no management area specific recreation standards and guidelines 

that apply to outfitter-guides. 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-137 February 2013

Okanogan-Wenatchee National Forest

Affected Environment

The Middle Methow portion of the analysis area includes the area east of the Lake ChelanSawtooth Wilderness and east of the Sawtooth Backcountry. There are about 15,000 annual 

visitor days in this area. About 10% are hiking, 80% are driving for pleasure, 5% are riding 

mountain bikes, and 5% are using pack animals. 

There are two major recreation areas in the Middle Methow. These are shown on Map 3.3-2.

The Twisp River corridor is surrounded by the Lake Chelan-Sawtooth Wilderness. Nearly all 

the trails that begin at trailheads in the corridor enter wilderness within one mile. Use on 

these trails is included in the use estimates for the Lake Chelan-Sawtooth Wilderness. The 

Twisp River Horse Camp is a popular campground specifically designed for people with 

horses and mules. This area also includes several campgrounds, and the Twisp River Trail, 

which goes from War Creek Campground to Gilbert Trailhead. None of the use in the horse 

camp, campgrounds, or on the Twisp River trail is outfitted. There is an outfitter base camp 

at the Slate Creek Trailhead. The only improvement is a corral, which is closed to nonoutfitted recreationists. 

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

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

enters wilderness about two miles from the trailhead. The Crater Creek and the Foggy Dew 

trailheads are located in the Gold Creek portion of the analysis area. Both these trails enter 

the Sawtooth Backcountry less than a mile from the trailheads. The use of these trails in 

included in the Sawtooth Backcountry descriptions. There is an assigned outfitter camp 

located near the Crater Creek trailhead. The outfitter takes clients into the Sawtooth 

Backcountry from this camp.

There are no service days for outfitters within the Middle Methow area. Outfitters use the 

trailheads to access the Lake Chelan-Sawtooth Wilderness and the Sawtooth Backcountry, but 

none of the use is considered to be in the Middle Methow. The effect of the alternatives from 

outfitter-guide activities in the Lake Chelan-Sawtooth Wilderness are discussed in the 

Wilderness section of Chapter 3. The effects on the Sawtooth Backcountry are discussed earlier 

in this section. 

Outfitter Activities

Service days are assigned to areas where outfitter-guide parties camp, so there are no outfitterguide service days in the Middle Methow area. The only outfitter activities in this area have 

been trips beginning at the trailheads, and the base camps at Slate and Crater Creek Trailheads. 

The camp at Slate Creek has a corral and access road. The Crater Creek camp has an access 

road, unloading ramp, hitch rails, watering trough, corrals, and parking area. Non-outfitted 

recreationists are not allowed to use these facilities. Only one of the pack and saddle stock 

outfitters uses the Crater Creek base camp – the other outfitters park in the Crater Creek 

Trailhead parking area.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-138 February 2013

Okanogan-Wenatchee National Forest

Figure 3.3-13. Current number of Visitor Days by Use Group in the Middle Methow Area, and Number 

of Pack and Saddle Stock Outfitter-Guide Service days.

Use Group Total Visitor days Outfitter-guide Service 

and Visitor Days

% of Total

Hikers 1,500 0 0%

Driving for Pleasure 12,000 0 0%

Use w/Pack and Saddle 

Stock

750 0 0%

Mountain Bike Riders 750 0 0%

TOTAL 15,000 0 0%

Environmental Consequences

Direct and Indirect Effects

There would be no pack and saddle stock outfitter-guide service days in the Middle Methow 

with any alternative; current use would not change.

Alternative 1

With Alternative 1,no permits would be issued and the outfitter-guides would cease operating. 

Although the pack and saddle stock outfitter-guides do not have any service days in this subunit, people recreating in this area would likely notice a reduction in use at the trailheads and 

the number of pack and saddle stock on the trails. 

Alternatives 2

The pack and saddle stock outfitter-guides would continue to use the trailheads and trails 

leading into the Sawtooth Backcountry and the Lake Chelan-Sawtooth Wilderness with 

implementation of Alternative 2. There would be some changes in the amount of use (2% 

increase in the Sawtooth Backcountry, and a 0.7% increase in the Lake Chelan-Sawtooth), but 

these are small enough to likely not be noticed by the non-outfitted recreationists. The effects 

of these changes in the two areas are discussed in those specific sections of this chapter.

The base camps at the Slate Creek Trailhead and Crater Creek Trailhead would still be used by 

the outfitters, but would remained closed to the public. 

Alternative 3

Alternative 3 would result in less outfitter-guide activities at the trailheads and along the trails 

leading into the Sawtooth Backcountry and Lake Chelan-Sawtooth Wilderness compared to the 

current condition, or to Alternative 2 or 4. There would be a 59% reduction in service days in 

the Sawtooth Backcountry and a 55% decrease in the Lake Chelan-Sawtooth. 

Pack and saddle stock outfitter-guides would park at trailheads less frequently, so there would 

be more parking at popular trailheads, especially at the Crater Creek trailhead. People would 

encounter fewer outfitted pack stock parties on the trails, so may experience more of a feeling 

of isolation. There would also be a decrease in traffic on the road leading to the Crater Creek 

trailhead.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-139 February 2013

Okanogan-Wenatchee National Forest

Alternative 4

Alternative 4 would increase use in the Sawtooth Backcountry and Lake Chelan-Sawtooth 

Wilderness. The number of service days in the Sawtooth Backcountry would increase 123%, so 

non-outfitted users would notice a substantial increase in pack and saddle stock outfitter-guide 

use at the Crater Creek Trailhead, and on the trails leading into the Backcountry. The base camp 

at Crater Creek would likely be used more frequently by the outfitter assigned to that camp, but 

this would not impact the public since it is not open to public use now. There would also be a 

noticeable increase in traffic leading to the trailhead. 

The number of service days in the Lake Chelan-Sawtooth would increase by 6%. This small 

increase would likely go unnoticed by non-outfitted recreationists. There would be some 

increase in outfitter-guide use of the trailheads and encounters on the trails leading into the 

wilderness. The base camp at Slate Creek Trailhead would continue to be used by the outfitter, 

but closed to public use.

Cumulative Effects

The spatial boundary for this analysis is the entire Middle Methow area. The temporal boundary 

is from the early 1900s through 2023, when the 10-year permits would expire, and effects of the 

permits would cease.

Present Actions

Non-outfitted Recreation Use

There are approximately 15,000 visitor days in the Middle Methow sub-unit, none of which are 

associated with the pack and saddle stock outfitter-guides. The following figure displays the 

number of visitor days by activity.

Figure 3.3-14 . Current number of Visitor Days by Use Group in the Middle Methow Area

User Group Total Visitor days

Hikers 1,500

Driving for Pleasure 12,000

Use w/Pack and Saddle Stock 750

Mountain Bike Riders 750

TOTAL 15,000

Outfitter-guides

Other outfitter-guides travel through the Middle Methow sub-unit on their way into the 

Sawtooth Backcountry and Lake Chelan-Sawtooth wilderness. The trailheads are located in the 

sub-unit, so these outfitter-guides contribute to traffic on the roads, use parking spaces at 

trailheads, and guide clients on the trails. 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-140 February 2013

Okanogan-Wenatchee National Forest

Reasonably Foreseeable Future Actions

Non-outfitted Recreation

It is reasonably foreseeable that the number of non-outfitted recreationists would increase in 

the sub-unit. Using the projections from the Interagency Committee on Outdoor Recreation 

(Interagency Committee for Outdoor Recreation, 2003), the approximate number of visitor days 

in the area in 2022 are included in the following figure. 

Figure 3.3-15. Number of Non-Pack and Saddle Stock-Outfitted Visitor Days in Middle Methow 

Currently and in 2023

User Group Approximate Current 

Number of Non Outfitted 

Visitor Days

% Increase by 

2022*

Estimated Number of Non 

Pack and Saddle Stock –

Outfitted Visitor Days in 

2023

Hikers 1,500 +13% 1,695

Driving for Pleasure 12,000 +10% 13,200

Pack and Saddle Stock 

Users

750 +3% 773

Mountain Bike Riders 750 +10% 825

Total 15,000 +10 16,493

(Interagency Committee on Outdoor Recreation, 2003)

Outfitter-guides

It is reasonably foreseeable that the current non-pack and saddle stock outfitter-guide activity 

and recreation events would continue in the future.

Alternatives 1

The cumulative effect of Alternative 1 and the past, present, and reasonably foreseeable future 

actions would be a 10% increase in the number of visitor days in the Middle Methow sub-unit. 

There would be approximately 8% more people using trailheads and trails leading into the 

Sawtooth Backcountry and Lake Chelan-Sawtooth Wilderness, and driving on the roads to the 

trailheads. Parking could still be limited at times at the most popular trailheads, such as Crater 

Creek, but generally there would be adequate room for all users. 

Alternative 2

The cumulative effect of Alternative 2 with the past, present, and reasonably foreseeable future 

actions would be approximately 10% more people recreating in the Middle Methow, and 

approximately 10% more use at trailheads and along trails, and in traffic on roads leading to 

trailheads. Parking could still be limited at times at the most popular trailheads, such as Crater 

Creek, but generally there would be adequate room for all users. 

Alternative 3

The cumulative effect of Alternative 3 and the past, present, and reasonably foreseeable future 

actions would be an increase of approximately 8% in use at trailheads and on trails, coupled 

with the 10% increase in recreation use in the Middle Methow. As with Alternatives 1 and 2, 

parking could be limited at times, but generally there would be adequate room for all users. The 

amount of traffic leading to the trailheads would also increase.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-141 February 2013

Okanogan-Wenatchee National Forest

Alternative 4

Alternative 4 would result in the largest cumulative effect as compared to the other alternatives. 

The cumulative effect would be as with Alternative 2, since there would be approximately 10% 

more people at the trailheads leading into leading into the Lake Chelan-Sawtooth Wilderness, 

and on the trails. Parking at trailheads leading into the wilderness could be limited at times, 

however there would be adequate room on most occasions. The cumulative increase in use into 

the Sawtooth Backcountry, approximately 13%, would increase crowding at trailheads, 

especially at the Crater Creek Trailhead. The cumulative effect of this 13% increase, and the 

anticipated 10% increase in recreation within the Middle Methow sub-unit would increase 

traffic on roads leading to the trailheads. 

Consistency Findings

Other than the Forest-wide findings at the end of this recreation section, no management area 

specific findings are required because the management areas in the Middle-Methow Sub-Area 

contain no standards and guidelines specific to recreational use.

Alta Lake

Regulatory Framework

This subsection is divided between Management Areas 5 and 14 in the Okanogan Forest Plan, as 

amended by the Northwest Forest Plan.

The goal for MA 5 is to: [p]rovide opportunities for recreation and viewing scenery in a roaded 

natural setting with a visual quality objective of retention or partial retention (4-65).

The goal for MA 14 is to: [p]rovide a diversity of wildlife habitat, including deer winter range, 

while growing and producing merchantable wood fiber (4-83).

Okanogan Forest Plan has no management area specific recreation standards and guidelines 

that apply to outfitter-guides. 

Affected Environment

The Alta Lake portion of the analysis area includes the National Forest System Land surrounding 

and near Alta Lake. In 1900, Mr. Heinz, from Wilbur, Washington was mining in the area and 

finding the lake without a name called it “Alta” after his daughter, Alta Heinz. Alta Lake is about 

two miles long and a half mile wide. Alta Lake State Park Campground is located on the north 

shore of the lake and lines about 3⁄4 miles of shoreline. Alta Lake State Park is described as “a 

camping park where the mountainous pine forests meet the desert.” The remaining shoreline 

ownership is split between private and National Forest lands; each owning about 50% of the 

remaining lands adjacent to the shoreline. Alta Lake is a 10 minute drive from Pateros and 40 

minutes from Chelan.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-142 February 2013

Okanogan-Wenatchee National Forest

Historic Activities

The following past actions have effects that are continuing, and overlapping effects from the 

pack and saddle stock outfitter-guides.

Grazing

Cattle grazing occurred in Alta Lake area for decades. Some stock driveways and trails became 

part of the developed trails around Alta Lake and coulee. There is an area of bare soil about 

2000 square feet in size, and several weed species near the popular Alta Pond destination along 

the developed trail resulting primarily from a combination of past cattle, some saddle stock 

grazing and concentration of use.

Timber harvest/road construction

The greater Alta Lake area is partially forested with ponderosa pine and Douglas-fir trees but 

much of the area is non-forested. Due to the open forest structure and scenic lake surrounded 

by steep mountains and cliffs, timber harvest has been limited to small sales accessed by the 

main road leading into and out of the area. 

Other than the original “Alta Coulee Road”, roads were minimal in this area due to the steep 

terrain beyond the valley flats. The Alta Coulee Road between Antoine Creek and State Highway 

153 was the main connection road between Chelan and Okanogan counties until the 

construction of Highway 97. It was constructed for commerce, residents and recreation travel 

rather than for timber harvest.

Recreation and Trail Maintenance

People have been riding horses, hiking and mountain biking into this area for decades. The cow 

paths developed into riding trails and have been maintained as needed by the outfitter to 

provide for day rides.

Alta Lake State Park

The City of Pateros donated lands it owned just north of Alta Lake to the state of Washington, 

and "Alta Lake State Park" was constructed in 1951. The park has attracted thousands of 

boaters, anglers, campers, picnickers and swimming enthusiasts to the Alta Lake area for over 

50 years.

Current Condition

Recreation Activities

There have been approximately 10,500 visitor days on National Forest lands in this area based 

on Forest Service employee observations. Most of these days (80%) are visitors driving for 

pleasure or access through a 1⁄4 mile section across National Forest lands on the only road 

accessing the south end of Alta Lake. Whisperin’ Pines Ranch, owned by one of the current 

outfitters, lies at the southernmost end of Alta Lake. It contains a private campground and 

provides day horseback riding opportunities. Day riding trails circle Alta Lake and wind through 

State Park, private, Bureau of Land Management (BLM) and National Forest lands and include a 

total of about 17 miles of trail. About five miles of this trail system lies on National Forest lands, 

and about 31⁄4 miles of this total lies on roads located on National Forest near the lake (1⁄4 mile), 

and south of the lake in Alta Coulee (about 3 miles).
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-143 February 2013

Okanogan-Wenatchee National Forest

The horseback day rides include an outfitter-guide employee leading the ride, but the service 

days are very close to the actual number of visitor days since there is usually just one employee, 

and there are no drop camps involved. Therefore, the number of service day-day rides equals 

the number of visitor day-day rides.

On National Forest land surrounding Alta Lake there are no constructed recreation sites other 

than trails used primarily for day rides. The trail portions on National Forest land are part of 

Chelan Ranger District trail system. All other activity on National Forest lands near Alta Lake is 

dispersed recreation accessed by trail, road and/or lake.

Adjacent to National Forest lands are state and private lands with developed public and private 

recreation opportunities. Alta Lake State Park provides tent and RV camping, two boat 

launches, picnic sites, a swim area; and hiking and mountain biking opportunities on two miles 

of designated trails. Whisperin’ Pines Ranch has a campground that provides tent and RV sites, 

rental cabins, and row boat rentals. Alta Lake public golf course lies nearby, and private docks 

and other types of recreation facilities are located on private lands interspersed around the lake.

Outfitter Guide Activities

Guided horseback day rides are provided on trails developed around Alta Lake and trail loops 

further south of the lake. Customers can choose trips of one, two, four hours duration, or a full 

day of horseback riding. There are currently 730 service days in this area. 

Figure 3.3-16. Current number of Visitor Days in Alta Lake Area, by User Group, and Number of Saddle 

Stock Outfitter-Guide Service Days

User Group Total Visitor Days Outfitter-guide Service 

& Visitor Days

Percent of Total

Hikers 355 0 0%

Driving for Pleasure 8,445 0 0%

Pack and Saddle Stock 1,575 730 46%

Mountain Bike Riders 125 0 0

Total 10,500 730 7%

Environmental Consequences

Direct/Indirect Effects

The following figure shows the number of visitor days, and pack and saddle stock outfitter-guide 

days by alternative in the Alta Lake Sub-Area. Overall use days, even though they are not part of 

the pack and saddle outfitter-guide effects, are shown to provide context.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-144 February 2013

Okanogan-Wenatchee National Forest

Figure 3.3.17. Number of Visitor days in the Alta Lake area by Alternative.

Current or 

Alternative

Pack and Saddle 

Stock Users

Hikers Driving for 

Pleasure

Mountain 

Bike Riders

Total

Current

Total Visitor Days 1,575 355 8,445 125 10,500

Pack and Saddle 

Stock OG Service 

Days

730 0 0 0 730

Percent of total 0% 0% 0% 0% 3%

Alternative 1

Total Visitor Days 845 355 8,445 125 9,770

Pack and Saddle 

Stock OG Service 

Days

0 0 0 0 0

Percent of total 0% 0% 0% 0% 0%

Percent Change From 

Current Total

-46% 0% 0% 0% -7%

Percent Change from 

Current Service Days

-100%

Alternative 2

Total Visitor Days 1,595 355 8,445 125 10,520

Pack and Saddle 

Stock OG Service 

Days

750 0 0 0 750

Percent of total 47% 0% 0% 0% 7%

Percent Change From 

Current Total

+1% 0% 0% 0% +0.2%

Percent Change from 

Current Service Days

+3%

Alternative 3

Total Visitor Days 1,435 355 8,445 125 10,360

Pack and Saddle 

Stock OG Service 

Days

590 0 0 0 590

Percent of total 41% 0% 0% 0% 6%

Percent Change From 

Current Total

-9% 0% 0% 0% -1%

Percent Change from 

Current Service Days

-18%

Alternative 4

Total Visitor Days 2,295 355 8,445 125 11,220

Pack and Saddle 

Stock OG Service 

Days

1,450 0 0 0 1,450

Percent of total 63% 0% 0% 0% 13%

Percent Change From 

Current Total

+46% 0% 0% 0% 7%

Percent Change from 

Current Service Days

101%
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-145 February 2013

Okanogan-Wenatchee National Forest

Alternative 1

There would be no saddle stock outfitter-guide clients or employees in the Alta Lake area in 

Alternative 1. The reduction would likely be unnoticed by most non-outfitted recreationists 

because of the small reduction in overall recreational use (see cumulative effects). However, 

the considerable reduction in the number of saddle stock users) would reduce the frequency of 

encounters between all other user groups and riding stock users, and eliminate these rides on 

NFS lands.

Alternative 2

Alternative 2 would increase pack and saddle stock outfitter guide visitor days by 1% (+20 days), 

essentially maintaining the existing number of people in the Alta Lake area. There would be 

about 750 saddle stock outfitter guide visitor days. People would continue to be able to take 

guided horseback riding trips on the trails in the area.

The effect of this amount of use on the Alta Lake trails would be that people would have a 

moderate chance of experiencing isolation on the trails and at popular viewpoints. Use would 

be concentrated on developed trails. 

Alternative 3

Alternative 3 would decrease permitted use by 140 days. Five hundred and ninety saddle stock 

outfitter guide visitor days would be provided, reducing use by 19% from current numbers. 

Fewer people would be able to be guided on horseback rides along the trails. 

People would have a reduced chance of seeing saddle groups compared to the current 

condition, or Alternatives 2 or 4. Use would continue to be concentrated on developed trails. 

People would have a slightly reduced chance of seeing saddle stock groups. Use would be 

concentrated on developed trails. 

Alternative 4

Alternative 4 would almost double the number of pack and saddle stock outfitter-guide service 

days in the Alta Lake area, allowing more people the chance to ride horses along the trails in the 

area. 

The trails and viewpoints would be more crowded, and isolation on trails would be reduced 

from the current levels. 

Cumulative Effects

The spatial boundary for this analysis was the entire Alta Lake area. The temporal boundary was 

from the early 1900s through 2023, when the 10-year permits would expire and the effects of 

the permits would cease. Past actions with effects overlapping effects of pack and saddle stock 

outfitter-guides are described in the Past Actions section above.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-146 February 2013

Okanogan-Wenatchee National Forest

Present Actions

Grazing

Twenty-five cow/calf pairs are currently permitted to graze the Alta Coulee Allotment from June 

1 through September 30 for a total of 102 Animal Unit Months (AUMs). Cattle tend to graze 

only the coulee bottom even though the boundary of the allotment is much larger. Grazing is 

having no effect on existing recreation activities other than isolated encounters with cattle on 

roads or trails.

Road maintenance

The Alta Lake County Road #1517 is managed and maintained by Okanogan County from its 

intersection with State Highway 153 to the Whisperin’ Pines Ranch at the south end of Alta 

Lake. It is paved through the State Park and graveled south of the park. Beyond the ranch the 

Alta Coulee Road (Forest Road 8141) extends approximately 2 1⁄2 miles to private land south of 

the sub-unit. 

Alta Lake State Park

Alta Lake State Park currently is 181 acres in size and has a developed campground containing 

168 tent sites, 32 sites with hook-ups, restrooms, showers, two boat launches, picnic sites, a 

swim area; and two miles of designated trails. It attracts many people to the Alta Lake area 

where they then discover other recreation attractions available such as day rides available on 

the National Forest.

Reasonably Foreseeable Future Actions

Grazing

It is reasonably foreseeable that the Alta Coulee Allotment cattle grazing will continue in the 

area, and that it will have little effect on recreation activities.

Road maintenance

Road maintenance is expected to continue at its current levels. This will maintain the existing 

recreation activities.

Alta Lake State Park

Recreation use at Alta Lake State Park is expected to increase over the next 10 years for all 

activities except fishing as projected in the Interagency Committee for Outdoor Recreation 

Estimates of Future Participation in Outdoor Recreation in Washington State (Interagency 

Committee for Outdoor Recreation 2003) Addendum to the State Comprehensive Recreation 

Planning (SCORP) publication. This increase of recreation users will also increase the amount of 

overall use on National Forest lands at Alta Lake.

Non-outfitted Recreation Use

The number of people recreating in the greater Alta Lake area is expected to increase by about 

10% overall by 2023, according to the Interagency Committee on Outdoor Recreation 

(Interagency Committee for Outdoor Recreation, 2003).

The following table lists the current number of non-pack and saddle stock-outfitted 

recreationists, and the number that will likely be there in 2022.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-147 February 2013

Okanogan-Wenatchee National Forest

Figure 3.3-18. Current Number of Visitor Days in Alta Lake Area and Estimated Number in 2023

User Group Current Number of NonOutfitted Visitor Days% Change by 

2022*

Estimated Number of NonOutfitted Visitor Days in 

2022

Hikers 335 + 13% 379

Driving for 

Pleasure

8,445 +10% 9,290

Pack and Saddle 

Stock Users

1,575 +3% 1,622

Mountain Bikers 125 +10% 138

Total 9,671 +10% 11,429

(*Interagency Committee for Outdoor Recreation, 2003)

The following figure displays the cumulative effect on visitor days for each alternative.
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Figure 3.3-19. Cumulative Effect on Visitor Days in Alta Lake with Each Alternative, Compared to 

Current, Projected to 2023 for all Recreation Uses

Current or 

Alternative

Pack and Saddle 

Stock Users

Hikers Driving for

Pleasure

Mountain 

Bike Riders

Total

Current

Total Visitor Days 1,575 355 8,445 125 10,500

Pack and Saddle 

Stock OG Service 

Days

730 0 0 0 730

Percent of total 46% 0% 0% 0% 3%

Alternative 1

Total Visitor Days 892 379 9,290 138 10,699

Service Days 0 0 0 0 0

Percent of total 0% 0% 0% 0% 0%

Percent Change 

from Current

-43% +7% 10% 10% +2%

Alternative 2

Total Visitor Days 1,642

(892+750=1,642)

379 9,290 138 11,449

Service Days 750 0 0 0 750

Percent of total 46% 0% 0% 0% 7%

Percent Change 

from Current

+4% +7% 10% 10% +9%

Alternative 3

Total Visitor Days 1,482

(892+590=1,482)

379 9,290 138 11,289

Service Days 590 0 0 0 590

Percent of total 40% 0% 0% 0% 5%

Percent Change 

from Current

-6% +7% 10% 10% +7%

Alternative 4

Total Visitor Days 2,342

(892+1,450=2,342)

379 9,290 138 12,149

Service Days 1,450 0 0 0 1,450

Percent of total 62% 0% 0% 0% 12%

Percent Change 

from Current

+49% +7% 10% 10% +16%

Alternative 1

There would be no cumulative effect on recreation in the Alta Lake area with Alternative 1 and 

the past, present, and reasonably foreseeable future actions since the overall number of 

recreationists would be nearly unchanged. No pack and saddle outfitter-guide permits would be 

issued which would result in a reduction of 730 use days from the recently permitted numbers 

(3% of current use). There would be a 50% reduction in the number of pack and saddle stock 
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users, so those riding horses would see fewer other riders. Trails and roads would still be 

available, so the distribution of people would change very little. The overall decrease would 

likely not be noticed by the people recreating there, but the number of encounters between and 

with saddle stock users would be noticeably smaller. 

Alternative 2

The cumulative effect of this alternative when added to past, present, and reasonably 

foreseeable future actions on recreation activities in the Alta Lake area would be an increase in 

the overall number of people recreating (about 9%), with pack and saddle stock use decreasing 

by 4%. Trails and roads would still be available, so the distribution of people would change very 

little. The overall increase would not likely be noticed by the people recreating there. 

Alternative 3

The cumulative effect of this alternative when added to past, present, and reasonably 

foreseeable future actions on recreation activities in the Alta Lake area would be a 7% increase 

in the overall number of people recreating, but a 6% decrease in the number of saddle stock 

uses over the next decade. Trails and roads would still be available, so the distribution of people 

would change very little. The overall increase would be unnoticeable by the people recreating 

there, but the number of encounters between and with saddle stock users would be smaller. 

Alternative 4

The cumulative effect of Alternative 4 and the past, present, and reasonably foreseeable future 

actions would be the largest increase in overall recreation use, compared to Alternatives 1, 2 or 

3. There would be approximately 16% more visitor days in the entire area, and 49% more pack 

and saddle stock riders. The increase in the number of riders would make the trails and 

viewpoints more crowded, but the overall use would be distributed on the roads and trails. The 

anticipated overall increase in visitor days would likely be noticed since it would be 

concentrated on the roads and trails in the sub-unit. 

Consistency Findings

Other than the Forest-wide findings at the end of this recreation section, no management area 

specific findings are required because the management areas in the Alta Lake Sub-Area contain 

no standards and guidelines specific to recreational use.

CONSISTENCY FINDINGS

All alternatives would be consistent with the Forest Plan standards and guidelines for the 

respective management areas. Standards and guidelines specific to particular sub-units are 

discussed at the end of each section. The standards and guidelines pertaining to all sub-units 

are discussed below. 

8-10: Annual review of recreation special use authorizations shall emphasize health, safety, and 

resource protection (page 4-38).

Annual performance evaluations are conducted with all pack and saddle stock outfitterguides. A copy of the evaluation form is in the analysis file. Refer to the discussion of 

outfitter evaluation in section 3.1 Outfitter-Guides (page 3-15). 
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8-11: Recreation special use authorizations shall conform with the goals of the Management 

Area (page 4-39).

As discussed in the discussion of each sub-unit, all alternatives comply with management 

area-specific standards and guidelines. Complying with the standards and guidelines ensures 

conformation with the management area goals.

8-12: Give priority to authorizations needed to provide public service.

The continued demand for pack and saddle stock outfitter-guide services demonstrates the 

public service the outfitters provide. 

3.4 SOIL RESOURCES

The section below is a summary of the Soils Report which is available in the project analysis file

(Davis 2012).

REGULATORY FRAMEWORK

Regional soil quality standards were developed to provide a consistent approach to monitor and 

identify detrimental soil disturbance (USDA Forest Service 1996d, updated1998). Although 

these standards were developed specifically to monitor disturbance from timber harvest 

activities, the concepts and principles can be applied to other activities such as outfitter-guide 

operations. The units of measures necessary to determine the level of soil effects are as 

follows:

soil compaction—acres of compacted bare mineral soil;

soil displacement—acres of “off-site” eroded soil material (eroded soil material buries grass 

or shrub root crowns); 

grazing practices trigger soil erosion—ocular evidence of surface and overland flow ;

soil effects at stream crossings— ocular analysis of denuded stream banks and evidence of 

loss of riparian stream bank vegetation.

soil erosion from livestock watering areas –- ocular evidence of trampling and surface 

runoff.

Standards and guidelines from the forest plans give the management direction for soils. 

Okanogan Forest Plan:

Forest-wide standard and guideline that can pertain to impacts from pack and saddle 

stock outfitter-guide activities:

13-7 Rehabilitate soil productivity, water quality, and land following any management 

activities that result in long-term site degradation to meet the goals of the 

Management Area.
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Management Area 15B has the following standards and guidelines pertaining to soils:

MA 15B-13A Displacement and erosion of soil resulting from human activity shall be 

limited to a rate that closely approximates the natural processes.

MA 15B-13B Soil compaction from human activities should not prevent natural plant 

establishment and growth except at some campsites, administrative facilities, and in 

designated tread.

MA 15B-22B Vegetation loss should not exceed 400 square feet (one percent of any 

acre) at any impacted site.

Wenatchee Forest Plan

No forest-wide standards and guidelines on soils pertain to outfitter-guide activities. The 

following standards and guidelines pertain to Wilderness Recreation Opportunity Spectrums 

where the pack and saddle stock outfitter-guides operate:

Primitive

Area of vegetation loss, and compacted bare mineral soil at any campsite should not 

exceed 400 square feet.

Displacement and erosion of soil resulting from human activity will be limited to a 

rate that approximates natural processes.

Soil compaction should not exceed limits which will prevent natural plant 

establishment and growth except at well established campsites.

Semi-Primitive

Area of vegetation loss, and compacted bare mineral soil at any campsite, should not 

exceed 625 square feet.

Displacement and erosion of soil resulting from human activity will be limited to a 

rate that approximates natural processes.

Soil compaction should not exceed limits which will prevent natural plant 

establishment and growth, except at desired campsites, and in designated trail 

treads.

Transition

Area of vegetation loss, and compacted bare mineral soil at any campsite, should not 

exceed 1000 square feet.
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Displacement and erosion of soil resulting from human activity will be limited to a 

rate that approximates natural processes.

Soil compaction should not exceed limits which will prevent natural plant 

establishment and growth, except at desired campsites, and on designated trail 

treads.

ANALYSIS METHODS

Soil conditions were evaluated in terms of soil compaction and displacement, grazing practices 

that trigger detrimental soil erosion, soil effects at stream crossings, and soil erosion at pack and 

saddle stock watering areas. A combination of qualitative and quantitative methods were used. 

The soil scientist visited a sampling of impacted areas, and conducted compaction surveys, and 

gathered qualitative information about the soil condition.

The methodology described above is the best available to describe the ecological and social 

conditions within the analysis area, and the potential effects of the proposed outfitter-guide use 

on the soil resource.

AFFECTED ENVIRONMENT

Historical Disturbance Factors

The volcanic ash soils in the analysis area have moderately high level of resiliency, yet with 

prolonged or intense disturbance to surface vegetation, detrimental soil compaction, 

displacement, and erosion can occur. Current soil conditions are a result of those past or 

current events that have hindered the vigor of surface vegetation. The two principal 

disturbance elements that have had a great influence on soils and surface vegetation are historic 

livestock grazing and natural wildland or human-caused fires. Historic sheep grazing effects on 

soils are most noticeable in upper subalpine and alpine meadows while the effects of wildland 

fires can be observed across the analysis area.

Grazing Effects

Historic livestock grazing, in particular by sheep, altered soil condition throughout the analysis 

area. Sheep bands grazing through the Pasayten and Lake Chelan-Sawtooth Wilderness Areas 

and in the Sawtooth Backcountry and the associated herder activities resulted in compacted, 

unvegetated livestock driveways and herder camps. The effect of these early grazing practices 

on soils continues to be noticeable.

To support the sheep operations, numerous mountain trails were built. Many of these trails 

exist today as Forest Service system trails. Other trails were constructed to provide access to 

sheepherder camps and grazing sites. These camps were severely hardened by use. Many of 

these camps continue to be used today by the recreating public and outfitters. Due to the level 

of historic and continuing use, these hardened campsites are still devoid of vegetation cover. 

Most of the camp areas predate the current Forest Plans and exceed current plan standards for 

compacted bare mineral soil and vegetation loss (barren core) for camp areas. Numerous sheep 
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driveways were constructed to enable sheep bands to access key use grazing areas. Often these 

driveways provided the most direct route to key use areas and were steep. Concentrated 

surface runoff normally occurs on these steep driveways, segments which are still devoid of 

vegetation.

Much of the historic sheep grazing effects occurred prior to the formation of formal Forest 

Service grazing allotments. Hence, much of this historic sheep grazing was unregulated and 

predated land management planning and current standards. Early grazing practices often 

started as soon as the snow melted and continued until snowfall. The volcanic ash soils were 

just too soft during the early seasons to support repeated hoove action. Due to the vast 

numbers and timing of historic sheep grazing, trailing patterns and a terraced landscape are 

prominent in some subalpine and alpine meadows. Vegetation recovery on these areas has 

been slow due to harsh climatic conditions. Some localized meadow sites are still in poor 

vegetative health with severely pedestalled plants and exposed mineral soil (USDA Forest 

Service 1980 and 1998c). Two such areas of degraded adverse vegetation and soil conditions 

include the cirque basin containing Bernice Lake in the Lake Chelan-Sawtooth Wilderness and 

the cirque basin on the south side of Amphitheater Mountain in the Pasayten Wilderness. 

Terraces in these locations are continuing to enlarge and unravel. Current vegetation cover is 

not adequate to retard surface soil erosion in these two locations. Detrimental soil 

displacement is readily apparent in these locations. Wildlife continues to use these paths and 

terraces but not outfitter-guide pack and saddle stock; it is likely these features remain as 

permanent fixtures in meadows but not as a result of permitted pack and saddle stock use. 

With the elimination of grazing in these historic sheep grazing allotments, plant communities 

have been recovering. Vegetation recovery has reduced soil effects from overland flow and 

raindrop impacts. With new emerging vegetation, with exception of the most severe locations 

at the highest elevations, eroded material is stabilized close to the source. The historic 

hardened campsites are still void of vegetation because of the constant recreation use, including 

permitted pack and saddle stock use. However, these sites are nearly flat and surrounded by 

vegetative cover which traps and stabilizes any eroded material. Watershed scale detrimental 

soil disturbances are essentially immeasurable.

Most of the historic trails that became system trails and are still used today have improved 

drainage features which have essentially eliminated detrimental soil erosion. Typically there is 

enough trail side vegetation to trap and stabilize eroded material close to the trails. Off-site 

sedimentation to streams is extremely low.

Some livestock grazing occurs in the lower elevations of the analysis area outside wilderness. 

These operations are relatively recent and are small scale. Grazing is closely monitored as 

required by allotment management plans and little detrimental soil disturbance has been 

observed.

Presently no commercial grazing is authorized in the historic sheep ranges. All of the grazing 

allotments within the Pasayten and Lake Chelan-Sawtooth Wilderness Areas are vacant, closed, 

or going through the closure process. This means that the Forest Service will no longer consider 

large scale permitted livestock operations in these areas. 
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Wildland Fire Effects

Wildland fires in the analysis area are a natural process and have occurred at predicted intervals 

for centuries (USDA Forest Service 2004b). Since 1919, most of the analysis area has 

experienced wildland fires (USDA Forest Service 2003a). Some areas have actually re-burned. 

Wildland fires have had a pronounced influence on vegetation structure and some effect on soil 

conditions. According to Burned Area Emergency Reports (BAER), adverse soil effects from 

recent wildland fires are limited to high and some moderate severity burns (USDA Forest Service 

2001e, 2002 and 2003a). Typically high and moderate severity burns occurred in the midelevation ranges of the analysis area which is usually dominated by dense seral stands of 

lodgepole pine. 

Though over 380,000 acres have burned in the last 5 years, only a portion burned with 

moderate to high severity. Most of these areas occurred in the Andrews and Farewell drainages 

of the Pasayten Wilderness. High severity fires caused 100 percent mortality and surface fire 

temperatures were more than enough to remove fine litter duff and volatize organic matter and 

nutrients at the soil surface (USDA Forest Service 2003a and Hungerford et al. 1991). The 

decline in organic matter content in soils has a long-term effect of reducing the nutrient capital 

for at least 30 years.

Nevertheless, even high severity fire areas typically have understory vegetation recovery within 

five years (USDA Forest Service 2004b). The critical period for adverse sheet erosion effects 

occurs within the first three years following high severity fires. During this period, concentrated 

runoff can trigger sheet erosion and even debris slides. Debris slide risk can continue for ten 

years following high severity fires, often associated with loss of root strength and tree wind 

throw. Isolated areas of sheet erosion and debris slides have occurred in burned areas across 

the analysis area over time. 

Pack and Saddle Stock Outfitter-Guides

The current pack and saddle stock outfitter-guides are having minor, isolated impacts on soil 

conditions in campsites, trails, and at stock watering and grazing locations, as described below. 

These areas, with the exception of the assigned campsites and base camps, are also used by 

non-outfitted recreationists. 

Soil Compaction and Displacement

Soil compaction has occurred from historic sheep grazing. Old sheep driveways, trails, and 

camps have detrimentally compacted bare mineral soils. Nearly all wilderness campsites used 

by pack and stock users still exceed the standard for barren core. The average amount of barren 

core at established campsites used by the pack and saddle stock outfitter-guides is 1,663 square 

feet in the Pasayten and 602 in the Lake Chelan-Sawtooth. There is no barren core limitation at 

campsites outside wilderness.

The following table shows analysis for barren core based on the recreation site inventory 

completed in 2011 and 2012. Approximately 344 sites without any barren core were excluded 

from this analysis. These were un-established trace sites and sites that have fully recovered. 
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Figure 3-4-1. Percent of Established Campsites Exceeding 400 and 1,000 Square Feet of Barren Core and 

With More than Four Damaged Trees in Pasayten and Lake Chelan-Sawtooth Wildernesses

Pasayten Wilderness Lake Chelan-Sawtooth Wilderness

All sites Sites Used by Pack and 

Saddle Stock Outfitterguides

All sites Sites Used by Pack 

and Saddle Stock 

Outfitter-guides

Sites exceeding 400 sq. 

feet

46% 68% 41% 27%

Sites exceeding 1,000 

sq. feet

23% 40% 16% 25%

Average Barren Core 775 1,663 630 602

The campsites most frequently used by the pack and saddle stock outfitter-guides are the 

largest, although campsite monitoring completed in the 2011 and 2012 seasons show a 

reduction in barren core at several sites. The following tables show the campsites in the 

Pasayten and Lake Chelan-Wilderness areas which exceeded 2,800 square feet. Where data 

exist, the change in the amount of barren core at each site recorded between 1989 and 2002 is 

compared to the most current data. Many of the sites had not been surveyed prior to the 

monitoring completed in 2011 and 2012. The information for campsites with less than 2,800 

square feet of barren core is included in the analysis file. Appendix A includes a complete list of 

campsites consistently used by the outfitters, and the amount of barren core in each.
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Figure 3.4-2. Established Camps in the Pasayten Used by Outfitter Guides With Over 2800 Square Feet 

of Barren Core.

Camp Name Square Feet of 

Barren Core

(from monitoring 

completed from 

1989 to 2002)

Square Feet of 

Barren Core

(from monitoring 

completed in 2011 

and 2012)

Comments

3 Fools No Data 2,800 Used occasionally by outfitters for fullservice and drop camps

Bald Mountain* No Data 3,900 Used by outfitters for full-service and 

drop camps

Beaver Creek* 8,038 6,747 Used by outfitters as full-service camp 

site.

Charlie Brown 15,239 1,870 Used by outfitters for full-service and 

drop camps

Chandler 9,181 60 Used by outfitters as a drop camp

Chewuch No Data 3,000 Used by outfitters as a drop camp

Corral Lake No Data 3,500 Used by outfitters as a drop camp

Cougar Lake No Data 2,916 Used regularly by the general public as 

well as outfitters.

Crow Lake* No Data 9,610 Used by outfitters as full-service camp 

site.

Crow Lake 2 No Data 7,000 Recreation camp, not used regularly by 

outfitters

Fred’s Lake No Data 5,400 Used occasionally by outfitters for fullservice and drop camps

Goat Lakes Basin 

2 

2,650 3,000 Used occasionally by outfitters for drop 

camps

Peeve Meadow 5,500 5,640 Used occasionally by outfitters for drop 

camps

Sheep 

Mountain* 

19,368 8,879 Used by outfitters as full-service camp 

site.

Spanish Creek 6,000 60 Recreation camp, not used regularly by 

outfitters

Tatoosh 3,316 900 Used by outfitters as full-service camp 

site 

WhistlerBasin No Data 4,020 Used occasionally by outfitters for fullservice and drop camps

Whistler Camp* 9,906 3,254 Used by outfitters as full-service camp 

site
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Figure 3.4-3. Established Camps in Lake Chelan-Sawtooth used by Outfitter Guides with over 2800 

square feet of Barren Core

Camp Name Square Feet of Barren 

Core

(from monitoring 

completed from 1989 

to 2002)

Square Feet of 

Barren Core

(from monitoring 

completed in 2011 

and 2012)

Comments

Bike West No Data 2,900 Used occasionally by outfitters 

for full-service and drop camps

Cascade Creek 21,000 NA Unable to locate the site, as the 

area burned very hot in early 

2000’s. No longer accessible to 

stock. 

Muleshoe 2 9,134 3,000 Used occasionally by outfitters 

for full-service and drop camps

Muleshoe North No Data 4,200 Used occasionally by outfitters 

for full-service and drop camps

Prince 4 Mile 5,600 0 Historically used by outfitters for 

full-service camps. Burned in 

2003. Little to no recent use

Surprise No Data 3,500 Used occasionally by outfitters 

for full-service and drop camps

Twin Springs 1 12,245 3,071 Used occasionally by outfitters 

for full-service and drop camps

All campsites are nearly flat with fairly dense adjoining understory or ground vegetation. Little 

evidence of surface runoff or eroded soil was readily apparent, so no additional soil 

displacement would be expected. Surrounding vegetation would trap and stabilize any eroded 

material that did occur.

In the Pasayten Wilderness, there are approximately 117,694 square feet collectively in all the 

campsites consistently used by the pack and saddle stock outfitter-guides (Appendix A). This 

converts to approximately 2.7 acres. There are approximately 798 miles of system trail in the 

Pasayten, which converts to approximately 376 acres. Adding these together, outfitter-guides 

use approximately 378.7 acres of bare, compacted soil in the Pasayten Wilderness., or 0.07% of 

the total area. 

In the Lake Chelan-Sawtooth Wilderness, there are approximately 48,534 square feet of barren 

core in the outfitter camps, or 1.1 acre (Appendix A). There are approximately 152 miles of 

system trail, which converts to approximately 71.6 acres. Adding these together, outfitterguides use approximately 72.7 acres of bare, compacted soil in the Lake Chelan-Sawtooth 

Wilderness, or 0.05% of the total area. 

Outfitter-guides also use barren core areas in campsites and trails in the other portions of the 

analysis area. There is no field data about campsite barren core outside wilderness since there 

is no standard and guideline limiting the amount. Having the exact information is not necessary 

to determine the effects of pack and saddle stock outfitter-guides because the amount of area 

because it no foreseeable significant impacts exist from the pack and saddle stock outfitterguide activities. The information is not essential to a reasoned choice among alternatives since 

there is no difference in the amount of barren core the outfitter-guides would use in the 
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alternatives. The total amount of barren core in campsites is a very small percentage of the 

each sub-area. Since campsites are located on flat, or nearly flat ground, and surrounded by 

ground vegetation, very little soil would erode from the barren areas. Any that does would be 

trapped by the vegetation before reaching waterways, or be quickly dissipated by flowing water. 

The estimates of barren core calculated with the specific barren core information from the 

wilderness campsites are adequate to make this determination. More precise data concerning 

barren core outside wilderness is not necessary.

Pack and saddle stock outfitter-guides use existing system trails to access campsites, and local 

social trails in and around the camps. Pack and saddle stock compact and displace soil in the 

trail tread as they move along the trails. The trails are designed to minimize erosion, and 

drainage structures are constructed and maintained to channel water off the tread into 

surrounding vegetation before it damages the trail, or reaches waterways. The stock also create 

braided trails when they leave the established tread to avoid wet areas or obstacles in the trail. 

These isolated spots are addressed through trail rerouting or trail structure construction as 

funding allows.

The average amount of barren core in full-service campsites in the Pasayten and Lake ChelanSawtooth wildernesses is 1,640 square feet and the average size in drop camps is 888 square 

feet. Applying these averages to the campsites consistently used by the pack and saddle stock 

outfitter-guides in the other sub-units generates an estimate of the number of acres of campsite 

barren core. The actual amount of barren core could be larges since there is no party size 

limitation outside wilderness. Refer to Appendix A for a list of campsites in each sub-area.

There are 15 drop camps and 1 full service camp in the North Cascades, which calculates to 

approximately 14,960 square feet, or 0.3 acres of barren core. There are approximately 150 

miles of system trail in this area, or approximately 70.6 acres. This is approximately 0.06% of 

the total sub-area.

In the Sawtooth Backcountry, there are 9 drop camps and 8 full service camps, with 

approximately 21,112 square feet, or 0.5 acres of barren core. There are approximately 60 

miles of trail in this area, or approximately 28.3 acres. The total of these is approximately 0.08% 

of the Backcountry.

There are no established campsites in the Middle Methow. The outfitter-guides do use the trails 

leading from the trailheads into the Lake Chelan-Sawtooth Wilderness or Sawtooth Backcountry. 

There is one established campsite in the Bear/Ramsey/Volstead area used as a drop camp, but 

no system trails used by the outfitter-guides. The Alta Lake area does not have any established 

campsites, but the outfitter-guide uses approximately 17 miles of trail, totaling approximately 8 

acres, or 0.2% of this sub-area.

Detrimental compaction of bare mineral soil in either wilderness from the other permit 

activities, such as areas where stock are allowed to loose graze, is essentially immeasurable and 

hence not identified.

When compared to the acreage of the entire area, the detrimental soil compaction of camp 

areas, trails, and meadows is not consequential; normal watershed hydrologic functions have 

not been impaired. The small amount of soil erosion occurring from these areas approximates 
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natural processes since it is isolated, and either captured by surrounding ground vegetation, or 

quickly dissipated by flowing water in streams.

Grazing Practices Triggering Soil Erosion

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

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

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

corral. Loose grazing is a technique where the stock are let loose to graze. 

Soil in stock containment areas are typically devoid of vegetation, compacted, and displaced. 

Stock also use these areas to take dust baths by rolling, contributing to bare ground. Long 

periods of containment can generally be equated to more impacts because it concentrates 

impact and contributes to restless behavior (Leave No Trace, 2001). These containment areas 

are located within camps, and counted as part of the camp’s barren core. Very little to no offsite erosion occurs from these containment areas because they are usually flat and surrounded 

by ground vegetation that captures soil movement (McClaran and Cole 1993). 

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

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

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

move stock well away from other campsites and private stock. Horses and mules stay together 

in the grazing areas, although they graze in a dispersed pattern. Stock spend most their time in 

continuous movement across the land, eating grasses as they go (Ransom and Cade 2009). The 

stock form a loose herd, always nearby each other, but not tightly congregated. 

When water is readily available as it is in most places in the wilderness, horses do not gather at 

specific sites to drink as in desert environments (Salter and Hudson 1979). Typically free-ranging 

horses move rapidly to and from water sources with very little feeding or loafing activities near 

drinking areas (Ganskopp and Vavra 1986). They prefer open areas and elevated terrain away 

from water and thick brush to get away from insects (Keiper and Berger 1982) and to be able to 

assess potential threats from predators (Ganskopp and Vavra 1986). They avoid muddy areas 

because they instinctually do not want to be mired in mud, and simply because they prefer to 

keep their feet dry. 

Soil disturbance is greater in areas where pack stock are confined than in larger areas where 

stock area allowed to graze freely (McClaran and Cole 1993). The loose grazing pattern results 

in very little soil disturbance. When the animals move from the campsite to the grazing area, 

they do create trails where the soil is compacted. Once the animals reach the grazing area, they 

spread out and disperse. The animals are not concentrated in small areas, such as the stock 

containment areas described above. Loose grazing results in fewer impacts to the soil and 

vegetation than other methods of grazing stock such as picketing or electric fences (McClaran 

and Cole 1993). The constant movement of the animals prevents concentrated soil disturbance. 
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The animals also spend most of their time on dry, well vegetated hillsides, away from muddy 

areas and water. Dry, well drained soils with continuous vegetative cover are less susceptible to 

soil compaction and shearing (Warren et al. 1986), so there are virtually no long term impacts to 

the soil as a result of loose grazing.

Soil Effects at Stream Crossings

Trail stream crossings are spots where soil compaction and displacement occurs, and where 

erosion can impact water quality. Current pack and saddle stock outfitter-guides use trails to 

access campsites, so contribute to impacts at these crossings. These crossings occur 

infrequently along streams, and any sediment entering the water is quickly dispersed, with 

water quality returning to normal once the animal or person exits the water. 

According to the Recreation Activity Review (Appendix F), most stream banks in the area are 

well-vegetated, stable, and meet Plan standards and guidelines. One exception is the stream 

flowing into Remmel Lake where a large camp has resulted in trampled riparian vegetation. An 

approximately 6 foot section of the bank on either side of the creek (12 feet total) was disturbed 

near the trail crossing. The stream gradient is low at this site, and this trail crossing is often 

boggy throughout the season. Stock try to avoid the mud at this location, resulting in a larger 

disturbed area than the typical width of a trail. However, impacts are isolated to the immediate 

12 foot area near the trail crossing. The streambank above and below this area is in pristine 

condition, with no disturbance to the bank or vegetation along the creek. 

Soil Effects at Stock Watering Locations 

Some soil erosion is occurring at watering locations for outfitter-guide stock. Outfitted pack and 

saddle stock disturb streambanks and riparian areas at watering spots near trail crossing areas 

and campsites. Unavoidable trampling occurs at these spots, exposing bare soil and causing 

alternations of the stream banks. Areas above and below these disturbance areas are in pristine 

condition, with no sign of human or stock use, intact streambanks, and established vegetation 

(refer to stream survey reports in the analysis file). This erosion is not affecting water quality 

beyond the isolated, local areas due to relative small size and infrequent occurrence. 

ENVIRONMENTAL CONSEQUENCES

Direct and Indirect Effects

Alternative 1

There would be no pack and saddle stock outfitter-guides with implementation of Alternative 1, 

so outfitters would no longer have any impact on soils, including soil compaction, displacement, 

from grazing, at stream crossings, or at stock watering locations.

Soil Compaction

Soil Compaction and displacement at established campsites would continue because nonoutfitted recreationists would continue to use the campsites. The size of the barren core areas 

shown in Figures 3.4-2 and 3.4-3 could decrease due to the overall decrease in total use and 

more specifically, pack and saddle stock use. This would reduce the total amount of compacted 
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and displaced soil associated with campsites. The amount of compacted soil in trails would not 

change.

Grazing Practices Triggering Soil Erosion

Outfitter-guide pack and saddle stock would not cause any soil erosion within stock containment 

areas in campsites, and would have no impacts to soil from loose grazing. There could be a 

slight reduction in impacts from grazing, both in stock containment areas within camps, and in 

areas currently used by loose grazing outfitted stock, because of the reduction in the number of 

pack and saddle stock across the analysis area. The change would be immeasurably small, 

however, since the current impacts are so slight. There would continue to be virtually no 

erosion from stock containment areas because they are generally flat and surrounded by ground 

vegetation that traps soil eroding from the bare areas. There are no impacts from loose grazing 

by outfitted stock, so there would be no change from the current condition in those grazing 

areas. 

Soil Effects at Stream Crossings

Erosion at trail stream crossings would continue, but would decrease from the current condition 

because of the 15% reduction in the number of pack and saddle stock using the trail system. .

Soil Erosion from Pack and Saddle Stock Watering Areas

Soil erosion from public pack and saddle stock use would continue. This erosion would not 

affect water quality beyond the isolated, local area due to relative small size and infrequent 

occurrence. 

Alternatives 2, 3, and 4

Mitigation Measures

Some of the mitigation measures listed in Chapter 2 would avoid or reduce impacts to soil. They 

would be effective since they would all be included in the annual operating plans for the pack 

and saddle stock outfitter guides. Compliance would be addressed through permit 

administration. These are discussed below. 

1b. Developing Camp Management Plans for the assigned sites would reduce potential 

impacts to soil by tracking existing barren core, and ensuring no additional barren core is 

forming. Identifying unneeded barren core would allow these areas to revegetate, 

reducing overall soil impact. There is a high likelihood that this would prevent additional 

soil damage, and allow some recovery of compacted areas. 

1c&d. Limiting the amount of barren core that the outfitters could use in established 

campsites would reduce impacts to soil by allowing excess barren core to revegetate. The 

Camp Management Plans for these larger sites would help track barren core and ensure 

compliance with limitations. This mitigation would be effective in controlling pack and 

saddle stock outfitter-guide impacts to soil, but since these camps are also used by the 

public, impacts could continue because of non-outfitted use patterns. 
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1e. Prohibiting pack and saddle stock outfitter-guides from increasing the amount of barren 

core in any campsite would eliminate the possibility of addition soil impacts. This 

mitigation would be effective

1g. Prohibiting outfitters from creating new campsites would eliminate the possibility of 

additional soil damage at currently undisturbed sites.

6a&b. Limiting pack and saddle stock outfitter-guides to using only existing trails with wellestablished tread, and prohibiting the construction or maintenance of unauthorized trails 

would eliminate the potential for new soil displacement and compaction from new trails

8a. Encouraging loose grazing for stock would reduce impacts to soil in stock containment 

areas in campsites by limiting the amount of time the stock are contained. This would be 

only be moderately effective in reducing soil impacts since soil impacts in containment 

areas would still occur. 

8b. Locating stock containment facilities (corrals, hitch rails, high lines) in areas where offsite impacts to soil would be minimized would prevent soil additional soil damage, 

compacting, and displacement

8d. Prohibiting overnight picketing of stock in subalpine meadows would allow stock to 

move freely, avoiding any impacts to soil caused by stock staying in one spot and by 

dispersing the animals. 

10a. Prohibiting the cutting or removing of green trees and other live vegetation, and 

requiring efforts to minimize trampling or damaging vegetation would prevent soil damage 

that would occur if an area becomes devegetated. 

10b. Requiring soils displaced by activities such as latrine construction or pawing by stock 

to be replaced or smoothed out would be moderately effective in repairing soil damage. 

Potential benefits would be limited to areas where the disturbance does not occur again. 

10c. Establishing stock travel routes through wetlands would minimize soil compaction and 

displacement that would occur with braided trails or widening tread to avoid water. This 

would by minimally effective since stock are typically unsupervised when traveling to 

grazing areas, and could easily get off established trails. 

Soil Compaction

The level of soil compaction in any of these alternatives would be similar to Alternative 1. 

Forest Plan amendments included in Alternatives 2, 3, and 4 concerning the allowable amount 

of bare mineral soil in outfitter-guide camps in the Pasayten Wilderness and Lake ChelanSawtooth Wilderness, in conjunction with camp management mitigation measures, would result 

in a reduction in the amount of compacted bare mineral soil associated with existing outfitter 

camps in Alternatives 2 and 3, and would result in no increase with Alternative 4. It is expected 

that over time, unused areas under Alternatives 2 and 3 would recover with protective 

vegetation cover. The amount of time for the recovery would depend on the microclimate at 

the campsite location and use by non-outfitted recreationists. 
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The Forest Plan amendment concerning the use of campsites within 200 feet of meadows, 

streams, lakes, and key interest areas would be nearly consistent among the alternatives. In 

Alternatives 2 and 4, the pack and saddle stock outfitter-guides would be allowed to use existing 

campsites within this zone, so the existing condition and amount of soil compaction would not 

change except that the size of the camps within 200 feet would be limited. In Alternative 3, the 

outfitters would be prohibited from using campsites within 200 feet of wetlands, streams, lakes, 

or key interest areas so would not have camping impacts within these areas.

The total amount of compacted bare mineral soil in the Pasayten and Lake Chelan-Sawtooth 

Wilderness Areas would be somewhat reduced from the current condition. Figure 3.4-4 lists the 

campsites with over 2,800 square feet of barren core, and the amount that would be used by 

the outfitters in the three alternatives. Overall, the amount of barren core the outfitters could 

use in the Pasayten would be 105,571 square feet, or 2.4 acres in Alternative 2; 38,029 square 

feet, or 0.9 acres in Alternative 3; and 117,694 square feet or 2.7 acres in Alternative 4

(Appendix A). In the Lake Chelan-Sawtooth, the amount of barren core used would be the same 

in Alternatives 2 and 4 since no campsite has over 5,250 square feet of barren core. The 

outfitters could use a total of 48,534 square feet, or 1.1 acres in 2 and 4; and 30,660 square feet, 

or 0.7 acres in Alternative 3 (Appendix A). All existing barren core in campsites with less than 

2,800 square feet currently would be used by the outfitters in each alternative. The current 

amount of compacted and displaced soil in trails would not change with any alternative, nor 

would the amount of barren core in campsites outside wilderness, since there would be no 

limitation on barren core in these campsites. When compared to the acreage of the analysis 

area, camp areas and trails would be inconsequential; normal hydrologic functions would not be 

impaired. 

Figure 3.4-4. Established Camps in the Pasayten used by Outfitter Guides with over 2800 square feet of 

Barren Core Existing, Compared to Amount Available to Outfitters in Alternatives.

Camp Name Existing Square 

Feet of Barren 

Core

Square Feet of Barren Core Outfitters Could Use

Alternative 2 Alternative 3 Alternative 4

3 Fools 2,800 2,800 No OG Use 2,800

Bald Mountain 3,900 3,900 No OG Use 3,900

Beaver Creek 6,747 5,250 No OG Use 6,747

Chewuch 3,000 3,000 No OG Use 3,000

Corral Lake 3,500 3,500 2,800 3,500

Cougar Lake 2,916 2,916 2,800 2,916

Crow Lake 9,610 5,250 2,800 9,610

Crow Lake 2 7,000 5,250 2,800 7,000

Fred’s Lake 5,400 5,250 No OG Use 5,400

Goat Lakes Basin 

2 

3,000 3,000 2,800 3,000

Peeve Meadow 5,640 5,250 No OG Use 5,640

Sheep Mountain 8,879 5,250 2,800 8,879

Whistler Basin 4,020 4,020 No OG Use 4,020

Whistler 3,254 3,254 2,800 3,254
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Figure 3.4-5. Established Camps in the Lake Chelan-Sawtooth used by Outfitter Guides with over 2800 

square feet of Barren Core Existing, Compared to Amount Available to Outfitters in Alternatives.

Camp Name Existing Square 

Feet of Barren 

Core

Square Feet of Barren Core Outfitters Could Use

Alternative 2 Alternative 3 Alternative 4

Bike West 2,900 2,900 2,800 2,900

Twin Springs 1 3,071 3,071 2,800 3,071

Muleshoe 2 3,000 3,000 2,800 3,000

Muleshoe North 4,200 4,200 2,800 4,200

Silver Lake 4,540 4,540 No OG Use 4,540

Surprise 3,500 3,500 No OG Use 3,500

Soil Displacement

Most of the soil displacement in the analysis area is a result of past grazing and wildfires. This 

displacement is slowing stabilizing with emerging vegetation on stock driveways and burned 

areas. The pack and saddle stock outfitter-guide operations included in Alternatives 2, 3, and 4 

would result in little, if any soil displacement. Nearly all displacement that occurs in camps, at 

stock watering areas, or along trails would be trapped by surrounding understory vegetation. 

Grazing Practices Triggering Soil Erosion

The pack and saddle stock outfitter-guides would continue to use a combination of loose grazing 

and stock containment in Alternatives 2, 3, and 4, and the effects would be similar to the 

existing condition. Soil in stock containment areas within camps would be compacted and 

displaced, but there would be little to no erosion from these areas because they are relatively 

flat and surrounded by ground vegetation that would capture any eroding soil. Areas where the 

stock loose graze would have virtually no soil impacts because of the dry soil and vegetative 

cover. Stock traveling through wetlands to reach grazing areas would compact and displace the 

soil within the trails, but impacts to soils would be reduced somewhat by the requirement to 

establish the travel routes. Stock could still travel outside the established routes, so some soil 

damage could occur. These impacts would be too small and isolated to change conditions on 

the ground, and would approximate natural processes. The grazing would not prevent plant 

establishment or growth outside the stock containment areas. 

Recovery from historic sheep operations would be a slow process due to the level of past 

disturbance and locally harsh climatic conditions. Hence, there is no discernible difference for 

grazing practices that trigger soil erosion between any alternative.

Soil Effects at Stream Crossings

Soil effects at trail stream crossings would be similar to current conditions. . Most stream banks 

are well-vegetated, stable, and meet Forest Plan standards and guidelines. Alternatives 2, 3, 

and 4 would not further degrade stream banks at existing stream crossings or channel bedding 

characteristics since pack and saddle stock outfitter-guides would be restricted to using existing 

campsites and existing trails. At most stream crossings, banks already lay back and are at least 

six feet wide. These crossing are common and were likely the travel routes of historic sheep 

bands. The continued use of these stream crossings would not degrade stream reaches. The 

crossing areas are not expected to expand as a result of pack and saddle stock outfitter-guides 

since the current number of recreation visitor days associated with pack and saddle stock would 

only increase slightly with Alternative 2, decrease by 6% in Alternative 3, and increase by 8% in 
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Alternative 4, compared to the existing levels. The changes are simply not big enough to change 

the conditions on the ground.

Soil Erosion from Pack and Saddle Stock Watering Areas

The overall level of soil effects at stock watering areas would be similar to the current condition 

and Alternative 1. There could be slight changes in the collective size of the stock watering 

areas, because of the variations in stock days with the various alternatives. The number of stock 

watering at one time is the biggest influence on the amount of disturbed area at stock watering 

locations. Therefore, Alternative 3 would have the potential for the most reduction because of 

the reduced party size. The mitigation measure requiring camp management plans for assigned 

pack and saddle stock outfitter-guide camps would specifically address operations in pack and 

saddle stock watering areas. In addition, travel routes between camps and loose grazing areas 

would be managed to minimize the number of trails. This measure would s reduce soil 

trampling damage resulting from pack and saddle stock outfitter-guide activities at watering 

areas and from camps to watering areas.

Some soil erosion from pack and saddle stock use would continue, so soil erosion would occur at 

some of these wet soil/meadow watering areas. The erosion would not affect water quality 

beyond the isolated, localized areas due to their relative small size and infrequent occurrence.

Cumulative Effects

The spatial boundary for this cumulative effects analysis is the entire analysis area; soils don’t 

generally move from the general area (although transportation by water is covered in the water 

section below). The temporal boundary is from the early 1900s through approximately 2123, 50 

to 100 years after the expiration of the 10 year permits, when any soil damage caused by the 

pack and saddle stock outfitter-guides, and not perpetuated by other activities, would have 

recovered by natural processes. 

Reasonably Foreseeable Future Actions

Public use and other outfitter-guide activities would continue in camp areas and user trails, 

consequently the total square feet of compacted bare mineral soil in camps, trails, and 

driveways would continue. There would be an increase of approximately 30% in overall, nonoutfitted recreation use in the analysis area, however the number of people using pack and 

saddle stock is expected to decline (IAC Committee on Outdoor Recreation, 2003). This increase 

would perpetuate soil damage at existing recreation sites, and could lead to more impacted 

areas. Use on trails would also increase, and soil compaction and displacement from other trail 

users (hikers, horseback riders, trail bike riders, and mountain bikers) would increase slightly. 

The soil damage to trails in the Sawtooth Backcountry would be on a landscape scale, the 

increases will be minor because they would still be small and localized, and any soil disturbance 

would approximate natural processes.

The stream crossing near a large non-outfitted Remmel camp area will also continue to be void 

of vegetation due to continued use. The same would be true for other stream crossings in the 

analysis area. Due to the isolated nature, soil erosion at stream crossing would not cause 

degraded water quality beyond the immediate vicinity. Any erosion would not affect water 

quality beyond the isolated, local area due to relative small size and infrequent occurrence. 

Minor soil impacts in moist meadow areas is also expected to continue, but would not affect the 
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overall conditions due to the fact that use is isolated, and impacts only affect a small portion of 

the meadow area.

Trail maintenance would continue, including cleaning and reconstructing drainage 

structures as needed to minimize erosion and water channeling on trails.

Some livestock grazing would continue in the lower elevations of the analysis area. Grazing 

would be closely monitored as required by allotment management plans and little detrimental 

soil disturbance would occur. Permits would be managed to comply with Forest Plan standards 

and guides, including those pertaining to soils. 

Non-outfitted pack and saddle stock use would have limited measurable effect on displacement 

since the areas that continue to pose a risk for accelerated surface erosion are associated with 

historic grazing sites or fire line construction. Grazing from permitted horse use would also be 

monitored to insure that grazing utilization does not exceed Forest Plan Standards. With the 

amount of subalpine and alpine meadows there are ample foraging areas for recreation 

livestock. Typically grazing use by recreation livestock would not be concentrated for any length 

of time. 

Prescribed landscape burning would also continue. These prescribed burns would be designed 

and implemented with low fire severity and no detrimental soil disturbance effects are 

expected.

Wildland fires would occur in the future. High severity fires in some landform groups could 

increase debris slides events and flooding. This hydrologic response following wildland fires is a 

natural process that is well within the range of expected responses (USDA Forest Service 2003a). 

Fire suppression activities such as fire line construction with mechanized equipment would also 

continue. The firelines would be rehabilitated, but some erosion would occur before the 

vegetation recovers and the litter cover reestablishes. Adjoining vegetation communities trap 

and stabilize eroded material close to the source from these fire lines. Mitigation measures 

would be implemented for fire suppression activities. Based on this adverse “off-site” 

sedimentation is not expected from these fire lines.

There are no other reasonably foreseeable future actions that would have overlapping effects 

with the pack and saddle stock outfitter-guides. 

Summary for Alternatives 1, 2, 3, and 4 

The cumulative soil effects of Alternative 1, 2, 3, and 4, with all past, present, and reasonably 

foreseeable future actions are essentially the same. The cumulative differences between these 

four alternatives are so slight that the magnitude of difference is immeasurable. Hence, all four 

alternatives are evaluated together.

The cumulative effects of any of the four alternatives and all past, present, and reasonably 

foreseeable future actions would be that the total soil disturbance from trails, camps, stream 

crossings, wildland fires, and grazing areas would minor and scattered across the analysis area. 

The effects to soil from past grazing would continue to diminish over time, and the cumulative 
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impact of all reasonably foreseeable future actions, the alternatives, and the continuing 

recovery from grazing would be an improvement in soil conditions. 

Wildfires could damage soil, but there would be no cumulative on-site soil disturbances from 

recreation or management actions that would adversely impact natural nutrient or hydrologic 

cycles that could lead to off-site effects. On-site nutrient cycles would not be altered to the 

point that the vigor of adjoining vegetation communities would be reduced. In addition, on-site 

soil compaction, displacement, or erosion would not alter natural soil hydrologic process and 

lead to accelerated erosion and sedimentation into streams since effects from recreation and 

the outfitter-guides would be small and isolated, and management actions would be designed 

with soil protection measures. The level of detrimental soil disturbance evaluated at the 

watershed scale is immeasurable.

CONSISTENCY FINDINGS

All alternatives would be consistent with Regional policy and Forest Plan standards and 

guidelines for achieving soil objectives. 

The amount of soil compaction would be less that 0.1% of the total analysis area, and virtually 

no soil displacement or erosion would occur in campsites. Grazing practices would not trigger 

erosion. Soil erosion from stock containment areas would be captured by surrounding ground 

vegetation. Loose grazing would cause some soil trampling in travel routes through isolated 

wetlands leading to grazing areas, but these would not lead to surface or overland flow. Trail 

stream crossing would result in some erosion into waterways, but the sediment would be 

quickly dissipated by flowing stream water. There would be some erosion and evidence of 

trampling at stock watering locations, but these would not impact water quality because they 

would be isolated. 

All alternatives would also comply with the Forest Plan standards and guidelines, as amended by 

the alternatives.

The standards and guidelines pertaining to vegetation loss, and compacted bare mineral soil 

would be amended with each alternative, and the corresponding alternative would comply with 

the amended standard.

Okanogan Forest Plan:

13-7 Rehabilitate soil productivity, water quality, and land following any management 

activities that result in long-term site degradation to meet the goals of the 

Management Area.

The alternatives would not lead to long-term degradation of soil quality, with the 

exception of the barren core in campsites and along trails. These areas represent 

such a small portion of the overall landscape that soil productivity would not be 

impacted. No rehabilitation would be needed. 
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Okanogan and Wenatchee Forest Plans

Displacement and erosion of soil resulting from human activity will be limited to a 

rate that approximates natural processes.

None of the alternatives would cause displacement or soil erosion at rates greater 

than natural processes. Soil displacement would be limited to campsites, but any 

soil eroding from these relatively flat areas would be captured by the surrounding 

ground vegetation. There would be erosion at trail stream crossing, stock watering 

locations, and in stock trails leading across wetlands to reach grazing areas, but 

these would be isolated, and any sediment reaching waterways would be quickly 

dissipated by the flowing water.

Soil compaction should not exceed limits which will prevent natural plant 

establishment and growth, except at desired campsites, and in designated trail 

treads.

None of the alternatives would lead to soil compaction that would prevent natural 

plant establishment and growth away from campsites and trails. Outfitter-guide 

activities would be limited to loose grazing by pack stock, which would be dispersed 

and would not prevent plant establishment or growth.

3.5 HYDROLOGY

The section below is a summary of the Hydrology specialist reports which are available in the 

project analysis file (Garrigues 2012).

REGULATORY FRAMEWORK

Both the Okanogan and Wenatchee Forest Plans (USDA Forest Service 1989b and 1990) provide 

direction for the actions. The Record of Decision and Environmental Impact Statement for 

Amendments to Forest Service and Bureau of Land Management Planning Documents Within 

the Range of the Northern Spotted Owl (Northwest Forest Plan, USDA and USDI 1994); and 

Decision Notice and Environmental Assessment for the Interim Strategies for Managing Fishproducing Watersheds in Eastern Oregon and Washington, Idaho, and Portions of California 

(PACFISH, USDA and USDI 1995) amended the Forest Plans.

The Okanogan Forest Plan desired condition for water (page 4-5) includes:

Areas allocated to Wilderness will remain essentially unchanged, modified only by natural 

processes.

Forest soil productivity will be maintained. Water yield and quality will be substantially the 

same.

The Wenatchee Forest Plan desired condition for water resource management (page IV-57) 

includes:

Maintain favorable conditions of streamflow in regards to water quality, quantity, and 

timing of flows.

Meet or exceed Federal and Washington State water quality standards.
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All the design criteria and mitigation measures for water quality protection described in 

Chapter 2 are considered Best Management Practices (BMP, 40 CFR 130.2, EPA Water Quality 

Standards Regulation). Additional scientific guidance and background information is available 

within various Watershed Assessments, General Water Quality Best Management Practices 

(USDA 1988) and National Best Management Practices for Water Quality Management on 

National Forest Lands (USDA 2012c). The forest-wide standards and guidelines that apply to this 

project include:

Okanogan Forest Plan, Soil and Water (page 4-45)

13-2 All activities shall comply with state requirements for the protection of waters through 

planning, application, and monitoring of BMPs.

13-3 In cooperation with the state, the Forest shall use the following process:

1. Select and design BMPs based on site-specific conditions, technical, economic, and 

institutional feasibility, and the water quality standards for those waters potentially 

impacted.

2. Implement and enforce BMPs.

3. Monitor to ensure that practices are correctly applied as designed.

4. Monitor to determine the effectiveness of practices in meeting design expectations and 

in attaining water quality standards.

5. Evaluate monitoring results and mitigate where necessary to minimize impacts from 

activities where BMPs do not perform as expected.

6. Adjust BMP design standards and application when it is found that beneficial uses are 

not being protected and water quality standards are not being achieved to the desired 

level. Evaluate the appropriateness of water quality criteria for reasonably assuring 

protection of beneficial uses. Consider recommending adjustment of water quality 

standards.

In wilderness areas:

MA15B-13A (page 4-96) Soil compaction from human activities should not prevent 

natural plant establishment and growth except at some campsites, administrative 

facilities, and in designated tread.

MA15B-13B (page 4-96) Human activities should not degrade water quality except for 

temporary changes where water quality returns to its normal level when the activity 

ceases.

None of the management areas outside wilderness have management area specific standards 

and guidelines for water.

Wenatchee Forest Plan, Water (page IV-94)

Protection of water quality through planning, application, and monitoring of BMP’s (see above 

Okanogan Forest Standard and Guideline 13-3, items 1 through 6).
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In wilderness areas:

Figure 3.5-1. Physical-Biological Standards for Water in Wilderness areas

Wilderness Recreation Opportunity Spectrum Physical-Biological Standards

for Water

Primitive There should be no change in water quality except 

for temporary changes that return to normal when 

activity ceases.

Semi-Primitive and Transition There should be no change in water quality except 

for temporary changes that return to normal when 

activity ceases.

The portion of the Sawtooth Backcountry on the Chelan Ranger District is allocated to RE-1 

(developed recreation). Neither of these management prescriptions have management 

prescription specific standards and guidelines for water that apply to issuance of outfitter-guide 

permits.

The Clean Water Act, as amended in 1977, 1982, and 1987

The primary objective of this Act is to restore and maintain the integrity of the nation’s waters. 

The Clean Water Act requires each state to develop water quality standards. Water bodies that 

do not meet established standards are identified in the 303(d) list. This FEIS uses the 2012 

version of this list. Each state also prepares a non-degradation policy for all waters that exceed 

standards. This policy protects these waters from any further degradation. 

The Forest Service responsibilities under the Clean Water Act are defined in a November, 2000 

Memorandum of Understanding (MOU) between the Department of Ecology and the Forest 

Service. The MOU designates the Forest Service as the management agency for the State on 

National Forest System lands. This means that the Forest Service is responsible for defining and 

implementing appropriate Best Management Practices (BMP) for National Forest System land. 

Mitigation measures were developed by the IDT for this project and incorporate BMPs. 

Mitigation measures are identified in Chapter 2. All analysis below is with mitigation in place. 

ANALYSIS METHOD

Information used to establish baseline conditions and desired future conditions for hydrology, 

erosion rates, and runoff came from several sources. These sources include field observations, 

stream inventories, watershed assessments, stream flow data, and an erosion prediction model. 

Throughout this analysis, the best available information and science was incorporated to 

describe the ecological and social conditions within the analysis area, and the potential effects 

of the proposed outfitter-guide use on resources and people.

AFFECTED ENVIRONMENT

Hydrology

Annual runoff is related to precipitation. Much of the annual precipitation in the analysis area 

falls as snow, although rain falls sporadically May through September. Peak runoff generally 

follows snowmelt patterns. Snow accumulates in the late fall, winter and early spring. The 

accumulated snow usually peaks in April. It melts rapidly in late May or early June and 
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generates peak stream flows. Overland surface flow from uplands, meadows, and riparian areas 

only occurs during spring melt which is prior to the summer period when wilderness areas 

become accessible to the public. Base flows from groundwater become part of the stream flow 

in July, increasing in percentage of the flow until it is most or all of the surface flow through the 

fall and winter. Base flows are supplied by shallow ground water moving into streams. Winter 

rain-on-snow floods could increase late fall or winter stream flow, however these events have a 

low risk of occurrence. Temperatures of wintertime snowstorms rarely increase to above 

freezing, which is necessary for rain-on-snow events. Lower elevation sites like Alta Lake and 

the Bear/Ramsey/Volstead area have less seasonal snowfall and earlier snowmelt, generating 

lower peak flows and less base flow. Many streams in these units are intermittent.

Stream reaches in much of the analysis area are slightly or moderately entrenched in deep 

glacial-fluvial outwash or glacial till plastered on steep hillsides. Some hillsides have little glacial 

till and streams flow primarily on exposed bedrock. Residual rounded rocks are common in the 

largest streams. Sediment is moved quickly through steep reaches during high flow periods. 

Late season flow is supplied by subsurface flow through the riparian areas associated with each 

stream. The larger, downstream channels have organic debris in the stream composed of small 

trees and other woody debris. Woody material may be partially or almost entirely buried or 

captured in wood debris jams. Some of this surface material moves downstream with each 

large flood, eventually reaching river systems.

Stream flow from steep gradient streams is seasonal, peaking in the spring snowmelt and drying 

July through September. Riparian areas along these intermittent channels are relatively narrow, 

and do not sustain extended periods of stream flow. These streams are high energy due to high 

stream gradient, and may be associated with debris avalanches or failures. Large amounts of 

sediment move through these systems.

Other upper reaches in thicker glacial till have stream channels that are slightly to moderately 

entrenched. Stream gradients are low and riparian areas are wider with sustained stream flow 

throughout the year. This stream flow is sustained by ground water from areas next to streams, 

and seeps and springs not necessarily adjacent to streams. Sediment is readily stored in stream 

channels and lower stream energy limits sediment movement. Smaller streams in low elevation 

sites like Alta Lake and the Bear/Ramsey/Volstead area have narrow to almost non-existent 

riparian areas, so these streams have little to no base flow entering the stream. As a result 

these intermittent streams are dry most of the year.

Sedimentation

Natural fire is an integral process in sediment movement to the stream and can influence how 

sediment is transported in the stream channel. Fire changes vegetation characteristics and 

reduces soil cover in the short term, increasing the rate of erosion that contributes to the 

sediment loads in the stream. Sediment delivery is increased by higher rates of debris failures 

and surface erosion, so more sediment enters the streams and rivers, especially in wilderness 

and North Cascade areas. Fires also kill trees adjacent to stream, and some of the trees fall into 

the stream where individual trees or groups of trees raise the stream base level and sediment 

deposition occurs.

Stream reaches with low stream gradients, low flows, and stream energy, as at Alta Lake and 

Bear/Ramsey/Volstead areas, store hillside sediments which move slowly through the stream 
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reaches. Vegetation is scarce and no large woody debris occurs in these streams. In these 

areas, lower precipitation and higher temperatures influence the frequency and intensity of 

wildfires. Natural fire return intervals are shorter and fires normally burn with lower intensity 

because under natural conditions, fuel loads were low. This results in lower levels of increased 

erosion and sediments entering surface water following wildfires.

Large fires burned in the 1920s and again over the last ten years. The Rex and Deer Point Fires 

burned over 100,000 acres of the Chelan side of the Sawtooth Range in 2001 and 2002. The 

Thirtymile Fire also burned in 2001 into the lower portion of the Pasayten area. In 2003 the 

Farewell Creek fire burned over 80,000 acres, in parts of the Pasayten and North Cascades 

areas. Most of the Bear/Ramsey/Volstead area burned with the Tripod Fire in 2006. In fire 

areas, erosion rates are higher where past intense sheep grazing occurred. In higher elevations 

and wetter areas of the watersheds, fire intervals are longer than fire suppression has occurred, 

so sediment depositional rates are probably within their historic range of occurrence.

Water Temperature

None of the water resources in the permit area are listed as impaired for temperature on the 

2012 Washington State 303(d) list which is the most current listing. Downstream of the analysis 

area, water temperature is listed for the Chewuch River and the Methow River. The impaired 

segment on the Chewuch River is near the forest boundary and is several miles downstream 

from the proposed action activities. The impaired water segment on the Methow River is near 

Pateros and the closest activities in the proposed action would be several miles away near Alta 

Lake.

Grazing History

Sheep grazing and bedding patterns from the first half of the twentieth century continue to 

impact streams, riparian areas, and adjacent slopes in the Pasayten, Lake Chelan-Sawtooth, and 

North Cascades areas. Limited wet areas, associated with streams, lakes or seeps were 

compacted and vegetative composition was changed on some locations where heavy grazing 

occurred. Streambanks along wet area and ponds in the Pasayten still show the impact of heavy 

sheep grazing. In undisturbed conditions, banks and vegetation root masses generally overhung 

the water. When large numbers of sheep accessed water, streambanks were trampled and 

became void of vegetation. The annual rising and falling water levels, along with the harsh

weather conditions contributed to the degraded situation. Overhanging vegetation will likely 

take many decades to re-establish, because growing seasons are harsh and short.

In the mid-1950s, the type of livestock grazed changed from sheep to cattle. Herding was not as 

intense, cattle numbers were lower than previous sheep numbers, and the type of grazing 

changed resulting in more vegetation being left. The larger cattle did generate more impacts in 

the wettest areas because cattle have larger hooves and weigh more than sheep. 

Effects of Current Pack and Saddle Stock Activities

Domestic livestock and recreational livestock grazing, including pack and saddle stock outfitterguide activities, have caused small scale localized changes to streams and wetlands. At trailstream crossings without culverts or bridges, stream banks are broken down because traffic is 

concentrated at an isolated location. Since these trails are also used by hikers and in some 

limited areas, trail bikes, some of the impact is due to those other uses and it is difficult to 

allocate the level of disturbance due to the various uses. Overall the visitor use days by 
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permitted outfitter guides is approximately 3 % of the total use by hikers, and permitted or 

personal use stock. 

There may be a slight increase in stream sedimentation at some of these locations, but the 

sedimentation contribution from the damaged section of stream banks is not detectable 

compared to background in-stream bank erosion. Higher levels of stream sedimentation may 

come from trail erosion as water drains down the trail during high intensity rainstorms and 

empties into the stream at crossings if not diverted by water bars or crossdrains. 

Loose Grazing and Stock Containment

Outfitter guides use either loose grazing or containment as described in Section 3.1 OutfitterGuides, to care for stock on overnight wilderness and back country trips. Loose grazing results 

in greater dispersal and reduction in site impacts. While this allows free access to riparian areas 

and water sources, typically pack animals spend most of their time grazing on dryer non-riparian 

areas where grasses are more prevalent. Where containment methods are used, locations are 

chosen away from riparian areas to confine stock. Monitoring during permit administration has 

shown that these stock management techniques have reduced impacts to riparian areas and 

reduced risk of water contamination because the wider dispersal of use lessens micro site 

disturbance. Overland flow which could transport fecal material or sediment into surface 

waters normally only occurs during snowmelt conditions which are earlier in the season before 

wilderness areas are accessible to recreation users. Bacterial do not remain viable for extended 

periods in dry fecal material so levels will not accumulate over the longterm.

Fecal Coliform and Other Nutrients

None of the water resources in the analysis area are designated water quality limited category 5 

for fecal coliform on the 2012 Washington State 303(d) list which is the most recent currently 

available listing.

Coliform is a naturally occurring bacteria common in streams and lakes. Feces of wild and 

domestic animals, and humans contain coliform, so when animals or people defecate in or near 

waterways or lakes, the fecal coliform is introduced into the water. If ingested in high enough 

concentrations, the bacteria can cause a number of intestinal maladies, such as gastritis. 

Generally speaking, wild and domestic animals are typically unaffected by ingested fecal 

coliform, but humans tend to be more sensitive to the bacteria, especially if the contamination 

is from human feces. 

Fecal coliform is used as an indicator of bacterial stream contamination because it is relatively 

easier to analyze for than other potentially harmful species such as giardia or cryptosporidium. 

These other pathogens can be identified by spores but presence does not necessarily correlate 

with viability of the organism.

Waters within the analysis area have been designated by the State Department of Ecology with 

the water contact recreation bacteria criteria category of “extraordinary primary contact 

recreation”. The standard for this category states that fecal coliform organism levels must not 

exceed a geometric mean value of 50 colonies per 100 milliliter sample. This is for direct contact 

such as swimming in surface waters and lakes.
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None of the lakes or waterways in the analysis area are designated as domestic water sources. 

The State Department of Health regulates domestic water supplies and the bacteria standard is 

to not exceed one colony per 100 milliliter sample. This level is essentially impossible to meet 

from surface water sources due to natural background levels. Thus the state requires that 

surface water which is diverted for domestic use to be treated by some method. The Forest 

Service recommends that wilderness users treat all water collected for drinking or food 

preparation.

Water testing for bacteria is problematic from wilderness and backcountry areas because 

samples must be delivered to the analysis laboratory within 24 hours of collection, and must be 

kept cold prior to testing. Most of the outfitter guide camp areas are more than a days ride or 

hike from the trailheads, which are several hours drive to the nearest testing laboratories. 

Extensive and repetitive testing of background levels of fecal coliform, followed by testing when 

pack and saddle stock outfitter-guide stock and clients are in the area, would be required to 

determine the precise effect. For this reason, quantifiable bacteria data for the analysis area is 

non-existent. 40 CFR 1502.22 specifies the process to follow when there is incomplete or 

unavailable information. Information about the effect of pack and saddle stock outfitter-guides 

on fecal coliform levels is not relevant to determining effects simply because the number of 

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

background levels. The contribution of outfitter guided use is approximately three percent of 

the overall visitor use days for the analysis area. No reasonably foreseeable adverse impacts 

exist. 

Recreational pack stock, including pack and saddle stock of the outfitter-guides along with 

human users do introduce fecal coliform into waterways, adding to the background level from 

wildlife. Waterways in the vicinity of stock camps, at trail crossings and stock watering sites may 

have locally higher levels of the bacteria during some periods of time but no documented 

sampling has been conducted. Any increases are only occurring on a limited basis compared to 

the analysis area as a whole due to the fact that these campsites, trail crossings and stock 

watering sites are isolated and infrequent across the landscape. Fecal coliform levels near trail 

crossings and at stock watering sites may be elevated during snowmelt and rainstorms as animal 

manure is washed down trails or overland into the streams at crossings if not diverted by water 

bars or crossdrains, or into lakes. Along streams, however, dilution by streamflow keeps fecal 

coliform levels well below the state water quality standard. Coliform bacteria also have a 

limited time of viability when dried and exposed to sunlight, as occurs in grazing areas away 

from water. This further reduces the risk of surface water contamination.

Other nutrients which can affect water quality are phosphorus and nitrogen, neither of which 

have numeric state water standards been established by Washington State Department of 

Ecology. Sources of phosphorus are typically from domestic sewage leaching or industrial 

outfalls and not resulting from livestock pollution. Nitrogen levels can be high in livestock, 

wildlife, and human feces or urine. Introduced levels of nitrogen to surface waters from these 

sources in the wilderness are dispersed in time and space and no elevated levels have been 

documented in the analysis area. Micro site effects to vegetation from high concentrations of 

nitrogen have not been observed.
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Stream Flow

Pack and saddle stock have also changed the character of some wetlands. Wetlands occur in 

many areas within the permitted area. Only those in direct continuity to navigable waters are 

protected under the Clean Water Act. Trails passing though wetlands are usually compacted 

and water tends to migrate to the slightly lower elevation of the trail. This occurs even during 

some drying periods where the trail is lower than the wetland surface. The amount of water in 

the trail during much of the use period often leads to a muddy situation where livestock and 

hikers may have difficulty getting through the wetland. When users re-negotiate the wettest 

areas, they create other user-made trails that increase the impacted area. Users may also widen 

and deepen the impacted area. Water may begin to flow as a stream through the wetland, 

where the water previously infiltrated into the soil. The net effect is that water leaves small 

areas adjacent to trails in wetland faster than before. Since these wetlands contribute to late 

season flows in down slope streams, the change in the wetland may reduce late season flows in 

nearby downstream locations. The relative impact on the wetlands in all the areas is low 

because the affected wetlands are a small portion of the total wetlands, and impacts in any 

given wetland would be isolated to areas directly adjacent to trails. The contribution of outfitter 

guided use is most likely very small since their total is approximately three percent of the overall 

visitor use days for the analysis area.

ENVIRONMENTAL CONSEQUENCES

Direct and Indirect Effects

Alternative 1

Under the No Action Alternative, the existing levels of non-permitted personal stock use and 

hiking would continue throughout the analysis area. Existing trails and all existing camps would 

be available to the general public as they are now. Alternative 1 would result in a 15 percent 

reduction in total stock use over current conditions with permitted outfitter guides and a 3 

percent reduction in total visitor days (hikers plus stock users). 

Stream Sedimentation

The slight decrease in total stock use (15 percent reduction) would slightly reduce the risk of 

sedimentation at trail stream crossings without bridges or culverts, access points for watering 

and erosion from campsites. Because of the small level of reduction in use, the change in 

stream sedimentation and erosion would not be detectable or measurable compared to natural 

background inputs from ongoing channel and hill-slope erosion.

State 303(d) Listings Temperature

Shading along riparian areas and streams would not change with this alternative because of the 

relatively small reduction in use levels at existing crossings and riparian areas. As a result, there 

would be no measureable change in stream water temperatures within the analysis area or 

further downstream in 303(d) listed segments.

Fecal Coliform and Other Nutrients

With the slight reduction in stock use there would be a corresponding slight decrease in the risk 

of animal waste and associated fecal coliform or urine entering surface waters. This change 
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from current conditions is not expected to be detectable or measureable within the analysis 

area or downstream.

Streamflow

With the No Action Alternative, any changes in streamflow are not expected to be measurable 

or detectable within the current available accuracy of measurement techniques (5 to 10 

percent). With the slight reduction in stock use levels in this alternative, there would be a 

corresponding slight decrease in compacted soil area in riparian areas. This could lead to 

improved water storage and timing of streamflow but these changes are not expected to be 

measurable. 

Alternatives 2, 3, and 4

Stream Sedimentation

Outfitted pack and saddle stock would continue to slightly increase the risk of sedimentation 

when animals cross streams on trails without bridges or culverts or access streams for water and 

from soil erosion at campsites. Changes would not be detectable compared to ongoing channel 

and hill slope erosion, except at the point of disturbance in the stream channel during the time 

of traffic crossing in water. There would be no detectable difference in stream sedimentation 

between alternatives across the analysis area. Stream turbidity is not expected to change under 

any of the alternatives, because the suspended sediment would not change by measurable 

levels.

State 303(d) List Implications (water temperature)

No new created openings would occur in riparian or other areas in any alternative nor any 

measurable reduction in stream shading, so water temperature in any stream in the analysis 

area would not be raised as a result of pack and saddle stock outfitter-guide activities. 

Therefore, water temperature within the analysis area or further downstream in 303(d) listed 

segments would not change from current levels with any alternative.

Fecal Coliform and Other Nutrients

The slight changes in use levels with the action alternatives would not result in measurable or 

detectable changes from the current conditions for the risk of animal waste and associated fecal 

coliform or urine entering surface waters.

Stream Flow

No measurable changes in stream flow would occur in any alternative from pack and saddle 

stock activities. Outfitted pack and saddle stock use could result in reduced late-season water 

flow through portions of impacted wetlands if water flows down compacted trails and through 

the wetland more rapidly than in non-impacted wetlands but any changes are not expected to 

be measurable at the current accuracy level of streamflow measurement techniques (5 to 10 

percent accuracy) There are very few trails passing through wetlands anywhere in the analysis 

area, so any changes in late season flows as a result of this would be well within the natural 

variation in stream flow levels from year to year. Refer to the Botany section, beginning on 

page 3-48 for a detailed analysis of the impacts to wetlands.
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Best Management Practices

Alternatives 2, 3, and 4 include Best Management Practices (BMPs), to prevent non-point source 

water pollution and ensure compliance with the Clean Water Act and Washington 

Administrative Code Chapters 173-201 and 202. BMPs are included in the Mitigation Measures, 

which begin on page 2-19 of this FEIS, and would be part of the annual operation plans.

The campsite BMPs would help reduce soil disturbance and compaction in campsites. This 

would reduce the risk any decrease in water quality from increased sedimentation from soil 

erosion. (Mitigation measures 1 a-g)

The trail BMPs would reduce the potential of decreased water quality from erosion from 

trails. (Mitigation measures 6 a-c)

The sanitation BMPs would help reduce the risk of fecal matter in waterways, helping to 

protect water quality by reducing introduction of fecal coliform. (Mitigation measures 7 ae)

The stock containment and grazing BMPs would help reduce the risk of impacts to water 

quality from sedimentation and fecal coliform at trail crossings, watering spots, and 

campsites. (Mitigation measures 8 a-j)

The vegetation and soil BMPs would help reduce the risk of water quality impacts by 

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

damage to reduce erosion potential. (Mitigation measures 10 a-c)

The aquatic resources BMPs would help protect riparian areas, and reduce the risk of 

impacts to water quality from increased sedimentation, reduced shade, and hazardous 

materials. (Mitigation measures 12 a-g)

Because BMPs are expected to be fully implemented, water quality standards and the antidegradation policy (Chapter 173-201A WAC) are expected to be met with all alternatives. None 

of the alternatives would substantially alter the water quality. Full implementation of BMPs has 

been shown to be an effective method (90 percent or greater) in preventing and controlling 

nonpoint source water pollution (Rashin, 2006), (USDA Forest Service, 2007a). Monitoring 

would be conducted during the project in order to validate implementation and effectiveness of 

BMPs and assure compliance with the Clean Water Act, State water quality regulations and 

forest plan standards.

Alternative 2

Alternative 2 would permit 4,620 visitor days for pack and saddle stock outfitter-guides. This 

amount of use is only slightly higher than the recently permitted numbers (4% higher) and only 

0.6% higher total pack and saddle use, so all the effects described above under Current 

Condition would likely continue. The risk of fecal coliform entering surface waters may slightly 

increase from background natural levels due to permitted stock use but any changes would not 

be meaningful. With this alternative, at outfitter assigned sites and other high use areas, there 

would continue to be areas where stock use might result in locally higher fecal coliform levels. 
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This would occur on a limited basis compared to the analysis area as a whole. Along streams, 

dilution by streamflow would keep fecal coliform levels well below the state water quality 

standard based on the isolated and localized nature of campsite, trail crossings, and stock 

watering sites across the analysis area. 

The Forest Plan amendment to limit the amount of barren core area pack and saddle stock 

outfitter-guides could use (5,250 square feet) would reduce the risk of impairment to water 

resources by limiting camp impact areas. The Best Management Practices would also provide 

water resource protection. They would be effective since they would be included in the 

operating plan, with compliance required by the special use permit and yearly monitoring. 

Because background levels currently do not exceed detrimental fecal coliform levels, these 

BMPs would ensure that fecal coliform bacteria would not be raised to detrimental levels as a 

result of pack and saddle stock outfitter-guide activities.

The Forest Plan amendment to allow outfitter-guides to use existing campsites within 200 feet 

of meadows, streams, lakes, or key interest areas would not change the current effects to water 

quality described in the affected environment above, since the outfitter-guides and the public 

have been using these campsites for decades and no new sites would be allowed.

Alternative 3

Alternative 3 would permit 2,660 visitor days for pack and saddle stock outfitter-guides. This 

would be a 40% decrease in the number of recently permitted number of pack and saddle stock 

users and 6 percent decrease in total pack and saddle use levels. This small decrease would 

result in virtually no change from the current conditions described above, or with Alternatives 2 

or 4. Fecal coliform levels may decrease slightly from permitted stock use and background but 

any changes would not be meaningful. The reduced party size in the Forest Plan amendment 

with this alternative could also slightly reduce the introduction of fecal coliform simply because 

there would be fewer stock in each party. The risk of fecal coliform entering surface waters 

would be less than Alternative 2 but greater than Alternative 1; however the difference would 

be slight and not likely to be measurable. With this alternative, at outfitter assigned sites and 

other high use camps, there would continue to be areas where stock use might result in locally 

higher fecal coliform levels. Along streams, dilution by streamflow would keep fecal coliform 

levels well below the state water quality standard based on the isolated and localized nature of 

campsite, trail crossings, and stock watering sites being dispersed across the analysis area. 

The Forest Plan amendment to limit the amount of barren core pack and saddle stock outfitterguides are allowed to use, and the amendment to reduce the party size would reduce the risk of 

impairment to water resources by limiting camp impact areas, to a greater degree than 

Alternatives 2 or 4. The Best Management Practices listed above would also provide water 

resource protection. They would be effective since they would be included in the operating 

plan, with compliance required by the special use permit and annual monitoring. Because of 

background levels currently do not exceed detrimental fecal coliform levels, these BMPs would 

ensure that fecal coliform bacteria would not be raised to detrimental levels as a result of pack 

and saddle stock outfitter-guide activities. 

The Forest Plan amendment to prohibit pack and saddle stock outfitter-guides from using 

existing campsites within 200 feet of wetlands, streams, lakes, and key interest areas would 
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eliminate any impacts to water quality caused by pack and saddle stock outfitter-guides in the 

vicinity of these camps. The current impacts described above would continue however, since 

the camps would still be used by the non-outfitted public. The slight reduction in use in these 

campsites may slightly reduce the current impacts to water quality, but the overall effects would 

remain constant. 

Alternative 4

Alternative 4 would permit 6,700 visitor days for pack and saddle stock outfitter-guides. This 

would be a 50% increase over the current number of pack and saddle stock users and 8% 

increase in total pack and saddle use levels. This increase would be small enough to not change 

the current conditions described above at meaningful or quantifiable levels. As with 

Alternatives 2 and 3 described above, fecal coliform levels would be from both permitted and 

non-permitted stock use and background sources. At assigned sites (outfitters only) and other 

high use camps (outfitters and public), there would continue to be areas where stock use might 

result in locally higher fecal coliform levels. This would occur on a limited basis compared to the 

analysis area as a whole. Along streams, dilution by streamflow would keep fecal coliform levels 

well below the state water quality standard based on the isolated and localized nature of 

campsite, trail crossings, and stock watering sites being dispersed across the analysis area. 

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

established campsites but not increase the amount of barren core would reduce the risk of 

impairment to water resources by limiting camp impact areas, but to a lesser degree than 

Alternatives 2 or 3. The Best Management Practices would also provide water resource 

protection. They would be effective since they would be included in the operating plan, with 

compliance required by the special use permit and annual monitoring. Because of background 

levels currently do not exceed detrimental fecal coliform levels, these BMPs would ensure that 

fecal coliform bacteria would not be raised to detrimental levels as a result of pack and saddle 

stock outfitter-guide activities. 

The Forest Plan amendment to allow outfitter-guides to use existing campsites within 200 feet 

of meadows, streams, lakes, or key interest areas would not change the current effects to water 

quality described above, since the outfitter-guides and the public have been using these 

campsites for decades.

Cumulative Effects

Past, present, and foreseeable future actions in or near the analysis area are listed at the 

beginning of this chapter The spatial boundary for this cumulative effects analysis is the entire 

Methow and Lake Chelan watersheds. The temporal boundary is the early 1900s through 

approximately 2033, 10 years after the proposed 10 year special use permits would expire and 

any effects would cease. Those past, present, and reasonably foreseeable future actions that 

continue to affect hydrology are summarized below. All other actions would not contribute to 

cumulative effects. 
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Past, Present, and Reasonably Foreseeable Future Actions

Grazing

Residual effect from livestock grazing throughout the twentieth century continue to impact 

streams, riparian areas, and adjacent slopes in the Pasayten, Lake Chelan-Sawtooth, and Upper 

Methow areas. Limited wet areas, associated with streams, lakes or seeps were compacted and 

vegetative composition was changed on some locations where heavy grazing occurred. 

Streambanks along wet area/ponds in the Pasayten still show the impact of heavy sheep 

grazing. In undisturbed conditions, banks and vegetation root masses generally overhung the 

water. When large numbers of sheep accessed water, streambanks were trampled and became 

void of vegetation leading to increased rates of surface erosion and input of fine sediment to 

surface water. Overhanging vegetation will likely take many decades to re-establish, because 

growing seasons are harsh and short. The shift to cattle in the 1940s impacted more wetlands 

since cattle tend to congregate in riparian areas and have larger hooves and weigh more than 

sheep. 

Fire

Past fires over the analysis area have increased surface erosion rates and input of fine sediment 

to stream channels. In general, the moister streamside riparian areas do not burn as hot as 

uplands and thus sediment transport to surface water is reduced. 

Trail Conditions and Use

Commercial livestock and non-outfitted recreational livestock grazing may be causing small site 

specific local changes to streams and wetlands on a limited basis. At trail-stream crossings, 

stream banks are broken down because of the traffic at a single location. These damaged 

crossings may cause a slight increase in stream sedimentation, but the sedimentation 

contribution from the damaged section of stream banks is not detectable compared to instream bank erosion. More noticeable stream sedimentation may come from trail erosion as 

water drains down the trail during high intensity rainstorms and empties into the stream at 

crossings. Fecal coliform levels near these crossings may be elevated during snowmelt and 

rainstorms as horse manure is washed down the trail and into the stream but higher 

streamflows at these times increase the dilution factors.

Non-outfitted Recreation Use

The amount of recreation use on the Tonasket, Methow Valley, and Chelan Ranger Districts is 

expected to increase over the next ten years. The projected increases in use may contribute to 

higher fecal coliform levels or stream sedimentation in local areas where the use is the highest, 

but use is so dispersed any effect is expected to be localized and still meet water quality 

standards.

Other Actions

Trail maintenance and construction will continue at levels similar to the past five years. 

Developed campgrounds in the analysis area would remain open, with facilities maintained. 

Campground maintenance activities, such as building maintenance, cleaning, water system 

maintenance, hazard tree removal, and road maintenance would continue. These activities will 

not increase fecal coliform bacteria or stream sedimentation.
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Grazing in the Bear/Ramsey/Volstead area would continue at current levels and may cause 

localized increases in fecal coliforms and stream sedimentation, but the water quality standard 

for fecal coliform is expected to be met. No other livestock grazing is anticipated in the 

Pasayten or Lake Chelan-Sawtooth Wilderness Areas, the Sawtooth Backcountry, or the North 

Cascades Scenic Highway corridor. These activities will not increase fecal coliform bacteria or 

stream sedimentation. 

Wildfires may also occur throughout any of the analysis areas, but would not increase the fecal 

coliform bacteria level in stream flow or wetlands. Fire suppression activities such as fire line 

construction would likely occur with a wild fire. Rehabilitation occurs to divert surface water off 

the constructed firelines. These activities will not increase fecal coliform bacteria or stream 

sedimentation because transport to surface water is reduced. 

Alternatives 1, 2, 3, and 4

There would be no cumulative effect on fecal coliform levels from all past, present, and 

reasonably foreseeable future actions and any of the alternatives considered in this analysis 

since none of the alternatives would raise levels except at isolated stream sections near camps, 

trail crossings, or stock watering spots. There are no current 303(d) listings in the Methow River 

watershed for fecal coliform, and this would not change as a result of the cumulative effects of 

past, present, and reasonable foreseeable actions and the alternatives analyzed in this 

document. Additionally, none of the proposed actions or alternatives would have a cumulative 

effect on water temperature since none would result in loss of riparian vegetation that would 

result in increases in water temperatures in streams. Therefore, there would be no effect on 

the existing 303(d) temperature listing for the Chewuch River and the Methow River at Pateros, 

Washington.

CONSISTENCY FINDINGS

The Best Management Practices listed above and shown as mitigation measures in Chapter 2 

when implemented will ensure that all of the alternatives are consistent with the Okanogan and 

Wenatchee Forest Plans as amended by the Northwest Forest Plan and PACFISH. Based on the 

findings in this analysis, this project complies with the standards and guidelines listed above for 

the Okanogan and Wenatchee National Forests. The proposed Forest Plan amendments for 

Alternatives 2, 3, or 4 would provide water resource protection by implementing the BMP’s for 

camp management listed in Chapter 2. 

Okanogan Forest Plan, Soil and Water (page 4-45) and Wenatchee Forest Plan (page IV-94)

The alternatives would include Best Management Practices to ensure protection of water 

quality and meet the intent of the Clean Water Act and Washington Administrative Code 

Chapters 173-201 and 202. Water quality would be monitored as part of the riparian campsite 

monitoring described in Chapter 2. 

Okanogan Forest Plan MA15B-13A (page 4-96)

Soil compaction from human activities should not prevent natural plant establishment and 

growth except at some campsites, administrative facilities, and in designated tread.

None of the alternatives would prevent natural plant establishment or growth. Refer to 

section 3.4 Soil.
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Okanogan Forest Plan MA15B-13B (page 4-96) and Wenatchee Forest Plan

Human activities should not degrade water quality except for temporary changes where water 

quality returns to its normal level when the activity ceases.

Pack and saddle stock outfitter-guide activities would not degrade water quality except for 

temporary changes at trail stream crossings or stock watering areas. Water quality would 

return to background conditions once the outfitter-guide activities cease.

Clean Water Act

A segment the Chewuch River near the forest boundary and a segment of the Methow River 

near Pateros are listed on the 303(d) list as impaired for water temperature. The impaired 

segments of both rivers are well downstream of most of the analysis area. Alta Lake is the 

closest area to the impaired segment of the Methow River with a predominance of day use that 

is three miles from Pateros. Issuance of outfitter-guide special use permits would not have an 

effect on stream temperature on either of these localized reaches or at the 6th or 5th HUC scale. 

Therefore, this project would be consistent with the Clean Water Act.

Although the project may result in some localized increases in fecal coliform levels, dilution and 

cold temperatures that kill these bacteria would ensure bacteria levels are not raised to 

detrimental levels or would exceed the state water quality standard.

3.6 AQUATIC RESOURCES

The section below is a summary of the Aquatic Resources Report which is available in the 

project analysis file (Shull, 2012).

REGULATORY FRAMEWORK 

The original Okanogan and Wenatchee Forest Plans provides direction for the outfitter-guide 

analysis area (USDA Forest Service 1989b and 1990). The desired condition is for habitat that 

supports fish rearing, spawning, and migration to be in an improved state (Okanogan Plan USDA 

Forest Service 1989b page 4-5) and to maintain excellent water quality and provide the 

structural stream components necessary for diverse, high quality aquatic habitat for native 

anadromous and resident fish species (Wenatchee Plan USDA Forest Service 1990:IV-9). Fish 

habitat management objectives that apply to this project are: to maintain and improve fish 

habitat capability, and integrate fish and riparian habitat management into other multiple use 

activities. Pertinent goals to the proposed activity under the Okanogan Plan are for fish habitat 

to be managed to maintain or enhance its biological, chemical, and physical qualities. The 

structural and functional properties of aquatic systems will be managed to promote bank and 

channel stability and riparian areas will be managed to provide a continuing supply of large 

wood for fish habitat (USDA Forest Service 1989b page 4-2). Under the Wenatchee Plan, the 

goals include fish habitat, quantity and quality, be at least maintained at existing levels and both 

the availability and quality of habitat should show an improving trend. The primary objective for 

riparian areas is to maintain and enhance long-term productivity to provide for riparian 

dependent resources including water quality and fish (USDA Forest Service 1990: IV-40 & 41). 
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Okanogan-Wenatchee National Forest

Okanogan and Wenatchee Forest Plan Standards and Guidelines that apply to this project 

include: 1)maintain low fine sediment levels (<20% surface fines); 2) manage activities to not 

result in exceeding current Washington State water quality standards (Washington State 2006); 

3) maintain wood levels >100 large pieces/mile (USDA Forest Service 1989b pg 4-30 -32 & 

1990:IV-84 to IV-88).

The Northwest Forest Plan (NWFP) amended the Forest Plan in 1994 (USDA and USDI 1994). The 

NWFP includes an Aquatic Conservation Strategy (ACS) with four components: Riparian 

Reserves, Key Watersheds, Watershed Analysis, and Watershed Restoration. In addition the ACS 

includes nine objectives to direct management of National Forest System lands at the 

site/project and watershed scale that focus on maintaining and/or improving conditions and 

processes associated with streams and adjacent riparian areas. Standard and Guidelines in the 

NWFP for Riparian Reserves of particular relevance to the outfitter-guide project include: 

adjust or eliminate grazing [pack animals] practices to eliminate impacts that reduce or 

prevent attainment of ACS objectives; 

ensure existing livestock [packstock] facilities inside Riparian Reserves meet ACS 

objectives;

limit livestock [pack animals] trailing, bedding, watering, loading, and other handling 

efforts to those areas and times that will ensure ACS objectives are met; and

adjust or eliminate dispersed recreation practices that reduce or prevent attainment of 

ACS objectives and where adjustment measures are not effective, eliminate the practice 

or occupancy (USDA and USDI 1994:C-31 to C-33). 

A detailed discussion of each aquatic conservation strategy objective is included at the end of 

this section, under Consistency.

Watershed analyses were completed for all project area watersheds except for the Pasayten 

and Ashnola. Because these watersheds are not Key Watersheds, watershed analyses are not 

required. Natural resources are generally in excellent condition and human disturbance is 

limited to backcountry recreation and occasional fire suppression. All the watershed analyses 

available were reviewed for resource issues associated with commercial outfitter-guide services 

and none in the NWFP area identified concerns over the effects of existing outfitter-guide 

activity. Riparian and aquatic impacts from backcountry hiking, camping, and stock animals are 

minor and limited to primarily to trails and campsites that enter Riparian Reserves or Riparian 

Habitat Conservation Areas (RHCAs). Wilderness is managed for potential natural conditions 

with little impacts from humans. The Pasayten and Ashnola watersheds do not contain ESA 

listed fish and are not designated Key Watersheds. Due to this and the direction of managing 

wilderness to preserve ‘untrammeled’ natural character, it was decided Watershed Analyses 

were not warranted for these two watersheds. 

The Decision Notice and Environmental Assessment for the Interim Strategies for Managing 

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

(PACFISH, USDA and USDI 1995) amended the Okanogan Forest Plan in 1995. PACFISH includes 

five components directing management of riparian areas: Riparian Habitat Conservation Areas 

(RHCAs), Riparian Goals, Riparian Management Objectives (RMOs), Key Watersheds, and 

Watershed Analysis. The RMOs include eight objectives to guide management of National 

Forest System lands at the watershed scale that focus on maintaining and/or improving 

conditions and processes associated with streams and adjacent riparian. Standard and 
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Okanogan-Wenatchee National Forest

Guidelines in the PACFISH area for RHCAs of particular relevance to the outfitter-guide project 

include:

Limiting livestock [packstock] trailing, bedding, watering, salting, loading, and other 

handling efforts to those areas and times that will not reduce or prevent attainment of 

RMOs or adversely affect listed anadromous fish; 

Prohibit fuel wood cutting in Riparian Habitat Conservation Areas;

Operate recreation facilities, including trails and dispersed sites, in a manner that does 

not reduce or prevent attainment of the RMOs and avoids adverse effects on listed 

anadromous fish; 

Adjust dispersed and developed recreation a practices that reduce or prevent 

attainment of RMOs and adverse effects to listed anadromous fish; and

Address attainment of RMOs and potential effects on listed anadromous fish and 

designated critical habitat in wild and scenic rivers, wilderness, and other recreation 

management plans. 

All the completed watershed analyses for the analysis area were reviewed to determine if any 

commercial outfitter use included as part of this project was mentioned as a concern. Only one 

area had a documented concern about outfitter-guide activities, specifically along Toats Coulee 

Creek in the Sinlahekin Creek 5th field watershed (See Fisheries report for details). 

As part of the overall ACS and the PACFISH strategy, Key Watersheds were established to act as 

refugia and provide high quality habitat for aquatic species. Priorities within these Key 

Watersheds include maintaining and recovering at-risk fish stocks (USDA and USDI 1994: B-19 

and USDA and USDI 1995 C-19). The analysis area lies within the NWFP’s Upper Chewuch, Lower 

Chewuch, Upper Methow, Middle Methow, Lower Methow, Twisp, and Lost River 5th field Tier 1 

key watersheds, in addition to the Lightning, Lower Lake Chelan, Pasayten, Ross Lake, Ruby, and 

Stehekin watersheds which are not designated as key watersheds. In the PACFISH boundary, 

the analysis area includes four 5th field Hydrologic Unit Code (HUC) key watersheds: Upper 

Chewuch River, Lower Chewuch River, Middle Methow River, Lower Methow River, Salmon 

Creek, and Lower Silkameen River. Additionally, the Ashnola and Sinlahekin watersheds are 

within the PACFISH management area, but not designated as key watersheds. These watersheds 

contain fish species listed under the Endangered Species Act (ESA) and are considered to be 

PACFISH Key Watersheds. All of these Key Watersheds contribute directly to the conservation of 

at-risk anadromous salmonids, bull trout, and resident fish species (See fish report in the 

analysis file for more details).

The Endangered Species Act, amended Okanogan and Wenatchee Forest Plan direction, and the 

Magnuson-Stevens Fishery Conservation and Management Act require that consultation be 

completed with respect to effects of proposed activities on Endangered, Threatened, Critical 

Habitat, and Essential Fish Habitat. The NFMA directs the Forest Service to analyze effects of 

projects on Management Indicator Species identified in the Forest Plan, and to maintain viable 

populations of all species identified by the Regional Forester. The species and habitat of concern 

in the outfitter-guide project are described later in this section. Consultation was completed 

with the US Fish and Wildlife Service (USFWS) and National Marine Fisheries Service (NMFS). 

Letters of concurrence were received on November 13, 2012 from NMFS, and on January 28, 

2013 from the USFWS. The letters are included in Appendix M. 
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Okanogan-Wenatchee National Forest

ANALYSIS METHODS

Information used to establish the baseline conditions for aquatic and riparian habitat, fish 

population trends, and their distribution came from several sources including field observation, 

stream and lake surveys, and watershed analyses/assessments. Most information is from the 

last decade. Through this analysis, the best available information and science was considered.

The analysis area has an estimated 3,200 miles of stream within the project area that covers 

over one million acres. Information is lacking on streams in these watersheds. Habitat surveys 

have been completed for most of the major fish bearing streams (23 streams) in most of the 5th

field watersheds included in the analysis area. The process for addressing incomplete or 

unavailable information is found in 40 CFR 1502.22. The analysis of the alternatives did not find 

any reasonably foreseeable significant adverse impacts to aquatic habitat. Most of the streams 

are in steep mountainous terrain with steep gradients, rocky channels, and are resistant to 

disturbances from bank alteration associated with livestock use. Limited data for streams in 

wilderness and roadless areas suggests streams are generally in good condition due to the lack 

of human influence. The degree and area of scale of impacts would not compromise the overall 

high quality streams, lakes, or occupied fish habitat. Therefore, collecting data on most or all of 

the streams and wetlands in the project area is not important for analyzing overall project 

effects. See the Aquatic Specialist report in the analysis file for more details on the condition of 

streams in the project area and similar undeveloped areas and why data collection is not 

necessary practical for making conclusions on the existing conditions or effects from the 

proposed action. 

Okanogan Forest Plan standards (USDA Forest Service 1989b:4-30 to 4-32), Wenatchee Forest 

Plan standards (USDA Forest Service 1990: IV 83 to 96), Northwest Forest Plan standards (USDA 

and USDI 1994: C-30 to C-38), and PACFISH goals and RMOs (USDA and USDI 1995:C-3) and 

standards pertinent to the desired conditions at the 5th field HUC watershed scale were tracked 

through the analysis.

Aquatic habitat was evaluated at different spatial scales in order to assess project effects, as 

related to the ACS Objectives (USDA and USDI 1994: B-11) and RMOs (USDA and USDI 1995:C-4 

to C-6), at the watershed 5th field HUC scale. Site scale impacts were analyzed individually and 

then reanalyzed collectively to determine whether or not there is an effect to species or their 

habiat at the 6th field sub-watershed scale. 

Relevant ACS Objectives and RMOs are water temperature, large woody debris, water quality as 

affected by fine sediment, and riparian habitat.

The analysis area lies within the nineteen 5th field watersheds and sixty-six 6th field subwatersheds listed in Appendix H, which includes the Pasayten, Skagit, Ashnola, and Similkameen 

watersheds. These areas define the area of direct effects analysis is located within the analysis 

area. Indirect effects can occur downstream and will be further analyzed at the sub-watershed 

6

th and watershed 5th HUC scales.
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Okanogan-Wenatchee National Forest

AFFECTED ENVIRONMENT

The analysis area occurs along some streams and lakes containing ESA listed fish species. All of 

the 5th field watersheds in the Methow sub-basin and the ones on the Skagit side have listed fish 

species present.

Streams

The analysis area has an estimated 3,200 miles of stream. Figure 3.6-1 below breaks them down 

by 5th field watersheds that are within the analysis area units. Most streams are characterized 

by being moderate to high gradient with multiple springs throughout the entire analysis area. 

Generally, there is little human manipulation or disturbance of streams due to the remoteness 

and difficult access. 
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Okanogan-Wenatchee National Forest

Figure 3.6-1. Streams by 5th and 6th field watersheds and by Analysis Area.

5th Field Watershed Perennial 

Stream (mi)

Intermittent 

(mi)

Total Streams 

(mi)

ASHNOLA RIVER* 50.0 65.8 115.8

LIGHTNING CREEK 34.5 76.4 111.0

LOST RIVER 38.5 118.2 156.7

LOWER CHEWUCH RIVER 85.7 227.8 313.5

LOWER METHOW RIVER 83.9 172.6 256.5

LOWER SIMILKAMEEN RIVER 18.3 24.9 43.2

MIDDLE METHOW RIVER 97.5 241.0 338.5

PASAYTEN RIVER* 105.0 239.0 344.0

ROSS LAKE 14.4 34.8 49.2

RUBY CREEK 40.9 154.0 194.9

SALMON CREEK 56.7 44.5 101.2

SINLAHEKIN CREEK 117.9 96.4 214.3

TWISP RIVER 76.1 164.7 240.8

UPPER CHEWUCH RIVER 50.3 144.3 194.7

UPPER COLUMBIA-SWAMP CREEK* Not Available

UPPER METHOW RIVER 47.5 178.1 225.5

UPPER LAKE CHELAN Not Available 68.0

STEHEKIN Not Available 123.3

LOWER LAKE CHELAN Not Available 109.1

Total in Lake Chelan Watershed 556.7 1189.1 3200.0

*Stream flow character data was not available for the Chelan portion, the Columbia –Swamp Creek, Pasayten, and 

Ashnola River Watersheds. Information is lacking on streams in these watersheds. Most of the streams are in steep 

mountainous terrain with steep gradients, rocky channels, and are resistant to disturbances from bank alteration 

associated with livestock use. Limited data for streams in wilderness and roadless areas suggests streams are 

generally in good condition due to the lack of human influence. The spatial scale of impacts would not compromise 

the overall high quality fish habitat. Therefore, collecting data on most or all of the streams and wetlands in the 

project area is not important for analyzing overall project effects.
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Okanogan-Wenatchee National Forest

Existing conditions of 24 major fish bearing streams in the analysis area for aquatic and riparian 

habitat has been inventoried, dating back to 1995. Aquatic inventories were completed on the 

following streams in the analysis area (full survey reports are available in the analysis file):

Figure 3.6-2. Stream Surveys within Analysis Area

Watershed Survey 

Year

Stream

LIGHTNING CREEK 2002 Lightning Creek

PASAYTEN RIVER 1998 Pasayten River

LOST RIVER 2000 Lost River

UPPER CHEWUCH RIVER

2001/2008 Chewuch River

2003 Lake Creek

2005 Andrews Creek

RUBY CREEK

2001 Ruby Creek

1999 Granite Creek

1998 Slate Creek

1998 Canyon Creek

UPPER METHOW RIVER

2003 WF Methow River

2003 Robinson Creek

Lower Methow River 

1997 Foggy Dew Creek (upper reach in roadless area)

1997 Crater Creek

TWISP RIVER

2001 Twisp River

1995 East Fork Buttermilk Creek (in Wilderness)

1995 West Fork Buttermilk Creek (in Wilderness)

Middle Methow River

2005 Wolf Creek

2007 Blue Buck Creek

2000 Goat Creek (roads and timber harvest in drainage)

2004/ 2007 Blue Buck Creek (before and after 2006 fire, drainage has roads 

and past timber harvest)

UPPER LAKE CHELAN 2000 Prince Creek

LOWER LAKE CHELAN 2000 Safety Harbor Creek

The majority of disturbances along streams and lakes are localized where camps and day use 

areas are close to lakes and streams and stream-trail crossings. Trail crossings typically create 

localized disturbances to stream banks of about 10 feet on each side of the crossing. Streamside 

campsites used by outfitter-guides are present at low densities with 24 campsites along 3,200 

miles of streams. Projects to reduce water routing down trails that cause sediment delivery to 

adjacent streams have been implemented on most system trails across the analysis area. For 

example, water bars are a standard practice during trail design and are maintained through trail 

maintenance. 

The Remmel Lake/Spanish Camp area is an area frequently visited by outfitted and nonoutfitted pack and saddle stock users. Data on stream and riparian conditions in the Remmel 

Lake/Spanish Camp area of the Pasayten collected, during a 2000 survey, shows that overall 
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Okanogan-Wenatchee National Forest

PACFISH standard and guidelines are being met with the exception of two small reaches that are 

on an improving trend since the end of historic sheep grazing and unlimited recreational party 

sizes. All stream reaches inspected were well-vegetated, most had undercut banks, and bank 

erosion was generally limited to trail crossings.

Stream habitat indicators potentially affected by the proposed project are temperature, 

sediment, stream banks stability, large wood levels, and riparian habitat.

Appendix G shows the aquatic habitat parameters for major fish bearing streams within the 

analysis area. The stream surveys are included in the analysis file. The data are summarized 

below.

Temperature

Stream temperatures are generally good in the streams at higher elevations and are higher at 

the lower elevations, ranging from functioning at risk to not properly functioning based on ESA 

standards. Natural climatic conditions as well as recent fires that removed streamside canopy 

cover are likely major factors in the higher temperatures. A portion of the Chewuch River and 

Methow River are on the Washington State 303d list for high summer temperatures several 

miles downstream of the analysis area, but not actually in the analysis area. No 303d listed 

streams are located in the analysis area (WA DOE 2008). Surveys done on streams in wilderness 

or roadless areas during the Aquatic and Riparian Effectiveness Monitoring Program4(AREMP) 

surveys found stream temperatures to be within properly functioning ranges, suggesting their 

riparian canopies are intact, as a result of lack of past management activities. Therefore, the 

Forest Service estimates streams in the project have similar high functioning riparian areas. 

Exceptions are the Chewuch River and Lake Creek, where fires recently burned. The Chewuch 

likely has naturally higher stream temperatures due to its north/south orientation and naturally 

high width:depth ratio (average channel width divided by the average max depth) that creates 

high solar exposure. Lake Creek water that leaves Black Lake comes off the top where it also 

receives high solar exposure and tends to be warmer. Overall, temperatures are considered 

functioning at risk but not due to recreation use because riparian canopies are generally in good 

condition. The stream surveys are located in the analysis file.

The primary mechanism by which stream temperature would affect by outfitter-guides is the 

removal of shade producing vegetation. 

Current outfitter-guide activities are having little to no impact on stream shade or impact to 

stream temperature. Outfitter-guide use occurs mostly on existing trails and campsites. Some 

minor vegetation loss occurs where trails and camps occur near water, but these sites are small 

in size and represent a small fraction of the total stream miles and lakes across the project area. 

Loose grazing occurs on ridge tops mostly with little access to streams and riparian areas. In 

general, horses and mules prefer grass to shrubs and trees, which would not affect the 

vegetative canopy providing stream shading. Based on the low frequency of use and the little 

time spent at the camp, outfitter-guide impacts to water temperature are inconsequential. 

Data for streams in wilderness areas with trails and stock use across available, north central 

 

4

AREMP characterizes the ecological condition of watersheds and aquatic ecosystems to whether the 

Northwest Forest Plan (NWFP) is maintaining or restoring aquatic and riparian ecosystems to desired 

conditions on federal lands in the Forest Plan area.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-190 February 2013

Okanogan-Wenatchee National Forest

Washington, shows riparian areas are functioning for providing adequate shade and 

temperatures are not impacted. 

Sediment

Stream sediment levels are generally low across the analysis area. Roads are considered one of 

the greatest sources of fine sediment for streams. Most streams across the analysis area are in 

wilderness or roadless areas, where there are few to no roads. Between 1995 and 2008, the 

Forest Service took fine sediment measurements in 14 streams within the project area that are 

within wilderness or roadless areas. The average fine sediment levels (<2mm) was 6.8% with a 

range of 2.5-12% of the total channel substrates. The AREMP program took fine sediment 

measurements in mid and north-central Washington, also within roadless or wilderness areas 

and found the average fine sediment to be less than 4%. Fine sediments in most streams within 

the project area likely similarly low because there is little human influence. Exceptions are areas 

with naturally high erosive soils and naturally have higher fine sediment levels such as the 

Chewuch, Sinlahekin, and Chelan watersheds (USDA 1994 & USDA 2000b), or where recent fires 

occurred. Based on the field observations of stream surveys in the analysis area (See stream 

surveys listed in analysis file) and the observations from the AREMP Surveys, fine sediment are 

estimated to be low and properly functioning. 

Excessive bank erosion can lead to high sediment levels. Most of the land in the project 

boundary is steep, mountainous terrain. Streams have mostly steep gradients (4- >10%) and are 

characterized by larger sized rocks in the channel and streambanks. These channels are 

consistent with Montgomery and Buffington’s (1997) definition of cascade and step-pool 

morphology channels, which occur on steep slopes, confined valleys, and cobble and boulder 

substrates. These channel types tend to be very stable that are resistant to bank erosion and 

channel incision due to the coarse bed and bank material. The 2000 field survey of streams in 

the Remmel/Spanish Camp (in Appendix G) areas found mostly low bank erosion. Low bank 

erosion rates observed at most sites indicates the stream banks are receiving little bank 

disturbance and the channels likely have natural fine sediment levels. The higher width:depth 

ratios can indicate higher fine sediment levels and can be a sign of poor conditions, but the low 

bank erosion rates suggest it may be natural. 

Based on the past stream surveys in the project area and data from other surveys within 

wilderness and roadless areas described above, the fine sediment levels are estimated to be low 

and properly functioning for the entire project area. 

Large Wood

Large wood levels were found to meet or exceed ESA standards for 16 out of 23 surveyed 

streams in the analysis area, but not the Okanogan and Wenatchee Forest Plan standards. The 

Forest Plan standards for wood are much higher then set by NMFS, U.S. Fish and Wildlife 

Service, and PACFISH, which are 20 pieces greater than 12 inches diameter and 35 feet or longer 

per mile compared to 106 pieces per mile under the Forest Plans. A recent publication looked at 

natural wood levels in undisturbed rivers in eastern Washington and found 33 pieces of large 

wood per mile to be properly functioning (Fox and Bolton 2007). Areas with lower wood levels 

were noted as being a natural condition due to the channel gradient and valley type. One 

exception was Granite Creek, which is right next to Highway 20, the construction of which was 

completed in 1964, removed a substantial portion of the wood source. Width:depth ratios can 

be an indicator of wood levels as large wood can promote scour and low ratios. Most ratios 
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-191 February 2013

Okanogan-Wenatchee National Forest

were low during the 2000 survey in the Pasayten (refer to analysis file), suggesting channel 

structure such as wood are adequate. Since timber harvest is prohibited by management 

direction along most streams in the analysis area, wood levels and recruitment are likely at or 

near natural levels. Therefore the existing wood levels are considered to be functioning 

appropriately for the analysis area as a whole. 

Current outfitter-guide activities are having no impact on instream-large wood levels. They are 

prohibited from removing wood from streams or cutting down standing trees. An exception is 

hazardous snags, but this effect would be too inconsequential to affect wood levels. 

Riparian Reserves/Riparian Habitat Conservation Areas

With little to no human disturbance across most the analysis area, it is likely nearly all riparian 

areas are intact and properly functioning. There are 28 camps within the Riparian 

Reserves/Riparian Habitat Conservation Areas for streams and lakes. Forested streams in the 

project, which represent nearly all streams, are well protected from human disturbance by 

downed wood and dense forest and are considered to be functioning at natural capability. 

Minor riparian canopy modification has occurred in localized areas, especially in riparian areas 

more open such as non-forested streams. There have been substantial reductions in sheep and 

cattle grazing across the entire analysis area (and entirely within the Pasayten and Lake ChelanSawtooth Wildernesses), resulting in riparian and stream function improving as seen in the 2000 

Remmel/Spanish Camp field survey. Overall, riparian areas are functioning appropriately at the 

reach, 6thand 5th field scale (See stream surveys and field repots listed in analysis file). 

Lakes

There are 530 lakes within the analysis area (see Figure 3.1-2). Existing conditions of lakes in the 

analysis area for aquatic and riparian habitat has been inventoried, dating back to 1994. High 

lake aquatic inventories were completed on the following lakes in the analysis area (full survey 

reports are available in the analysis file):

Swamp, Cabinet, Jerry (1-4), Lewis, Wing, Subzero, and Freeze-out Lakes within the Skagit 

River basin which is within the Lake Chelan - Sawtooth Wilderness and Sawtooth 

backcountry, North Cascades Scenic Highway, and Pasayten Wilderness in 1998.

Cougar Lake, First Hidden Lake, Big Hidden Lake, and Middle Hidden Lake within the

Pasayten Wilderness in 1995.

Cub Lake, Boiling, Bernice Lake, and Surprise Lake in the Chelan Sawtooth Wilderness in 

2000 (Entiat Ranger District).

Remmel, Cornell, and Lower Cathedral lakes in the Spanish Camp area of the Pasayten 

Wilderness in 2001.

Crow, Corral, Sheep, Quartz, and Ramon Lakes within the Pasayten Wilderness in 2002.
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Figure 3.6-3. Number of Lakes in the Analysis Area.

Location Number of Lakes

Bear/Ramsey/Volstead 21

Sawtooth Backcountry/Chelan 10

Sawtooth Backcountry/Methow 25

Middle Methow 9

North Cascades 57

Pasayten Wilderness/Methow 283

Pasayten Wilderness/Tonasket 51

Lake Chelan-Sawtooth/ Chelan 16

Lake Chelan-Sawtooth/Methow 53

Seventeen lakes in the analysis area have been surveyed, and six had frequent human use. 

Detailed results of the lake surveys are included in the analysis file. Observations made during 

lake surveys shows that lakes used by the stock have moderate to high impacts, but most lakes 

used by the outfitter-guides are for drop camps or for day use and the stock do not stay there 

more than a few hours. Outfitter-guide stock are generally controlled and are considered to 

contribute a small fraction of the overall stock effects that includes the general public. The 

majority of the use is considered from the general public stock use. 

Water quality data is shown in Figure 3.1-3 for lakes on the Chelan District portion of the 

analysis area. Water quality for the Methow Valley Ranger District is not available for lakes. 

Similar data has been collected for 16 Methow Valley lakes with no water quality problems 

identified. Fecal Coliform data, which is a bacterium that originates in feces, has not been 

collected for lakes in the Methow Valley. Fecal coliform levels in lakes could be elevated if loose 

grazing stock congregate on the lake shore. Snowmelt and rainstorms could wash manure into 

lakes, however coliform bacteria have a limited time of viability when dried and exposed to 

sunlight which reduces the risk of surface water contamination. Refer to the Water Resources 

section for more information about fecal coliform. 

Lake Chelan and its tributaries are subject to State Lake Class and Class AA (extraordinary) water 

quality standards as determined by Washington State Department of Ecology (DOE) using 

parameters defined by the Clean Water Act (CWA) 303(d) regulations. In the analysis area there 

are no CWA 303(d) listed water bodies (although see stream information above – there are 

some downstream listings), although lower Lake Chelan is listed for DDT and PCBs likely caused 

by orchard spraying. The four alpine lakes within the analysis area were surveyed and sampled 

in August 2000. Sampling results are presented in Figure 3.1-3 with US EPA (1987) median 

reference values of surveyed lakes in the Pacific Northwest.

The parameter values for year 2000 samples show these lakes to have low primary productivity 

(from low nutrient contents) with high water quality, low nutrient inputs, and low organic 

production. Overall water analysis compares favorably to median reference values. The 

parameters with the greatest departure from the median reference values are due to the 

mineral characteristics of the Oval Peak Batholith that consists of tonalite and tonalite gneiss 

(igneous type rock). The most important indicator of contamination by humans and mammals, 

total coliform, was low (<1.1 colonies/100ml of sample volume) in Cub and Boiling Lakes 

analyzed for this parameter. These two lakes receive the greatest recreational usage of the four 

lakes measured. 
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Okanogan-Wenatchee National Forest

Figure 3.6-4. Results of Water Analysis for Lakes Within the Lake Chelan-Sawtooth Wilderness on the 

Chelan Ranger District 

Parameter Cub Boiling Bernice Surprise Reference value

Sodium (mg/L) 1.12 0.92 0.62 † 0.425

Potassium (mg/L)

Calcium (mg/L)

Magnesium (mg/L)

0.45

2.53

0.38

0.39

1.69

0.24

0.20

0.68

0.08

†

†

†

0.339

1.958

0.203

Nitrate (mg/L-N)

Ammonia (mg/L)

0.00

0.11

0.00

0.15

0.00

0.12

†

†

0.006

0.00

Chloride (mg/L)

Sulfate (mg/L)

Total Phosphorus (mg P/L)

0.1

1.0

0.020

0.10

2.23

0.048

0.08

2.07

0.017

†

†

0.022

0.124

1.144

0.0035

Total Coliform (col/100ml) <1.1 <1.1 † † <50 col/100ml

WA State DOE

pH

Conductivity (μS/cm)

ANC (μEQ/L)

7.0

19.6

185.5

6.7

14.8

95.4

6.2 

8.27 

20.9

7.6

†

†

7.0

13.6

89.5

Alkalinity (mg/L)

Chlorophyll a (μg/L)

194.34

0.7

104.71

1.5

27.75

0.5

†

1.0

>20

1.9

† = no data

(Full reports available in analysis file).
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Figure 3.6-5. Results of Water Analysis for Lakes on the Methow Valley Ranger District 

Lake Name Total –P 

in mg/L

NO3+NO2 

in mg/L

Sulfate in 

mg/L

Chloride in 

mg/L

Calcium in 

mg/L

Magnesiu

m in mg/L

Potassiu

m in 

mg/L

Sodium 

in mg/L

Chlorop

hyll a in 

ug/L

pH

Conductivit

y umho/per 

cm 

Alkalinit

y CaC03 

ueq/L

Crow 0.01 <0.010 <1.00 0.8 4.8 1.32 <0.500 <0.500 1.2

Corral 0.008 <0.010 <1.00 0.6 1.32 0.343 <0.500 <0.500 0.2

Sheep 0.006 <0.010 1.81 0.6 2.3 0.429 <0.500 <0.500 <0.1

Quartz 0.006 <0.010 <0.010 0.6 4.41 1.32 <0.500 <0.500 <0.1

Ramon 0.016 <0.010 <0.010 0.6 2.42 0.424 <0.500 <0.500 1.1

Cooney 0.009 0.002 0.86 0.143 0.25 0.78

Swamp 0 0.001 0.09 0.12 2.1 0.301 0.08 0.61 7.2 17 166.93

Cabinet 0.002 0.001 0.25 0.22 5.97 0.466 0.18 0.78 7.6 38.6 386.19

Jerry 1 0.001 0.004 0.19 0.15 3.14 0.388 0.06 0.32 7.4 22.5 224.33

Jerry 2 0.002 0.01 0.18 0.15 3.28 0.421 0.07 0.34 7.5 28.5 234.53

Jerry 3 0.001 0.004 0.19 0.2 3.33 0.375 0.07 0.33 7.4 23.3 236.57

Jerry 4 0.001 0 0.09 0.16 0.95 0.175 0.04 0.19 6.8 7.7 87.69

Lewis 0.004 0 0.11 0.15 2.56 0.316 0.14 0.26 7.3 18.4 200.89

Wing 0.003 0 0.12 0.29 1.98 0.326 0.09 0.32 7.2 15.4 159.89

Subzero 0.002 0 0.82 0.17 4.59 0.117 0.17 0.45 7.4 28.6 239.4

Freez-out 0.003 0 0.86 0.2 6.9 0.391 0.12 0.64 7.6 43.7 385.47

Reference 

value 0.0035 0.006 1.144 0.124 1.958 0.203 0.339 0.425 1.9 7 13.6 >20

(Full reports available in analysis file).
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Okanogan-Wenatchee National Forest

Fish

The analysis area contains or is adjacent habitat for fish species listed under the ESA, 

Management Indicator Species (MIS), and species for which Essential Fish Habitat (EFH) has 

been designated under the Magnuson-Stevens Fishery Conservation and Management Act. EFH 

in the Methow and around the project area is designated where Chinook and coho are present. 

Since Chinook have higher distribution, the Forest Service uses Chinook’s distribution for a 

surrogate of EFH because they have similar habitat preferences. Regional Forester’s Sensitive 

Species, which include pygmy whitefish, Umatilla dace, and river lamprey are not found within 

the project area boundary or within the effects analysis area and thus will not be discussed 

further. Under the 2008 Regional Forester’s Sensitive species list, westslope cutthroat trout and 

inland redband trout were listed. These species were dropped for the 2011 updated list, but this 

aquatics analysis will include specific analysis for these species. See Figure 3.1-4 below for ESA 

listed, sensitive, MIS, and EFH.

Figure 3.6-6. Fish Species by Category Present in or adjacent to the Analysis area.

ESA Sensitive MIS EFH

Spring Chinook (Endangered) Pygmy 

Whitefish

Spring Chinook

Westslope Cutthroat Chinook

Summer Steelhead (Threatened) Umatilla 

Dace

Inland redband Rainbow

Bull Trout (Threatened) River 

Lamprey Steelhead Coho

Bull Trout

Eastern Brook Trout

Sockeye 

Summer Chinook

Bull Trout

The U.S. Fish and Wildlife Service (FWS) listed the Columbia River population of bull trout 

(Salvelinus confluentus) as threatened on 06/10/1998 (63 FR 31647). The FWS designated 

critical habitat for Columbia River Bull Trout throughout their U.S. range on September 30, 2010 

(75 FR 63897). The entire Chewuch River from its confluence with the Methow River to 

Chewuch Falls at about River Mile (RM) 34 is designated critical habitat for the species. Other 

critical habitat streams in the project area include the lower Lightning Creek system and Canyon 

Creek in the Ross Lake drainage portion of the Pasayten; Lost River and upper reaches of Lake 

Creek and the Chewuch River the Pasayten; Goat Creek, the upper Methow River, Trout Creek, 

and Early Winters Creek in the Upper Methow area; Blue Buck Creek and upper Beaver Creek in 

the Bear/Ramsey/Volstead area; the upper Twisp River and Buttermilk drainage in the Sawtooth 

Wilderness and Middle Methow areas; and parts of upper Gold Creek and Foggy Dew Creek in 

the Sawtooth Backcountry area (Figure 3.1-5).
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The Upper Chewuch River Watershed is estimated to support between 5% and 25% of the 

migratory type bull trout spawning in the Methow Sub-basin, based on incomplete data from 

1995 to 2008. Bull trout production appears to not have been reduced by the Farewell and 

Thirtymile Fires and may have been improved, based on an increase in redd (spawning nest) 

counts since before the fires. 

One of the most important habitat requirements for bull trout is cold water because of their 

requirement for cold water for spawning and rearing. Generally, bull trout use is limited in 

streams when temperatures exceed 59D Fahrenheit (Reiman and McIntyre 1993). During the 

summer, water temperatures in the lower 15 to 20 miles of the Chewuch are considered to be 

too warm for ideal bull trout rearing and foraging habitat, except for the area near the 

confluence with Eightmile Creek, which provides a cold water influence to the mainstem river. 

Bull trout foraging and rearing are believed to increase in the lower mainstem during the spring, 

fall, and winter when temperatures are more favorable. Fluvial bull trout redds and individuals 

have been documented in Eightmile Creek below a suspected barrier at RM 1.6. 

Spring Chinook 

Upper Columbia River (UCR) Spring-run Chinook salmon (Oncorhynchus tshawytscha) were 

listed as an endangered species on March 24, 1999 (64 FR 14308) and their endangered status 

was reaffirmed on June 28, 2005 (70 FR 37160). The National Marine Fisheries Service (NMFS) 

designated Critical Habitat on September 2, 2005 (70 FR 52630). 

Designated spring Chinook critical habitat in the analysis area includes the Chewuch River from 

its confluence with the Methow River to the barrier falls at RM 36.6, as well as short reaches of 

several tributaries including lower Eightmile, lower Cub, lower Boulder and Lake Creeks; the 

upper Methow/West Fork Methow to about Trout Creek, Lost River from its confluence with the 

Methow River to about Monument Creek; Early Winters Creek; lower Wolf Creek just below the 

project area; the Twisp River from its confluence with the Methow River to Road’s End 

campground; Beaver Creek to the confluence of Middle Fork Beaver Creek; Gold Creek from its 

confluence with the Methow River to just below Foggy Dew Creek (the project area boundary) 

(Figure 3.1-5). 

The most recent NMFS UCR spring-run Chinook salmon status review was in 2005 (Good et al. 

2005) and describes the population level, as a whole, on a downward trend for the last 40 years. 

Since 1958, the entire Methow Sub-basin spawning population trend has been on a declining 

rate of 6.3% per year. 

Steelhead

UCR steelhead were listed as an endangered species on August 18, 1997 (62 FR 43937) and their 

status was downgraded to threatened on January 5, 2006 (71 FR 834). NMFS designated Critical 

Habitat for UCR steelhead on September 2, 2005 (70 FR 52630).

Designated critical habitat in the analysis area includes the Chewuch River from its confluence 

with the Methow River to the barrier falls at RM 36.6, as well as Lake Creek from its confluence 

with the Chewuch River to Black Lake, and short reaches of several tributaries to the Chewuch 

River including lower Andrews, Twentymile, Eightmile, Cub, and Boulder creeks; the upper 

Methow/West Fork Methow to about Robinson Creek, Lost River from its confluence with the 
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Methow River to about Monument Creek; lower Early Winters Creek; lower Wolf Creek; the 

Twisp River from its confluence with the Methow River to Road’s End campground, as well as its 

lower South, War, and Buttermilk creeks tributaries; and Gold Creek from its confluence with 

the Methow River to just beyond and into Foggy Dew Creek (Figure 3.1-5). 

In the latest status review (Good et al. 2005), abundance for the entire UCR population was 

noted to be on the increase, though the run continues to be composed of a high proportion of 

hatchery origin fish, still well below the interim recovery levels identified for the population. 

Adult steelhead returns to the Methow Sub-basin, the primary natural reproduction area above 

Wells Dam, has been on an upward trend since the mid-1990s. 

Inland Redband Trout

Inland redband rainbow trout (O. mykiss) are the native form of rainbow trout in the interior 

Columbia River basin and are native to the Methow Sub-basin. Redband trout are the resident 

form of rainbow trout while steelhead are the anadromous form. They contain the genetic and 

physical ability to change to steelhead, which largely depends on environmental conditions such 

as temperature. Mullan et al. (1992), speculated that colder temperatures in headwater streams 

leads to rainbow trout remaining in streams as ‘resident’ fish versus going out to sea as 

steelhead. 

Redband rainbow trout is an Okanogan National Forest Management Indicator Species, which 

are ecological indicators for the effects of management activities on other species of selected 

major biological communities or on water quality. Redband trout are found throughout the 

Methow Valley sub-basin in streams with barriers below and streams connected with 

anadromous streams. 

Non-native rainbow trout were historically stocked throughout the Methow sub-basin; stocking 

has since been restricted to isolated lakes, though many stream and lake subpopulations have 

likely experienced interbreeding between native and non-native trout. Despite this, relatively 

pure populations continue to exist in isolated locations around the sub-basin (Proebstel et al. 

1998). Rainbow trout from the Lower Chewuch Watershed show signs of hybridization with 

coastal rainbow trout and, in some locations, with cutthroat trout (Proebstel et al. 1998) though 

some level of natural hybridization has likely occurred. O. mykiss specimens sampled from 

several locations along Eightmile Creek were determined by Proebstel et al. to be derived from 

or influenced by coastal rainbow trout. Genetically pure populations are found in pockets 

including Little Bridge Creek (Twisp), Goat Creek, Buttermilk Creek, and potentially more remote 

stream such as those in the Ashnola and Pasayten drainages; however distribution and genetics 

data on these populations are unavailable. Population trend data for the Methow Valley Subbasin or the analysis area are not available, but the general distribution and population trend is 

considered depressed from historical ranges and population numbers (Thurow et al. 1997). 

Westslope Cutthroat Trout (WCT)

Westslope cutthroat trout (O. clarki lewisi) are native to the Methow and Chelan Sub-basins and 

are Okanogan and Wenatchee Forest Plan MIS species. Their populations are generally found in 

isolated areas in the upper elevations of the sub-basin, distributed above rainbow trout 

populations, often with a hybrid-zone between. Streams within the analysis area with 

westslope cutthroat include upper Eightmile Creek and the Chewuch River. Washington State 

Department of Fish and Wildlife has stocked lakes extensively with this species across the 
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project area into high mountain lakes over the last 80 years and their distribution is thought to 

be artificially expanded due to colonization downstream from some of these lakes. Washington 

State Department of Fish and Wildlife continues to stock many mountain lakes in the sub-basin 

with westslope cutthroat trout outside of the Methow Sub-basin. 

In the Methow River watershed, westslope cutthroat trout presence is known or predicted in 43 

HUCs and known absent in 18 out of the total sub-watersheds. Westslope cutthroat trout status 

is known or predicted strong in 27 HUCs and known or predicted depressed in two. However, 

most of the WCT in these HUCs (roughly 20) have been introduced and are believed to exist 

outside their historic range. In the Lake Chelan watershed, WCT presence is known or predicted 

in 31 HUCs and absent in one. Westslope cutthroat trout status is known or predicted strong in 

15 HUCs, and known or predicted depressed in nine HUCs. Overall, the stocking of non-native 

trout and loss of habitat are believed to result in depressed population status within the 

Methow and Chelan sub-basins (USDI 1999). 

Sockeye

Sockeye are a MIS species on the Wenatchee Forest, but are not present in the analysis area. 

Kokanee, which are the landlocked form of sockeye salmon, have been stocked in Lake Chelan 

since around 1917. They are not native to the lake or tributaries and do not have sensitive 

species status. Sockeye are not discussed further in this analysis.

Umatilla Dace

Wydoski and Whitney (2003) report that Umatilla dace are benthic fish found in relatively 

productive, low–elevation streams. They inhabit streams with clean substrates of rock, boulders 

and cobble where water velocity is strong enough to prevent siltation from embedding 

interspaces. Umatilla dace reach 7–10 cm (3–4 in) in length. Mature fish probably spawn in July 

to early August. Diet is unknown but likely to consist of small aquatic insects. This species have 

been documented in the lower Twisp River and the Methow River. None have been found in the 

project analysis area. 

Pygmy Whitefish 

This species is not found within the Methow Valley Sub-basin. Pygmy whitefish are indigenous 

to Lake Chelan. The only documented pygmy whitefish is Lake Chelan was during deep water 

netting in 1996. No other individuals have been detected in the basin. Very little is known about 

abundance and locations during various life stages. They typically reside in deep, cold, 

oligotrophic lakes and will use streams of mountainous areas to spawn. Spawning surveys for 

pygmy whitefish indicate that the majority of the spawning occurs in December (Barnett and 

Paige 2012). The Forest Service and US Fish and Wildlife Service conducted three fish surveys on 

Fish Creek (surveys available in analysis file) and one on NF Fish Creek and four on Prince Creek 

and found no pygmy whitefish. It is possible some use may occur in these streams that were 

undetected, but their use would be low if at all. 

Summer-Run Chinook 

Summer-run Chinook salmon are a management indicator species on the Wenatchee National 

Forest, but are not present in the Lake Chelan or in the Methow Sub-watersheds where project 

effects would occur and are only found outside of the analysis area. Therefore they will not be 

discussed further in this analysis. 
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Fish Distribution

Most pack and saddle stock outfitter-guide activities occur miles above habitat occupied by fish 

listed under the ESA. Historically all high elevation lakes and streams above natural barriers did 

not support fish until stocking began in high lakes and some streams in the early 1920s. Fish 

soon colonized streams downstream of the stocked lakes and today the distribution of fish in 

the analysis area is greater than 80 years ago (Jennifer Molesworth personal communication). 

All lakes in the area except Cougar, the Hiddens, Black, and possibly Lower Cathedral, were 

historically fish-free. Planted fish are from stocks that are not native to the Methow, Pasayten, 

or Ashnola watersheds. Introduced fish have greatly, but not completely, diluted native genetic 

stocks of westslope cutthroat and redband rainbow trout unique to this area. Today many of 

the lakes are stocked on a 10 year rotation by the WDFW, with the exception of lakes that have 

established spawning populations of trout. The WDFW is responsible for fish stocking and 

management of fish populations; they coordinate fish stocking in wilderness lakes to address 

concerns over effects to native species and human use patterns in wilderness. 

Fish stocking can lead to impacts at lakes because the presence of fish is a major attraction to 

people visiting the area. The high elevation of the lakes and short growing season makes high 

lake riparian areas vulnerable to over use. For the most part the smaller streams within the 

analysis area are well protected with vegetation, difficult to access and receive little fishing 

traffic while fish bearing lakes have fishing trails around them and usually a camp or two 

somewhere around the lake, usually near the outlet. High lake survey data show that this 

occurs at lakes accessed not only by foot traffic, but also at lakes accessed by horse users. Lakes 

accessed by horse users tend to have bigger impact areas. Non-native fish can compete or 

interbreed with native species, resulting in reduced survival. An example is introduced eastern 

brook trout is considered one of the major threats to the persistence of bull trout due to 

interbreeding and competition for habitat (Kanda et al. 2002). Brook trout historically, were 

stocked in most high mountain lakes and many streams on the Methow Valley Ranger District. 

Natural fish bearing streams in the analysis area include the Chewuch River, Lake Creek, lower 

Andrews Creek, the Ashnola River including possibly Cathedral Creek and Spanish Creek, the 

Lost River, the Pasayten River, the West Fork of the Methow River, Granite and Canyon Creek, 

Early Winters Creek, the mainstem of the Twisp River, Wolf Creek, Goat Creek, Beaver Creek, 

Libby Creek, and Gold Creek (including Foggy Dew Creek and lower Crater Creek).

Fish species listed under ESA, on the Regional Forester’s Sensitive Species list, Forest Plan 

Management Indicator Species, and species for which Essential Fish Habitat has been 

designated under the Magnuson-Stevens Fishery Conservation and Management Act in the 

analysis area are identified in Figures 3.1-5 and 3.1-5 (see below and on maps in the analysis 

file). Fish presence/absence is based on stream and fish distribution inventories for the analysis 

area (included in analysis file). Generally, sensitive fish species are below the OG analysis area 

except for a few areas.
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Figure 3.6-7. Presence of listed fish species by 5th field watershed.

Watershed (5th Field) Listed Fish Species

Regional Forester 

Sensitive Species and 

Management 

Indicator Species

Essential Fish 

Habitat

Ashnola River None WC, RB None

Sinlakekin Creek None None None

Lower Similkameen None None CH*

Pasayten River None WC, RB None

Ross Lake BT BT None

Ruby Creek BT BT, RB None

Lightning Creek BT BT, WC, RB None

Salmon Creek ST ST None

Twisp River CH, ST, BT CH, ST, BT, WC, RB CH

Middle Methow River CH, ST, BT CH, ST, BT, WC, RB CH

Upper Chewuch River CH, ST, BT CH, ST, BT, WC, RB, CH

Lost River CH, ST, BT CH, ST, BT, WC, RB, CH

Lower Chewuch River CH, ST, BT CH, ST, BT, WC, RB CH

Lower Methow River CH, ST, BT CH, ST, BT, WC, RB CH

Upper Methow River CH, ST, BT CH, ST, BT, WC, RB CH

Upper Columbia - Swamp Creek CH, ST, BT CH, ST, BT, WC, RB CH

Upper Lake Chelan None WC, RB None

Lower Lake Chelan None WC, RB None

Stehekin None WC, RB None

CH –Spring Chinook

ST – Steelhead

BT – Bull Trout

WC – Westslope Cutthroat Trout

RB – Rainbow Trout/Redband Rainbow Trout

*CH Summer Chinook

Bull trout is the only ESA listed species that extends well into the analysis area. The upper Lost 

River and Wolf Creek are the only areas with outfitter-guide camps adjacent to streams with bull 

trout. Four of the lakes have bull trout: Black, Cougar (Pasayten), First Hidden, and Middle 

Hidden Lakes. 

Most ESA listed fish use occurs well downstream. Figure 3.1-6 describes the camps within the 

Riparian Reserve of sensitive fish streams, fish species, and the use in the area. All other camps 

are more than 300 feet off of sensitive fish streams.
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Figure 3.6-8. Outfitter-guide campsites along sensitive fish streams.

Campsite Stream Species Fish Use

Horse Heaven WF Methow River WC Spawning/Rearing

Cedar Creek Cedar Creek WC Spawning/Rearing

Gardner Meadows Wolf Creek WC Spawning/Rearing

South Fork Wolf Creek WC Spawning/Rearing

Little Fish Camp Wolf Creek BT, WC, RB Spawning/Rearing

Chewuch Chewuch River WC, RB Spawning/Rearing

Lost River Lost River BT, WC, RB Spawning/Rearing

Current known fish species in the Chelan portion of the analysis area consists of native 

Westslope cutthroat trout, introduced Yellowstone cutthroat trout, introduced rainbow trout, 

and introduced kokanee (Figure 3.1-7). Most of the streams in the analysis area have natural 

barriers (waterfalls within 1000 feet of Lake Chelan) that prevent lake resident fish from 

ascending streams. No streams in this portion of the analysis area support anadromous fish as a 

result of both natural barriers and the dam on the Chelan River (R2 and IA 2000). Introduced 

rainbow trout, Yellowstone cutthroat trout, and kokanee have no special status (sensitive, 

management indicator, proposed, listed, or otherwise). Bull trout are not present in the Lake 

Chelan portion of the analysis area.

Figure 3.6-9. Chelan Ranger District portion of the Analysis Area Stream/Lake Fish distribution.

Stream/Lake

Name

Survey Year(s) Surveyed Fish Species Present in order of relative 

abundance

Safety Harbor

Creek

1,060 feet. 1993, 2001, 2003 hybrid swarm of westslope-Yellowstone 

cutthroat, rainbow, kokanee

Canoe Creek ~50 feet. 2001 None

Prince Creek 1,584 ft. 1992, 2003 cutthroat, rainbow, kokanee

Rex Creek 2001 None

Pioneer Creek 2001 None

Cascade Creek 450 feet. 1983 cutthroat, rainbow

Meadow Creek unknown 1983 unknown

Fish Creek 1,312 ft. 1998, 2003 cutthroat, rainbow, kokanee, suckers, 

cyprinids 

Boiling Lake 1990, 2000 cutthroat & rainbow hybrids, cutthroat 

Cub Lake 1990, 2000 cutthroat

Bernice Lake 1990, 2000 cutthroat & rainbow hybrids

Surprise Lake 1990, 2000 cutthroat

Current Outfitter-guide Use and Effects to Streams and Lakes

Pack and saddle stock outfitter-guide use in the project area represents only three percent of 

the total annual visitor days and 15 percent of the total pack and saddle visitor days. Therefore, 

overall use from the commercial outfitter-guides accounts for a minority of total use and 

logically, would account for only a small proportion of recreational impacts. 

Outfitter-guides use a total of 24 campsites within Riparian Reserves or Riparian Habitat 

Conservation Areas, 4 campsites, and 35 near wetlands (refer to Appendix I for campsites within 
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500 feet of wetlands). The Forest Service completed campsite inventories on the 14 riparian 

camps located in the Pasayten and Lake Chelan-Sawtooth Wilderness. Measurements included 

barren core, number of trees with exposed roots, number of mutilated trees, and number of 

access trails. Additionally, field personnel reviewed physical streambank and streamside 

vegetation disturbances at access points and looked for evidence of firewood collection near 

streams. Each site has photos taken and a lineal estimates of streambank and vegetation 

disturbance.

Most of the land in the project boundary is steep, mountainous terrain. Streams have mostly 

steep gradients (4 to >10%) and are characterized by larger sized rocks in the channel and 

streambanks. Stream bank vegetation consists of conifers, alders, willows, dogwoods, and 

coarse substrates. These channel types are consistent with Montgomery and Buffington’s (1997) 

definition of cascade and step-pool morphology channels, which occur on steep slopes, confined 

valleys, and cobble and boulder substrates and tend to be very stable that are resistant to bank 

erosion and channel incision due to the coarse bed and bank material (Montgomery and 

Buffington’s 1997). The limited stream survey data available for the project area, located in 

wilderness or roadless areas (19 streams), indicates bank stability are excellent with higher than 

90% bank stability throughout (See survey reports in analysis file more details). Most lakes 

receive little or no use throughout the year due to their remoteness. Many of the lakes are lined 

with rocky slopes and shores where human impacts are little to none. Lake surveys completed 

on the 17 lakes in the project area found recreation impacts to be mostly minor with the 

greatest impacts at the campsites. Trails often run around the lakes, but this often occurs on 

rocky slopes without vegetation naturally. From the survey reports, conditions such as lake 

shores, water quality, and vegetation are found in good to excellent conditions. Refer to lake 

surveys in the analysis file for more information.

Current commercial outfitter-guide activities do cause small, localized disturbances to lake 

shores, stream channels, and riparian areas across the project area with more concentrated 

impacts at campsites and day use areas close to wet areas. Where stock is allowed to loose 

graze, some localized impacts to streambanks, streamside vegetation, lake shores, wetlands, 

and riparian vegetation occurs. When stock are contained at camps or in pack-strings, impacts 

are limited to stock containment areas at riparian camps, trail-stream crossings, and watering 

areas. Field review of a subset of streams, wetlands, and lakes across the analysis area identified 

general recreational impacts occurring as streambank and lake shore trampling and riparian 

vegetation loss from browse (stock) and trampling (Laurie Dowie personal communication). 

However, the areas disturbed are small and represent only a small fraction of the high quality

resources across the entire analysis area. It is important to note the current conditions reflect all 

recreational use in the backcountry and pack and saddle stock outfitter-guides stock use is only 

a small portion of the total use. 

To assess disturbance to riparian vegetation associated with camps used by the outfitter-guides 

in Riparian Reserves or RHCAs (riparian camps), this analysis relies on field review of a subset of 

the riparian camps. Fourteen of the twenty-four Riparian campsites used by the commercial 

outfitter-guides, within the Pasayten and Lake Chelan-Sawtooth Wilderness, were inventoried 

over the last few years to measure the amount of barren core and camp area impacts to 

vegetation. Disturbances to vegetation ranged from nearly full vegetation loss in the barren 

core area to reduced densities and damage to existing trees and shrubs. Campsites averages 

from these sites were used to estimate sizes for the other 10 sites. Campsite vegetation 
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disturbances ranged from 20 square feet to over 10,000 square feet at the largest site. The 

average was about 2,700 square feet or a 52-foot diameter circle area. Barren core area, the 

area void of ground cover, ranged from 0 to 5,400 square feet with an average of about 1,140 

square feet or a 30-foot diameter circle area. Using GIS, an estimated total of 86 acres of 

riparian vegetation are within this 52 foot radius of camps. The total estimated acres of 

designated Riparian Reserves and RHCAs across the project area are 173,527 acres. This amount

of disturbance at the riparian campsites amounts to a range of 1% to less than 0.01% for a given 

5

th field watershed. This represents a small fraction of the total riparian areas associated with 

streams, lakes, and wetlands within the analysis area. Vegetation and ground disturbance 

outside of these areas was not present, except for trails to streams and lakes with some 

disturbance around them as discussed below. 

Most streams across the project area are considered to be in pristine or near pristine condition 

with little human influence. Streambanks are well armored with dense vegetation and/or coarse 

rocks and receive little to no human use. Where stream surveys exist within the project area 

(See survey reports in the analysis file), bank stability is over 95% and considered excellent. Field 

observations of several other smaller streams suggest they have a similar high level of bank 

stability. This is considered optimal bank stability according to Cowley (2002), who reviewed 

several studies looking at bank stability over several hundred miles of different stream types 

through the western United States. Information is lacking on most streams in the project area. 

Most of the streams are in steep mountainous terrain with steep gradients, rocky channels, and 

are resistant to disturbances from bank alteration associated with livestock use as described 

above under analysis methods. Limited data for streams in wilderness and roadless areas 

suggests streams are generally in good condition due to the lack of human influence. There is 

limited or incomplete data for most streams, but the extent of project effects are small and the 

spatial scale of impacts would not compromise the overall high quality fish habitat. Therefore, 

collecting data on most or all of the streams and wetlands in the project area is not important 

for analyzing overall project effects.

Field review of some stream channels near camps and trails indicates current recreation impacts 

to streambank stability and streamside vegetation are minor. At riparian campsites, typically 

there were about 2-10 feet of disturbed streambank observed at trails from the campsites to 

streams and about 5-10 feet where trails cross streams. Vegetation browse was observed at the 

campsites, but little to none was observed along streambanks. Within the project area, there 

are 24 camps within riparian areas along streams. There is an estimated 3,200 miles of streams 

in the analysis area. Based on a distance of 10 feet of disturbed stream banks near camps and 

10 feet along trails, 0.25 miles total or less than 0.001% of disturbed stream banks associated 

with camps. 

Disturbances also occur where existing trails cross stream channels. Based on GIS analysis there 

are 709 stream crossings on trails in the analysis area. Field observations indicated that there is 

approximately 10 square feet of channel disturbance per stream crossing, which amounts to 

about 1.3 miles total of bank disturbance out of the 3,200 miles total or less than 0.001% 

disturbance. Furthermore, these crossings are dispersed across the analysis area and are not all 

used by outfitters. 

There are 525 lakes in or bordering the entire analysis area, within the Northwest Forest Plan 

area. These lakes have an estimated combined distance of 137 miles of lake shore. Much of the 
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lake shores around these lakes are rocky slopes, which are highly resistant to recreational 

impacts. Based on lake surveys of human use, the campsites are the biggest impacts around 

lakes. Most campsites are positioned sufficient distance from the shores and none of the 

surveys found more than minor impacts to lake shores. Lakes used by pack and saddle stock 

outfitter-guides include Cooney Lake in the Sawtooth Backcountry and Crow, Corral, Sheep, 

Quartz, Ramon, Remmel, Upper Cathedral, Cougar, First Hidden, Middle Hidden, and Big Hidden 

lakes in the Pasayten Wilderness. Outfitters also use Sheep, Quartz, Upper Cathedral, Cougar, 

Remmel, Crow, and Ramon Lakes for day use and/or drop camps. Each of these lakes has been 

surveyed over the years (surveys in the analysis file). Based on lake surveys of human use from 

trails and campsite access from a handful of lakes in the project area (surveys in the analysis 

file), it assumed at lakes that have nearby campsites that are within Riparian Reserves or RHCAs 

will have approximately 25 feet of disturbed lakeshore. This equals a combined lakeshore 

disturbance distance of 0.1miles or less than 0.001% disturbed total lakeshores across the 

project area. 

Impacts to lakes from current outfitter-guide trips are minimal because when pack stock are at 

lakes, they are tethered at least 200 feet away and spend no more than a few hours at the sites 

as explained below (L Dowie – personal communication). Cooney Lake in the Sawtooth 

Backcountry has a full service campsite but it is over a mile from the lake. There is a drop camp 

at the lake but the outfitter-guides and packstock do not stay at the lake. Recreation impacts at 

these popular lakes are primarily from the general public (hikers and non-outfitted stock users) 

using the backcountry. Commercial pack and saddle stock outfitters cause a negligible portion 

of the impacts, as their use only accounts for approximately 3% of total use. There is a full 

service campsite near First Hidden Lake where the outfitters camp with clients but it is over 200 

feet from the lake. Pack stock are mostly grazed up at Stub Creek, 11.2 miles from the lake, or 

are tethered to hitch rails or highlines at least 200 feet from the lake (tethered rope to tie stock 

on). The outfitters do not camp along the other two Hidden lakes and the impacts there are 

primarily from the general public users. 

Pasayten Wilderness

The major tributaries draining out of the Pasayten Wilderness portion of the analysis area are 

the Pasayten, Ashnola, and Chewuch Rivers, and Lake and Andrews Creeks. Fires in the last 30 

years burned about 112,300 acres in this analysis unit and the fire effects to streams have 

produced favorable habitat conditions for fish and productivity. Bull trout redd counts increased 

after debris torrents from the 2001 Thirtymile Fire and 2003 Farwell Fires (USDA 2008). Fire is 

considered a natural habitat forming process and all habitat indicators are considered to be 

functioning at natural potential.

Up until 1995, cattle and sheep grazed on the Remmel allotment, which includes the Remmel 

Lake/Spanish Camp area. Sheep and cattle grazed these areas for nearly 100 years but use 

declined over the century and there has been no grazing since 1995. In early 2000, the permit 

for the Remmel allotment was waived back to the Forest Service and has been vacated and is 

proposed for closing. This represents a large decrease in domestic grazing in this area. The past 

grazing that occurred in some of these areas, makes it more difficult to determine the possible 

long term effects dispersed recreation or outfitter-guide use may have on riparian and aquatic 

habitat; but an overall movement towards restoration is anticipated with the removal of cow 

and sheep grazing. Stream channel data collected in the Remmel Lake and Spanish Camp area 

in late July 2000 show that meadow-type channels in the area were, at one time, beginning to 
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widen and show signs of deterioration but are now assumed to be recovering from the past 

cattle and sheep use. With the change from cattle and horses to generally just horses/mules, 

overall grazing use may be shifting to higher and drier meadows above the streams; cattle are 

more likely to use wet areas adjacent to streams while horses tend to avoid boggy areas, 

preferring drier, and upland forage areas.

With the exception of Cougar Lake, Hidden Lakes, the Thirtymile trailhead, the Andrews creek 

corral, Eightmile Creek, and Lake Creek (the specifics of which are all discussed below), the back 

country areas used by recreationists and outfitter-guides in the Chewuch watershed are miles 

upstream from fish species listed under the ESA. MIS are found in streams throughout this 

project area sub-unit. The level of disturbance caused by pack stock in the most heavily used 

areas of the Pasayten is generally confined to stream crossings and is not great enough to cause 

downstream effects. A handful of heavily used stream crossings have been inventoried and the 

effects include minor sedimentation of the channel and loss of streamside vegetation at the 

immediate area around the trail crossings. 

Habitat conditions in the upper Lost River are functioning properly and considered in pristine 

condition. Bank stability of 90% or greater is considered optimal bank stability and 

representative of undisturbed sites (Cowley 2002). Streambanks along the upper Lost River are 

at or exceed 90% stability in all mainstem reaches surveyed, with most reaches exceeding 95% 

stable. One reach showed the highest proportion of eroding banks at 10.6%, which was 

attributed to recent (recent at the time of survey in 2000) wildfire activity that had resulted in 

streambank vegetation and tree loss . This amount of erosion (10.6%) and stability (89.4%) is 

just below what is considered optimal bank stability. 

On the upper Lost River, near Lost River Camp, there is a trail down to the water’s edge and 

some other minor bank trampling, amounting to about 15 feet on both sides. During rain events, 

these disturbed areas would likely deliver extra fine sediment to the river. No other human 

caused sediment sources were observed along the river near the campsites. Based on this one 

location with minimal disturbance and the low frequency of outfitter-guide access, it is unlikely 

sediment or streambank levels would result in measurable changes at the site scale and 

definitely not at the watershed scale. The effects to bull trout habitat from current use are 

insignificant. 

The trail access to the Hidden Lakes is in the Lost River watershed and most of the trails are 

located far away from stream channels except at stream crossings and at Cougar Lake and the 

Hidden Lakes. Outfitters and the public frequently use the trail to Hidden Lakes, especially early 

in the season, but use at the lakes is limited to short stops or short duration stays of one to two 

days. Effects include some lake shore trampling and sediment delivery. The relocation of 

hitching rails in away from Stub Creek and First and Middle Hidden Lakes is reducing stock 

impacts to this area. Tying or grazing of stock is not allowed within 200 feet of the lakes.

With little to no human disturbance across the upper Lost River area, nearly all riparian areas 

are intact and properly functioning. The only areas where outfitter-guide activity, specifically 

pack animals and clients, would disturb lakeshores, stream channels, and riparian areas are at 

campsites and day use areas close to lakes and streams and at stream crossings on trails. There 

are 4 camps within the Riparian Reserves for streams and lakes in the Lost River Watershed. 

Nearly all streams in the project area are well protected from recreational disturbance by 
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downed wood and dense forest and are considered to be functioning naturally. Minor riparian 

canopy modification has occurred in localized areas, especially in areas where camps are within 

the Riparian Reserve. 

Outfitter-guide use at the Thirtymile trailhead and Andrews Creek Base Camp occurs only a 

handful of times per year. The Thirtymile Trailhead (#510) is at the end of the road at Thirtymile 

where outfitter-guides start into the Pasayten Wilderness. Use of this trail is minimal. Trips can 

occur between July and late 

September. Normally, there is one 

trip on this trail in mid- to lateSeptember, coinciding with the 

High Buck Hunt in the Pasayten 

Wilderness, which runs from 

September 15 to September 25 

each year. All camps are several 

miles up the river drainage and 

distant from critical habitat. There 

is a new trail bridge at the trailhead 

that immediately crosses the river, 

and then parallels it for several 

miles. The bridge design is such 

that a small proportion of stock 

heading up the trail will not cross 

the bridge due to its narrow width 

and height of the side railing. Based 

on our own pack stock use and 

observations on past outfitterguide use, we estimate about 20% 

of the stock animals will not cross 

the bridge (Rogers 2011, personal 

communication). In these cases, 

most of the stock use the bridge 

and the few animals that will not 

are led across the river. The ford 

site is rocky and the potential for sediment input is minor. 

A small amount of sediment probably enters the river, but it would not compromise fish habitat 

because the amount would be immeasurable. Effects to fish would be inconsequential. 

The Andrews Base Camp is an existing site near the confluence of Andrews Creek and the 

Chewuch Riparian Reserve. The site includes a corral that extends down near a small high water 

side channel at a distance of about 10 feet. A water trough exists in the corral, along the edge of 

the side channel. The water trough is fed by a ~ 1-inch pipe from the Chewuch River. The pipe is 

gravity fed with a small wooden box at the end with a small mesh screen to prevent fish from 

entering it. Mitigation measure 13f would require the fish screen on the pipe to meet NMFS 

approved criteria. The volume of water used by the trough is estimated at 0.0003 cfs. This is 

based on 2009 flow rates measured for gravity fed water developments on our grazing 

allotments using 1 inch. Water withdrawal of this volume would have no measurable to fish 
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habitat. Outfitter-guide use at this campsite is about 10 days a year and they normally stay 

overnight. Stock do not access the Chewuch River or Andrews Creek and therefore, there is no 

potential for sediment delivery to the river. The area of the camp has modified riparian 

vegetation, but it is far enough from the river to not influence stream shade and temperature or 

large wood recruitment. The effect to aquatic habitat in the river in minor and would not affect 

the quality of fish habitat.

Trails that access camping and loose grazing areas are used by the general public and outfitterguides. Trails generally follow valley bottoms and are located on the outer edge or completely 

outside of Riparian Reserves and RHCAs. Trails are maintained to control erosion. The main 

routes into the Pasayten have little to no effect on stream channels except at stream crossings 

and a few localized segments where a trail may come close to a stream. An example is where 

the Andrews Creek trail is close to the stream as it approaches Andrews Pass. Trail location is 

locally affecting stream quality between Amphitheater and Upper Cathedral Lake, between 

lower Cathedral area and upper Beaver Creek, and the trail segments between Spanish Camp 

and Remmel Lake by adding excess fine sediment. A drift fence was constructed to prevent 

stock from going back on the trail. Stock presence at this site is infrequent as they don’t usually 

go there. The effects are localized and do not cause impacts to aquatic or riparian habitat at the 

reach scale or at the watershed scale because the fine sediment delivery is small such that it 

does not increase measurable fine sediment levels.

In the Sheep Mountain area stream channels drain east towards the Ashnola River or west 

towards the Hidden Lakes and the Lost River. Main trails are located well away from streams so 

the trail network has little to no effect on channels. Streams in the Sheep Mountain area were 

also grazed by sheep and cattle in the past, which are recovering with increased bank stability 

and vegetation.

Trails that begin near Harts Pass and access the Pasayten River watershed are located away 

from stream channels except at crossings and are having little to no effect on stream habitat. 

Minor volumes of sediment, estimated at <0.1 cubic yard per year, is delivered to the river. 

Most of the past outfitter use in this area has been in the fall during hunting season, when fish 

are out of their redds and free swimming. Impacts to fish and their habitat would be minor as 

disturbance levels are few and short-term. 

There is a corral within the Riparian Reserve of Eightmile Creek at the Billygoat Basecamp. Stock 

are staged at this corral before taking clients to the Pasayten Wilderness. There is a road that 

provides access from the corral to trailhead and the stock are never loose grazed at this 

location. Therefore, it is a discountable probability there would be any disturbance to 

streambanks or sediment from the activity in the drainage. There is a small water pipe taking 

water from a tributary stream to a trough in the corral. The amount of water removed would be 

an estimated 0.003 cfs. For Eightmile Creek, the estimated low flow is 1.2 cfs and with a 

measured a flow of 3.1 cfs in September of 1992. Using the lower amount, we estimate the 

water development use amounts to less than 0.3% of flows in Eightmile Creek. The small 

amount of water used for this water development combined with low number of days used per 

year (<14), would have a trivial effect to stream flow in Eightmile Creek and the Chewuch River. 

Therefore, the overall effect in upper Eightmile Creek would be minor and would not 

compromise the existing aquatic or riparian habitat. 
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Habitat conditions on Lake Creek are currently recovering from a large wildfire. Prior to the fire, 

bank stability exceeded 95% and fine sediment levels averaged 10%. Riparian conditions were 

found to be properly functioning with dense riparian forests and streambank vegetation. These 

conditions suggest the outfitter-guide use was having little impact on the aquatic and riparian 

conditions. The camps used by the outfitters are near the top of the watershed, miles above 

listed fish habitat and outside of riparian reserves. Overall impacts to aquatic and riparian 

habitat conditions are minor. 

Virtually all of the use in the Lake Creek watershed has been from private parties. The trail from 

Black Lake to Ashnola Pass and the Pasayten has not been maintained for several years and is no 

longer passable to horses; horse use through the area is declining especially following the 2003 

Farewell Fire. The number of bull trout redds counted in upper Lake Creek from 1995 to 1999 

dropped from 22 to zero in 1999; the reason for this apparent decline is not known. In 2004, 

following the fire, six bull trout redds were counted in upper Lake Creek and in 2005 there were 

24 redds; the highest number since counting began in 1995. Lake Creek and Black Lake were 

closed to the public from the start of the June 2003 Farewell fire until mid-summer 2005. It is 

unknown if the higher redd counts are due to three years of reduced angling pressure, improved 

post-fire habitat conditions, or natural population cycles unrelated to fire and fishing pressure. 

Although it is not permitted to retain bull trout the main threats to this population are fishing 

pressure and incidental catch by people that are unaware of the fishing regulations, choose to 

ignore them, or do not know how to identify a bull trout, or damage done during catch and 

release. 

There are approximately ten drift gates in the Pasayten and Lake Chelan-Sawtooth 

Wildernesses. These gates are located where topography or terrain, in addition to the drift 

gate, helps prevent loose grazing stock from moving out of an area. None of the gates, including 

the ones on the Andrews Creek and Chewuch trails, are causing stock to trample riparian areas 

or wetlands because the gates are located in dry upland areas. Wetlands and streams in the 

vicinity of the gates are not being trampled by the occasional outfitted stock that may be 

stopped by the gate. 

Middle Methow

There are no outfitter-guide client days or RVDs in the Middle Methow area. The only outfitter 

activities in this area are the assigned sites at Slate and Crater Creek basecamps. The camp at 

Slate Creek has a corral and access road. The Crater Creek camp has an access road, unloading 

ramp, hitch rails, watering trough, corrals, and parking area. In the middle Methow portion of 

the analysis area, back country and wilderness recreation, including stock based outfitter-guide 

use, is trail-based and takes place away from roads in areas not accessible to listed fish.

North Cascades

The Pacific Crest Trail (PCT) traverses the West Fork of the Methow watershed from near 

Cutthroat Pass to Harts Pass. The 4 to 5 miles of the Methow River that the trail follows is above 

Brush Creek and is not inhabited by ESA listed fish or sensitive species, but does have MIS 

present. There is one large camp used by pack and saddle stock outfitter-guides at Horse 

Heaven above Brush Creek. This camp is within 100-feet of the river and has several trails 

accessing the river, but is 2 miles upstream of a natural barrier and the upper limit of ESA listed 

fish. MIS are found in the West Fork Methow River. Most popular are the easy day hikes out 

and back from Harts Pass, where on a peak day in summer over a hundred people will use these 
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trails. The peak season of use is short, usually limited to the months of July and August. Due to 

popularity, the PCT is maintained annually to the highest standards. ESA listed fish are too far 

downstream to have fine sediment effects, but MIS are present and some recreation induced 

sediment occurs at minor levels where the trail crosses tributaries. The level of effects would be 

small enough to fall within natural background levels. 

The West Fork of the Methow River trail parallels the Methow River from Rattlesnake Creek to 

Brush Creek where it joins the PCT. This area was burned in the 2003 Needles fire and the trail 

was reopened to mountain bikes, horses, and hikers in 2004. It is used by commercial horse 

packers for day rides and to access the high country. There are no camps along the trail that are 

regularly used by commercial outfitters except for Horse Heaven camp located on the PCT 

upstream of Brush Creek (see above). The camp does not affect aquatic and riparian habitat 

indicators at the reach scale; effects at the site scale are localized. The West Fork trail is located 

in the Riparian Reserve for the Methow River in a number of places. Access for bull trout and 

steelhead is blocked at the falls just below the confluence with Brush Creek, 2.4 miles 

downstream. This trail parallels habitat occupied by bull trout, but is sufficient distance away to 

that sediment effects would fall within natural background levels. 

In the Upper Methow watershed, outfitter-guides use established trails and roads. Pack and 

saddle stock outfitter-guides also use Little Boulder Creek during the hunting season. The 

stream channel is steep and protected by steep valley walls; hunting takes place in the uplands. 

There is no recreational use along the stream and therefore, no aquatic effects. 

Outfitter-guide activities along the North Cascades Highway are limited to Cedar Creek, 

Cutthroat Creek, and the Pacific Crest Trail, with an average of less than two trips per year. Trips 

have historically been taken by the outfitters using burros or llamas. Cedar Creek and Cutthroat 

Creek habitat observations by field biologists were reported as being excellent with low fine 

sediment and good wood levels (Hopkins – personal communication), and so these effects are 

apparently not affecting fish or their habitat. 

Lake Chelan-Sawtooth Wilderness and Sawtooth Backcountry

Most of the access into the Lake Chelan-Sawtooth Wilderness originates at trailheads in the 

Twisp River drainage. Two trails, Fish Creek and Prince Creek, begin on the shores of Lake 

Chelan. 

The Sawtooth Backcountry is most commonly accessed by the Crater Creek and Foggy Dew trails 

in the Methow watershed. These trail systems are generally located outside of riparian reserves 

except at stream crossings and have virtually no effect on stream habitat indicators or on fish. 

Listed fish are not adjacent to any of these trails or in the areas used by outfitters, but MIS are 

present throughout much of the streams.

The Wolf Creek trail accesses the Mount Gardner area in the Lake Chelan-Sawtooth Wilderness. 

Listed bull trout and native cutthroat and redband rainbow trout are present in Wolf Creek. Use 

by outfitters in this area is a small percentage of overall use. Outfitters use Wolf Creek mainly 

for drop camps during hunting season and use is little to none before this, suggesting overall use 

during the year is limited to a trip or two. This does coincide with bull trout spawning in the 

upper Wolf Creek. Annual spawning surveys have not seen channel impacts or any signs of redds 

being disturbed by outfitter-guide use. The Wolf creek watershed was grazed by cattle until 
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about 2001 when the permit was purchased and waived back to the Forest Service; as a result, 

use on the trail has declined dramatically. The Wolf Creek trail is located away from riparian 

reserves for most of its length except at the Fish Camp area near the confluence with the North 

Fork of Wolf Creek. Fish Camp is a bull trout spawning area and outfitters are not allowed to 

ford the mainstem of Wolf Creek during bull trout spawning season to avoid trampling spawning 

areas since 2007.

Current outfitter-guide impacts are mainly a result of trail or campsite location. Destinations of 

outfitter-guides include the Oval Lakes, Scatter Lake, Slate Lake, and the Lake Chelan National 

Recreation Area via trails in the Reynolds Creek, War Creek, and Eagle Creek sub-drainages. 

Outfitter-guide activities have not had direct effects on listed fish because the activity takes 

place miles above habitat occupied by listed fish on existing trails, but may have had some 

minor direct effects to MIS species when accessing streams.

There are roughly 140 miles of trail in the Twisp River watershed. Many of the tributary 

drainages in the watershed have trails that parallel the drainage but are generally located out of 

riparian reserves. Trails are usually less than two or three feet wide and do not deliver 

measurable sediment to habitat occupied by listed or MIS fish. 

Trails are maintained to keep a clear pathway, to minimize erosion, and to protect water quality. 

Specific projects that have been completed to address erosion or water quality concerns in the 

Twisp River watershed include work done in 1999 on the West Fork Buttermilk Creek trail, and 

work done in 2007 on the Twisp River trail to relocate a large segment of the trail in the upper 

part of the drainage out of a wetland area. Another section that was eroding and adding 

sediment to the stream just above the trailhead was re-contoured. In addition, one mile of the 

trail on the North Creek alluvial fan where bull trout spawn was moved off the fan. These 

projects reduced recreation caused fine sediment delivery to fish habitat, thereby having a 

beneficial effect. 

Bear Ramsey/Volstead

Much of the Bear Ramsey/Volstead area burned in the 2006 Tripod Fire. Bull trout are present 

next to some trails used, but not the one camp used. MIS, westslope cutthroat trout, and 

redband trout are present throughout some of the streams in this unit.

Three campsites in the area are used by pack and saddle stock outfitter-guides as drop camps 

during hunting season. Fish are more capable to avoid disturbances during this time of year. In 

the past, outfitter-guide use in this area has been virtually nonexistent and there have been no 

observed overlaps with outfitter use in this area and fish bearing streams. The upper Beaver 

Creek watershed had a fragile population of bull trout that is vulnerable to human disturbance 

prior to the Tripod Fire of 2006. Since then, fish surveys have found no bull trout. Bull trout 

either were killed from the fire or moved out. There are no outfitter-guide dispersed campsites 

in this area.
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Alta Lake

The only outfitter use in this unit is day rides. Alta Lake and a small pond are the only water 

bodies in the unit. There were no visible effects from outfitter-guide use along these water 

bodies. 

Loose Grazing

When loose grazing, horses and mules generally stick together and are constantly moving across 

the land, eating grass as they move. Typically free-ranging horses move rapidly to and from 

water sources with very little feeding or loafing activities near drinking areas (Ganskopp and 

Vavra 1986). They may travel to lakes for water, and may graze near them for short periods of 

time, but tend to not linger along lakeshores. They prefer open areas and elevated terrain away 

from water and thick brush to get away from insects (Keiper and Berger 1982) and to be able to 

assess potential threats from predators (Ganskopp and Vavra 1986). They prefer to avoid 

muddy areas because they instinctively do not want to be mired in mud, and simply because 

they prefer to keep their feet dry. Grasses are the preferred browse over riparian species like 

sedges and shrubs (Salter and Hudson 1980, Hansen et al. 1977). Horses and mules will disturb 

wet areas, streambanks, and some vegetation from their grazing, but they do not prefer wet 

areas for grazing and spend a minority of their time in these areas. Dispersal of horses and 

mules across a loose grazing area tends to minimize impacts to sensitive riparian areas 

(Ganskopp and Vavra 1986). 

The number of trips per trail and management area varies by drainage, ranging from multiple 

per month to a few per month. Stock numbers per trip vary but are not more than 18 head, 

except for pre-approved oversize parties. Many of trips involve stock spending only one night in 

the backcountry to bring clients in and one night to bring them back, but some trips do involve 

stock staying in the backcountry for up to a week in the backcountry. Stock density when loose 

grazing would mostly be up to 18 head over about 5 acres or about four animals per acre. This 

level of density coupled with their behavior of preferring open meadows, limits the effects to 

riparian areas associated with streams, wetlands, and lakes to minor habitat effects. Streams, 

wetlands, and lakes reviewed near camps where the use is the highest indicate disturbance is 

minor. Difficult access as a result of steep terrain and dense vegetation limit disturbance to most 

streams, wetlands, and riparian specific vegetation. 

ENVIRONMENTAL CONSEQUENCES

Direct and Indirect Effects

Alternative 1

Pack and saddle stock outfitter-guides would have no impact on aquatic resources, since no 

permits would be issued. The existing non-outfitted stock use and hiking would continue 

throughout the analysis area. Current outfitter-guide use amounts to about 3 percent of the 

total visitor days and about 15% of the total pack and saddle stock use. Existing trails would be 

maintained and all existing camps would be available to the general public. Alternative 1 would 

result in a 3 percent reduction in total visitor days and a 15 percent reduction in stock use days 

on trails and at camps. 
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There would be an insignificant positive effect to fish species under this alternative, because 

reduction in stock use would be 15% and overall use would be a 3% reduction. This small 

decrease in use would not meaningfully change existing aquatic habitat conditions. 

Some of the creek crossings in the most frequently used areas, such as Spanish Camp, would 

possibly become a bit smaller in size because there would be less stock crossing and watering at 

these areas. Since the existing trail network would be maintained at current levels and existing 

levels of public use would continue, the effects of Alternative 1 would not cause a measurable 

change in effect to any stream habitat indicators. 

Effects from campsites and fishing trails at lakes created by the non-outfitted public would 

continue under Alternative 1. Riparian conditions at lakes that are most frequently visited by 

stock outfitters and clients may improve slightly due to less lake shore trampling and less human 

disturbances. This would be most notable at Cornwell, Airview, and Remmel Lakes in the 

Spanish Camp/Remmel area, and at Quartz, Crow, Corral, Sheep and Ramon Lakes in the Sheep 

Mountain area, within the Ashnola Watershed. 

In the Lake Chelan-Sawtooth and Sawtooth Backcountry, riparian conditions may improve 

slightly around Cub, Boiling, Bernice, and Surprise Lakes with less overall recreational use, but 

public use would continue at existing levels. Areas that currently receive infrequent use by 

outfitters (Wolf Creek, Early Winters, Cutthroat, West Fork Methow, Libby, 

Bear/Ramsey/Volstead) would remain unchanged from the existing condition. With Alternative 

1 there would be “no effect” to ESA listed fish species or habitat.

Alternatives 2, 3, and 4

The pertinent differences between Alternatives 2, 3, and 4, relating to impacts to aquatic and 

riparian resources, include visitor/stock use days, party size, riparian campsite barren core area, 

and campsite locations. Through field review and surveys, the existing impacts to lakes, 

wetlands, and streams from all back country recreation are mostly minor (See survey reports in 

analysis file). This coupled with the slight differences in use levels between alternatives and the 

small proportion of pack and saddle stock outfitter-guide visitor and stock use compared to total 

use, would result in such small differences in resource effects that they would not be 

meaningfully measurable and would be inconsequential between alternatives. The following 

points discuss how the alternatives would have similar effects. 

Service Days and Visitor Days. 

The number of pack and saddle stock service days would increase 4% with Alternative 2, 

decrease 40% with Alternative 3, or increase 50% with Alternative 4. When considered 

in context of overall use, Alternative 2 would increase pack and saddle stock use by 

0.6%, Alternative 3 would decrease use by 6%, and Alternative 4 would increase it by 

8%. 

This difference between alternatives would not result in a measurable change in 

resource impacts to lakes, streams, or wetlands because the differences in use between 

alternatives is small, the same protective mitigation measures would apply to each 

alternative, and overall, the pack and saddle stock outfitter-guides use is a small a 

fraction of the total visitor days. Thus, it’s logical that the proportion of impacts to 
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aquatic resources would follow the same proportions where the general public use 

would cause a majority of the impacts and the commercial pack and saddle stock 

outfitters would account to for a minority of impacts. There may be slight differences in 

effects to streambanks, riparian vegetation, lake shores, and wetlands, but the 

differences would too small to be measureable or detectible between alternatives. 

Party size. 

Alternatives 2 and 4 have identical party sizes and would have identical resource 

impacts. Alternative 3 would have reduced number of stock and people present on trips. 

This alternative would have a slight reduction in aquatic and riparian impacts due to less 

stock and people, but this would be too small to detect differences from the other two 

alternatives. Again, because the outfitter-guide use accounts for such a small proportion 

of overall recreational use the larger general public use and associated impacts would 

mask any differences from Alternative 3 to 2 and 4. Additionally, the current level of use 

and associated impacts to aquatic and riparian resources are minor and immeasurable 

on resources that are at or near pristine condition. With only slight increases in use, the 

additional impacts would not increase the magnitude of effects to a measurable level. 

Barren core within riparian campsites. 

Outfitter-guides use 21 riparian campsites within the backcountry. Of these, only two 

sites are larger than 2,800 square feet and only one over 5,250 square feet. Alternative 

2 would limit the amount of barren core area pack and saddle stock outfitter-guides 

could use to 5,250 square feet. Only one campsite exceeds this amount by 150 square 

feet, which would be revegetated under this alternative. This would result in such a 

small benefit, it would be meaningless. Alternative 3 would limit barren core to 2,800 

square feet and only two sites exceed this amount. The total restored area would equal 

less than one tenth of an acre under this alternative. Similarly, the benefit of restoring 

these small areas would not result in any meaningful benefit to aquatic resources. 

Alternative 4 would allow the outfitter-guides to use the existing barren core at 

campsites, but prohibited from any increasing their size. There would be slightly more 

barren core under Alternative 4, but it would be less than one tenth of an acre. 

Therefore, Alternatives 2 and 3 would have trivial benefits to aquatic resources and 

Alternative 4 would have slightly more barren core overall, but it too would be 

meaningless. With no measurable difference in impacts between alternatives, the 

effects of each would essentially be the same. Additionally, the general public would 

continue to use the existing sites, which proportionally amounts to approximately all the 

use (>95% of the use across the project area). Hence, differentiating the effects would 

not be possible.

Camp locations and access routes. 

Alternatives 2 and 4 are identical where existing camps within 200 feet of wetlands, 

lakes, and streams could be used by outfitter-guides. There are 26 campsites within 200 

feet of these areas across the project area. Alternative 3 would prohibit using camps 

within 200 feet of wetlands, lakes, and streams. Prohibiting outfitter-guide use of these 

campsites would not change the current effects to aquatic habitat for two reasons. First, 

the outfitter-guides and the public have been using these campsites for decades and the 

impacts to aquatic resources have been found to be small and inconsequential. Second, 

these campsites would continue to be used by the general public, which accounts to >95 
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percent of the total people use and 85 percent of the total stock use. Therefore, use at 

these sites would continue at levels close to what they are currently and the impacts to 

aquatic/riparian resources would be the same. The trail use to these sites would remain 

essentially the same, so the difference in impacts to aquatic resources would remain 

immeasurable between alternatives. 

Other than less overall use, the direct and indirect effects to ESA listed, MIS, pygmy 

whitefish, westslope cutthroat, and redband trout species, aquatic habitat, and riparian 

habitat would be essentially the same between alternatives. The overall use, including 

the general public, would continue to mostly be the same at these campsites. The slight 

reduction in use under Alternative 3 would result in slightly less effects to wetlands, 

lakes, and streams, but the reduction of effects would be too small to change habitat 

conditions and the risk for aquatic and riparian effects would be essentially the same 

between alternatives. Effects to temperature, sediment, streambanks, lake shores, and 

riparian vegetation would be minor and indistinguishable between alternatives. Overall, 

it is expected that the effects to streams, lakes, and wetland resources should be similar 

to each alternative in most places. Each alternative has the same aquatic/riparian 

management objective and mitigation measures and therefore, the effects from all 

activities would be essentially the same to fish and aquatic habitat. 

Direct Effects

There is potential for direct effects to fish present in streams accessed by outfitter-guides. 

Species with potential for direct effects include pygmy whitefish, westslope cutthroat, redband 

rainbow trout, bull trout, steelhead, and Chinook. Direct effects could involve trampling redds, 

disturbing spawning adults, or displacing individual fish from hiding cover making them 

vulnerable to predation. Areas with potential direct effects to ESA species include Wolf Creek, 

upper Lost River, and the upper Chewuch River drainages. 

Within Wolf Creek, bull trout occupy up to RM 7.4 on the mainstem and the lower 1/2 mile on 

North Fork Wolf Creek. Redd surveys have been done since 1995 and the number of redds range 

from 8 to 29 per year. No spawning has been observed in NF Wolf Creek. Most of the spawning 

reach is well away from the trail and not accessed by the pack and saddle stock outfitter-guides. 

An access point to the spawning reach occurs at the Little Fish Camp, which is about a half mile 

above North Fork Wolf Creek. The camp would be closed to commercial pack and saddle stock 

outfitter-guides after September 1 each year, which would eliminate outfitter-guides from 

crossing Wolf Creek in spawning habitat. The only access to occupied habitat would be on the 

main existing trail that fords North Fork Wolf Creek. It’s very unlikely a bull trout would spawn at 

the short piece where the trail crosses because the habitat is not suitable. To further reduce the 

probability, the outfitter-guides will be trained to identify bull trout redds or spawning activity 

so they could avoid walking on them. Therefore, the probability of a redd being trampled or 

spawning fish disturbed to be considered negligible. It is possible stock or people would cross 

North Fork Wolf or mainstem Wolf Creek prior to September 1 and may disturb individual fish. 

Access to bull trout habitat is limited, due to steep terrain and dense vegetation, so this would 

occur only a few places. Temporary disturbance or displacement of a few bull trout is not likely 

to physically harm or disturb feeding or sheltering of fish to the extent of causing injury. Pack 

and saddle stock outfitter-guides would not access steelhead or Chinook habitat, so there is no 

potential for direct effects. The closest point for these species is at least a mile downstream 

from any creek access. All other camps are well above the presence of bull trout.
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The risk of direct effects to bull trout from outfitter-guide stock, guides, or clients in the Lost 

River drainage is low. The access trail to all the camps never crosses the river and the stock 

animals stay on the trail except when loose grazing or dropping off clients at campsites. Stock 

animals water at tributary stream crossings on the trail. Loose grazing occurs at the Tatoosh 

Butte deluxe campsite, which is six miles upslope from the river. The only time the animals are 

by the river is on the trail or at camps when bringing gear or people in and out. When not on the 

trail or dropping off gear or clients, they are kept up on Tatoosh Butte. 

 

Of the seven drop camps in the upper Lost River area, only two are within 500 feet of the river 

and the others are over 1/2 mile from the river. The most likely spot for river access and 

potential for bull trout redd trampling is at Drop Camp G, which is near the Lost River where 

spawning does occur. In order to prevent disturbance to spawning, all outfitter-guide activity 

would be prohibited from using Drop Camp G and from crossing the river at any location after 

September 1. These measures would prevent redds and pre-spawning adults from being 

disturbed. 

Prior to September 1, outfitters and clients would be allowed to access and cross Lost River. 

Some disturbance to juvenile and adult bull trout is expected. Access to bull trout habitat is 

limited, due to steep terrain and dense vegetation, so this would occur only a few times per year 

where fish would be disturbed. Temporary disturbance or displacement of a few bull trout is not 

likely to physically harm or disturb feeding or sheltering of fish to the extent of causing injury. 

Commercial outfitters would not access steelhead or Chinook habitat because the closest point 

for these species is several miles downstream from any creek access. There would be no 

potential for direct effects.

The ford across the Chewuch River presents a potential location for redd trampling or disturbing 

individual Chinook and steelhead; however, the probability is expected to be extremely low. The 

ford site is located right above the Thirtymile trail bridge. The frequency of ford events would be 

low, up to two times or four river crossings each year. Use could occur during any time of the 

summer or fall; however, use is typically limited to one group during the month of September, 

coinciding with the High Buck Hunt. Channel conditions at the ford site are not suitable for 

spawning. Substrate composition is too large for spawning sized gravels (see photo), which 

needs to be golf ball to tennis ball sized rocks. By limiting river access to the ford site, the 

project would minimize the amount of habitat accessed. Due to the channel conditions, there 

would be no spawning at this ford site, so no potential for redd trampling Chinook, steelhead, or 

bull trout. 

When stock cross the river, some direct effects could occur to individual steelhead, Chinook, and 

bull trout. Adults would likely be in deeper water with cover, away from the ford or on spawning 

grounds upstream or downstream. Similarly, the channel gradient at the ford is not preferred 

rearing habitat. Therefore, the likelihood of encountering an adult or juveniles would be low 

compared to other low gradient habitat sections. Because of low frequency and duration of use 

at the ford, stock entering the river is likely to be so infrequent as to be of insignificant 

magnitude via disturbance/ temporary displacement only. There may be some short (minutes) 

behavioral changes of individual adult or juvenile fish but it will not lead to anything more than 

the fish swimming away from the pack animal. In addition, no crossing will occur near an ESA 

listed fish redd because stock will be prohibited from crossing critical habitat or limited to a 
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location with no spawning habitat (Thirtymile Ford). Direct effects to steelhead, bull trout, and 

Chinook would be minor and not cause any harm or effects to the local population. 

There is no for direct effects to the Umatilla dace because their closest point to the project area 

is at least 10 stream miles downstream and pygmy whitefish are not found in the Methow 

Valley. Redband and cutthroat trout are found throughout the project area. These two species 

spawn in the spring and can remain in their redds until mid-August. Outfitter-guide trips 

generally start in mid-July, but can start earlier with lower snowpack years. Redband and 

cutthroat trout typically spawn in smaller pockets of habitat in remote reaches where access is 

very low. Access occurs at trail crossings and occasionally when stock cross fish bearing streams. 

Because of the limited overlap in timing of outfitter-guide activities when redds are present and 

limited access to spawning habitat, the probability of redds being trampled is considered to be 

very low. 

Pygmy whitefish are indigenous to Lake Chelan. Very little is known about abundance and 

locations during various life stages. They typically reside in deep, cold, oligotrophic lakes and use 

streams for spawning. Spawning surveys for pygmy whitefish indicate that the majority of the 

spawning occurs in December (Barnett and Paige 2012). Three surveys have been done in Fish 

Creek, one in NF Fish Creek, and four in Prince Creek. These are the largest streams in the 

project area that drain into Lake Chelan. If pygmy whitefish use these streams, it is likely their 

use is infrequent as compared to redband and cutthroat trout. However, it is possible for some 

whitefish to be present and they may be disturbed from outfitter-guides. Any disturbance would 

be infrequent and short-lived (minutes). It is unlikely this level of disturbance would result in any 

harm to individual species and no effect to the local population. 

The most likely direct effect to redband and cutthroat trout is temporary disturbance (minutes) 

when stock or people access streams. Access to fish habitat is limited where these species exist, 

due to steep terrain and dense vegetation, so this would occur only a few times per year on a 

handful of streams across the entire project area. Temporary disturbance or displacement of a 

few fish is not likely to physically harm or disturb feeding or sheltering of fish to the extent of 

causing injury. Therefore, the effects would be not affect local populations.

Indirect Effects

Temperature

Outfitters would be prohibited from removing vegetation without prior Forest Service approval 

and if approved, any removal would be required to maintain existing shade levels. There would 

be no newly created openings. Therefore, no changes to stream temperatures would be 

expected and there would be no effects to the existing high quality temperature conditions 

associated with sensitive fish habitats. Existing high quality stream temperatures on site or 

downstream, where fish are present, would remain. 

Sediment

Some sediment would be generated into streams and fish habitat when clients and stock access 

streams at trails and when loose grazing occurs. Disturbance to streambanks, in the form of 

tramping from stock or humans, is the most likely mechanism for generating sediment to fish 

habitat. Field review of major fish streams, which have the greatest disturbance, show 

streambank alteration and disturbance, is very low. Streambanks are well armored (>95%) with 

vegetation and coarse rocks. Small sediment inputs across the analysis area would not be 
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measurable and would not diminish the existing high quality habitat. Existing high quality 

sediment levels on site or downstream, where fish are present, would remain.

Large Wood

Outfitters would be prohibited from cutting down any live vegetation without specific 

authorization from the Forest Service. On rare occasions, standing trees or snags may be cut if 

an immediate, unavoidable safety hazard is posed. If authorized, any tree removal would be 

designed to not reduce natural wood recruitment. Downed firewood would be collected at 

sites, but gathering and using downed wood greater than 12 inches in diameter would be 

prohibited within 200 feet of streams. This would provide for adequate coarse wood in areas 

with connected floodplain where streams may flood and this wood could provide high water fish 

habitat. Because of the very small proportional length of the river’s riparian reserves occupied 

by camps, the overall effects to instream wood levels would be zero. Existing high quality large 

wood levels on site or downstream, where fish are present, would remain.

Riparian Reserves/Riparian Habitat Conservation Areas

With little to no human disturbance across most of the project area, most riparian areas are 

intact and properly functioning. The only areas where outfitter-guide activity, specifically pack 

animals and clients, would disturb lakeshores, stream channels, and riparian areas are at 

campsites and day use areas close to lakes and streams and at stream crossings on trails. There 

are 28 camps within the Riparian Reserves or RHCAs surrounding streams and lakes in the 

analysis area. Nearly all streams in the project area are well protected from recreational 

disturbance by downed wood and dense forest and are considered to be functioning naturally. 

In all cases the camp sizes will be maintained at existing levels and impacts would not increase 

over existing conditions. 

Effects of packstock on riparian vegetation would not be measurable because the project does 

not propose new trails or campsites. Most of the Riparian Reserves across the project area are 

not accessed by the outfitters or for any other recreational activity. Some localized impacts 

(reduced ground vegetation, soil compaction, and potential surface erosion) are expected inside 

Riparian Reserves and RHCAs along some streams near camps and trail/stream crossings and 

may be negative at the site level, but are expected to be insignificant at the sub-watershed and 

watershed levels due to the small scale of the impact. Anticipated effects from continued use 

include alteration to riparian function in the form of changes to microclimate conditions, slightly 

higher fine sediment delivery to channels, and slightly less large wood recruitment. As with 

other indicators affected by browsing and vegetation trampling, effects to Riparian Reserves and 

RHCAs are not expected to be measurable and will have a neutral effect on the Riparian Reserve 

and RHCA indicator on site or downstream.

Aquatic habitat conditions where EFH is designated would remain unchanged over the existing 

conditions. EFH is limited to where Chinook and coho salmon are present, which are miles 

downstream except at the Thirtymile ford. A few stock crossings at this location would add 

minor sediment to the river, but would be immeasurable and have no impact on the existing 

high quality habitat that currently exists. Therefore, project effects to EFH would be 

inconsequential or no effect across the entire project area. 
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Lakes

There are 530 lakes within the analysis area. Based on field review and GIS analysis, less than 1% 

of the total lake shores across the analysis area are estimated to be impacted by recreation use 

and the existing pack and saddle stock outfitter-guides analyzed in this document only accounts 

for only 2-4% of that total use across the entire analysis area. Therefore, the alternatives would 

account for only a small fraction of impacts to lakes. Pack and saddle stock outfitter-guide would 

be prohibited from grazing within 200 feet of lake shores, so would have little effect on the 

existing lake ecosystems across the analysis area. For example, stock impacts from trampling 

would be limited to a controlled area over 200 feet from lakes with only occasional trampling 

from access for water. Effects to fish would non-existent because in-lake habitat would not be 

altered. 

By establishing tighter controls, the mitigation measures would eliminate future development of 

outfitter created trails and stream crossings. The forest plan amendments would control the 

amount of barren core allowed in campsites, possibly slightly improving aquatic habitat by 

reducing impacts to riparian vegetation. There would be less barren core under Alternative 3 

than 2 & 4; however, the general public would continue to use these sites and they likely would 

remain the same. 

Small-scale, localized habitat impacts could temporarily alter some individual trout behavior 

when people or stock cross streams and generate some localized turbidity, but the extent would 

be minor. Observed fish habitat effects from the outfitter-guide project is limited to a few 

dispersed access points where minor bank trampling or vegetation disturbance occurs. Fish 

habitat is generally optimal or near optimal across the entire project area. Minor habitat 

disturbances would not degrade the high quality habitat available to redband and cutthroat 

trout. Overall, the habitat effects would be immeasurable and minor to aquatic and riparian 

habitat. The existing high quality habitat for ESA listed fish, MIS, westslope cutthroat, and 

redband trout would remain and the indirect effects the outfitter-guide activities would be 

insignificant. 

In summary, the pack and saddle stock outfitter-guide activities would have small and localized 

insignificant effects to aquatic and riparian habitats across the project area. A few individual fish 

may be exposed to some stress from stock or humans causing displacement or altering their 

behavior or indirect disturbance from small, localized impacts to habitat. These effects would be 

infrequent and minor and would not affect local population levels. In the long term (years to 

decades), ESA, MIS, and redband and cutthroat trout habitat features are expected to continue 

to provide high quality habitat conditions. 

Summary of Effects to Region 6 Sensitive Species and Management Indicator Fish Species 

Under each alternative, there is potential for some direct effects to individual MIS, including 

redband and cutthroat trout, and pygmy whitefish. Indirect impacts through outfitter-guide 

caused sediment delivery and reduction in riparian vegetation that would reduce habitat quality 

in small, localized areas. Due to the distance from sensitive species (several miles), there would 

be no direct or indirect effects to Umatilla dace. Direct impacts would be in the form of 

disturbance and possibly displacement to adjacent habitat. This level of impact would not result 

in harm to individuals and no effect to local populations. The small-scale, localized habitat 

impacts could result in disturbance to individual trout listed as MIS. These would be few in 

number across the project area due to limited access and short-duration of stock or people 
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presence along fish bearing streams. The overall habitat conditions, which are good to excellent, 

would remain as a result of the proposed project’s design and mitigation measures. Impacts to 

native trout habitat would minimal and not sufficient to decrease each species’ viability within 

the project area. 

Overall, some minor direct and indirect habitat effects may occur to MIS, but at very low 

frequency and intensity that would not affect survival or reproduction of local populations. The 

combination of good to excellent habitat conditions, light impact of current outfitter-guide 

activities on aquatic resources, and development of a good riparian monitoring strategy to 

ensure resource objectives are met, the project effects for each alternative would be minor and 

would not degrade or diminish local populations or their habitat. 

Summary Effects to ESA Listed Fish Species and to Essential Fish Habitat 

Informal consultation on the project with FWS and NMFS was completed in accordance with the 

regulations implementing the ESA, 50 CFR 402.14(b)(1). The regulatory agencies responded with 

letters of concurrence dated November 13, 2012 (NMFS) and January 28, 2013 (USFWS) to the

insignificance of any effects to the species, their critical habitat, or Essential Fish Habitat. The 

letters are included in Appendix M. 

The potential for direct effects to steelhead is limited to the ford on the upper Chewuch River, 

at the Thirtymile Trailhead. There would be up to two trips crossing the river per year, for a 

total of 4 times fording the river. The channel condition at the ford site is a cobble/boulder riffle 

and steelhead redds are not likely to be present at this location due to the large rock sizes. 

Furthermore, outfitter-guides would be limited to crossing the river twice during the year. 

Therefore, the probability of a redd being trampled was deemed discountable. Disturbance of 

juveniles and adults may occur, but is likely to be low and minor. Disturbances are expected to 

be infrequent and minor, not rising to the level of harassment. As discussed above and in great 

detail in the project Aquatics Biological Assessment, aquatic habitat effects from each 

alternative would be minor at this site and for the project area above. All other steelhead 

streams would not be affected because the proposed activity occurs well above their 

distribution. Therefore, the proposed activity results in a “may affect, not likely to adversely 

affect” determination for steelhead and their critical habitat.

The potential for direct effects to Chinook is limited to the ford on the upper Chewuch River, at 

Thirtymile Trailhead. The channel condition at the ford site is a cobble/boulder riffle and 

Chinook redds are not likely to be present at this location due to the large rock sizes. The closest 

documented redd was about 600 feet downstream. Therefore, the probability of a redd being 

trampled was deemed discountable. Disturbance of juveniles and adults may occur, but is likely 

to be low and minor. Snorkel surveys found low densities of juvenile Chinook at this location so 

the risk of disturbing young Chinook would slight and their exposure would be very infrequent. 

Therefore any disturbance is expected to be infrequent and minor, not rising to the level of 

harassment. Habitat effects would be minor at this site and for the project area above, where 

there is no access to Chinook habitat. Some fine sediment would be generated when stock ford 

the river, but the ford is mostly large rock with little fine sediment to generate. Any sediment 

delivered to the river would be too small to have any impact on redds downstream. All other 

Chinook streams would not be affected because the proposed activities occur well above their 

distribution. Therefore, the proposed activities result in a “may affect, not likely to adversely 

affect” determination for spring Chinook and their critical habitat.
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Access to bull trout habitat occurs in the Upper Chewuch, Lower Chewuch, Lost River, Upper 

Methow, and Middle Methow watersheds. By prohibiting these outfitter-guides from accessing 

spawning streams in the fall, no direct effects would occur to any life stages. Indirect effects 

from habitat disturbances were concluded as neutral to insignificant/discountable. Therefore, 

the proposed activity results in a “may affect, not likely to adversely affect” determination for 

bull trout and their critical habitat.

The extent of original coho salmon habitat in the Methow Sub-basin is not known and current 

reintroduction efforts have not found any known spawning adults or juveniles in any project 

area streams. All Chinook salmon habitat, except the ford across the Chewuch River at 

Thirtymile, is well downstream from pack and saddle stock outfitter-guide activities. Impacts to 

combined steelhead and spring Chinook critical habitat, as a rough coho surrogate, are 

considered unsubstantial, based on the Aquatics Biological Assessment in the analysis file. No 

adverse impacts to EFH are expected.

Mitigation Measures

Alternatives 2, 3, and 4 include Mitigation Measures that would be implemented in order to 

minimize impacts to various resources. These mitigations also serve as Best Management 

Practices (BMPs), as required by the Clean Water Act. The following list is included in the 

Mitigation Measures. The following measures would help the proposed project to meet the ACS 

and RMOs and comply with the Forest Plan’s aquatic and riparian Standards & Guidelines.

Campsites

Campsite mitigation measures (1 a-g and 2a-h)would prevent an increase in the existing barren 

core size which minimizes the potential for vegetation loss and erosion, thereby reducing 

potential for an increase in overland flow and sedimentation to nearby streams. Minimizing 

erosion and sedimentation mitigate potential impacts to water quality that may impact fish 

habitat.

Stream surveys completed on the upper Lost River, Chewuch River, Lake Creek, and Wolf Creek 

found fine sediment and bank erosion to be at low or optimal levels along the existing camps 

(surveys in analysis file). Suggesting, the existing campsite sizes have minimal to no erosion and 

sedimentation to adjacent streams. 

Trails

Trail mitigations (6 a-c) would reduce the potential of decreased water quality from erosion from 

trails by limiting the establishment of new trails and ensuring that existing trails are maintained 

so as to prevent erosion.

Stream surveys completed on the multiple streams adjacent to trails in the project area found 

fine sediment levels to be at low or optimal levels (surveys in analysis file) suggesting, the trails 

had minimal to no erosion and sedimentation to adjacent streams. 
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Sanitation

Sanitation mitigations (7 a-e) would help reduce the amount of fecal matter and other 

contaminants in waterways, helping to protect water quality. Proper disposal of waste away 

from water minimizes potential that contaminants are deposited directly in water and the 

potential for contaminants to wash into water during rain events. 

From the project hydrology report, fecal coliform levels from existing outfitter-guide use are not 

degrading water quality, suggesting human and stock fecal matter are not of a magnitude to 

alter the current high water quality. The proposed mitigation is similar to what has occurred for 

several years and it’s expected to have the same minor impact to water quality. 

Stock Containment and Grazing

Stock containment and grazing mitigations (8 a-j) would help reduce impacts to water quality 

from sedimentation at trail crossings, watering spots, and campsites. Loose grazing disperses 

stock across large areas, minimizing impacts to water quality and riparian areas. This helps to 

ensure that there is not an increase in erosion or sedimentation. Grazing stock away from water 

reduces the likelihood that lakeshores will be heavily impacted and eroded and the risk of 

contaminants such as fecal coliform impacting water quality.

Vegetation and Soil

Vegetation and soil mitigations (10 a-c) would help reduce water quality impacts by minimizing 

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

erosion potential. Vegetation helps to reduce overland flow, a mechanism by which sediment 

can be deposited in streams and lakes, by absorbing water and slowing the rate at which it 

reaches water. 

Stream buffers, with vegetative cover, are effective at mitigating sediment delivery to streams 

(Rashin et al. 2006; Liquori et al. 2008).

Aquatic Resources

Aquatic habitat, riparian reserve and riparian habitat conservation area mitigations (12 a-g) 

would help protect riparian areas, and reduce impacts to water quality from increased 

sedimentation, reduced shade, and hazardous materials. Closing camps during spawning season 

eliminates the potential that outfitter-guide use would result in trampling of redds. Educating 

guests and outfitters about bull trout and fishing regulations reduces the risk that clients 

accidently take a listed fish species. Storing hazardous materials away from water reduces the 

likelihood of water contamination in the event of a spill.

Prohibiting outfitters from using camps adjacent to bull trout spawning in the fall and from 

crossing spawning habitat (mitigation measure13 c and d) would be effective in preventing 

disturbances to this critical life stage. By preventing hazardous material from being handled or 

stored with Riparian Reserves or RHCAS, this would be effective in reducing the risk for spillage 

or contamination. 

Allowing only drop camps at Black Lake, and not allowing outfitter-guide camps on weekends or 

holidays between Memorial Day and Labor Day (mitigation measure 2c) would minimize 

potential effects to bull trout by protecting lake side habitat, and reducing fishing pressure.
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Cumulative Effects

The geographic area for cumulative effects is the Methow River and Chelan watersheds because 

any aquatic effects from the permitted use under the alternatives would not be felt beyond 

these watersheds. The temporal timeframe is the early 1900s through 2023, when the 10-year 

permits would expire and no additional effects would occur. This period is also includes 

reasonably foreseeable future actions listed at the beginning of this chapter for consideration in 

this cumulative effects analysis. 

Past, Present, and Reasonably Foreseeable Future Actions

Past actions that are still impacting aquatic habitat are discussed in the Current Condition 

section above. The effects of past, present and reasonably foreseeable future actions that 

would overlap impacts from pack and saddle stock outfitter-guide are summarized below.

Grazing

Throughout the analysis area cattle and sheep grazing has slowly declined from peak levels in 

the early 1900s. In the last 10 years sheep grazing has been discontinued in the Hart’s Pass area 

and in the Lake Chelan-Sawtooth and Sawtooth Backcountry. Cattle grazing has also been 

discontinued in the Wolf Creek watershed and across the Pasayten Wilderness. Today there is 

no livestock grazing in any of the wilderness areas and the number of domestic animals grazing 

from recreational activities in these areas is substantially lower than it has been for the last 80 

to 100 years. Livestock grazing would continue within the Bear/Ramsey/Volstead area. The 

elimination of livestock grazing in wilderness and the Sawtooth Backcountry combined with a 

continuation of pack and saddle stock grazing would result in fewer domestic animals grazing in 

the analysis area than under past conditions even though recreational pack and saddle stock 

grazing may increase by up to 5% in the future (IAC, 2003). In the Bear/Ramsey/Volstead area 

livestock grazing would be rested for at least another year to allow the burned during the 2006 

Tripod fire area to recover after which livestock grazing will continue with monitoring and 

annual review. The addition of a small amount of commercial recreational outfitter stock use 

combined with the existing livestock grazing permit is not expected to result in any noticeable 

changes to aquatic or riparian habitat in the Bear/Ramsey/Volstead area.

Recreation use

Non-outfitted recreation use by hikers and stock users is expected to increase by about 30% 

over the next 10 years (Refer to Reasonably Foreseeable Future actions in introduction of 

Chapter 3). A 5% increase in non-commercial pack and saddle stock recreation use combined 

with commercially outfitted pack and saddle stock use at levels that are similar to past levels 

(Alternative 2) or slightly less than past levels (Alternative 3) would result in conditions that are 

similar to the current condition because management of use in riparian areas would be the 

same under each alternative. Use on trails and at lakes would increase by about 35% over 

current conditions.

Trail maintenance would continue as it does now and drainage structures will be maintained on 

trail treads and any expansion of the existing trail network will be discouraged. Outfitter-guides 

will be prohibited from expanding the existing trail network and thus will add no incremental 

cumulative effects.
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It is expected that the Washington State Department of Fish and Wildlife will continue fish 

stocking of wilderness lakes depending on future budgets and recreational use levels. The 

Forest Service will continue to work with the agency to provide information about fishing 

activity and to provide information to anglers about fishing regulations and species 

identification where listed bull trout are present in the analysis area. Commercial outfitters 

would help with this effort by ensuring that their clients are knowledgeable about fishing 

regulations and species identification.

Alternative 1

Under Alternative 1, eliminating the outfitter-guides would reduce impacts to aquatic and 

riparian resources at the few localized areas accessed. However, these areas will continue to be 

used by the general public and only a few impacted areas would likely have slight 

improvements. Therefore, eliminating the existing outfitter-guide use would not be measurable 

or detectable and would have little to no cumulative benefit. 

Alternatives 2, 3 or 4

Alternatives 2, 3, and 4 would continue outfitter use with essentially the same effects to aquatic 

and riparian resources. Impacts would continue to occur to localized areas that are well 

dispersed and represent a small fraction of the entire analysis area. Additionally, ongoing use 

from private stock parties, hikers and other users would continue. 

There have been substantial reductions in sheep and cattle grazing across the entire analysis 

area, resulting in a positive cumulative effect to riparian and stream functions, as seen in the 

2000 stream surveys. Aquatic and riparian conditions in areas previously grazed by cattle and 

sheep would continue to improve without pressure from this type of grazing. 

Overall, aquatic and riparian conditions would continue to maintain high quality conditions at 

the reach, 6th and 5th field scales in wilderness and roadless areas given the minimal 

management activities that take place in these areas. Aquatic and riparian conditions are 

considered properly functioning across the analysis area and continuing the outfitter-guide 

activity would not meaningfully retard or prevent their functions. Given the large size of the 

analysis area, over one million acres, compared to the small amount of impacted area, 

cumulative impacts would too small to meaningfully measure or detect. 

CONSISTENCY FINDINGS

The design criteria and mitigation measures listed in Chapter 2 were used to ensure that all of 

the alternatives are consistent with the Forest Plans as amended by the Northwest Forest Plan 

and PACFISH. Specifically, the measures listed under mitigation measures would be effective in 

mitigating any potential effects because pack stock would be kept 200 feet away from water, 

riparian camps would not grow in size, and vegetation along streams and riparian camps would 

be protected. They would be part of the operating plans, with compliance required by the 

special use permit. Failure to comply with the terms and condition of their permits and 

operating plans would result in administration action would be taken as described above. All 

Alternatives would meet management objectives to maintain conditions in Riparian Reserves 

and RHCAs, maintain stream temperatures, prevent chemical contamination, maintain large 
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wood within channels, and provide for long term woody debris input. They would also meet 

Forest Plan standards and objectives (given the riparian buffers) as amended by each alternative 

and Aquatic Conservation Strategy and PACFISH objectives at the 6th and 5th field watershed 

scale (see specifics below and in Appendices K and L).

Standards and Guidelines

The aquatic and riparian Standard and Guidelines are met as follows:

Fisheries

Forest Plan 3-1 is met through current conditions and prohibiting live vegetation and nonhazardous snags from being cut, following Leave-No-Trace practices, using existing trails, 

loose versus concentrated grazing in designated areas away from streams, minimizing 

trampling of live vegetation, and designated travel ways in meadows or wet areas.

Forest Plan 3-4 and 3-5 are met through current conditions and prohibiting live vegetation 

and non-hazardous snags from being cut, following Leave-No-Trace practices, using existing 

trails, loose versus concentrated grazing in designated areas away from streams, and 

minimizing trampling of live vegetation.

Forest Plan 3-6 is addressed by current conditions and prohibiting live vegetation and nonhazardous snags from being cut, following Leave-No-Trace practices, using existing trails, 

loose versus concentrated grazing in designated areas away from streams, and minimizing 

trampling of live vegetation.

PACFISH 

GM-3 is addressed through current conditions, alternative design, and following Leave-NoTrace practices, using existing trails, loose versus concentrated grazing in designated areas 

away from streams, minimizing trampling of live vegetation, and designated travel ways in 

meadows or wet areas.

RM-1 through RM-3 are addressed by current conditions, alternative design, and prohibiting 

live vegetation and non-hazardous snags from being cut, using designated campsites, 

prohibiting any measurable increase in barren core at riparian campsites, following LeaveNo-Trace practices, using existing trails, loose versus concentrated grazing in designated 

areas away from streams, minimizing trampling of live vegetation, and designated travel 

ways in meadows or wet areas. 

LH-3 is addressed through current conditions and alternative design. 

Northwest Forest Plan 

GM-1, GM-2, and GM-3 are addressed through current conditions, alternative design, and 

following Leave-No-Trace practices, using existing trails, loose versus concentrated grazing 

in designated areas away from streams, minimizing trampling of live vegetation, and 

designated travel ways in meadows or wet areas.

RM-1 and RM-2 current conditions, alternative design, and prohibiting live vegetation and 

non-hazardous snags from being cut, using designated campsites, prohibiting any 

measurable increase in barren core at riparian campsites, following Leave-No-Trace 

practices, using existing trails, loose versus concentrated grazing in designated areas away 

from streams, minimizing trampling of live vegetation, and designated travel ways in 

meadows or wet areas.
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PACFISH Riparian Management Objectives

All the alternatives would be consistent with the PACFISH Riparian Management Objectives. To 

assess consistency with the RMOs, the proposed project was assessed for maintenance or 

restoration of healthy and functioning aquatic and riparian resources. 

The following table depicts the expected effects of the No Action and the Action alternatives to 

the Riparian Management Objectives (RMOs) found in PACFISH and INFISH for streams. 

The RMOs are an integral part of the 1995 PACFISH (USDA and USDI 1995) that was developed 

to restore and/or maintain the ecological health of watersheds and aquatic ecosystems within 

public lands. Design criteria and mitigation measures for the proposed pack and saddle stock 

outfitter-guide project are designed so the project would be consistent with the RMOs at subwatershed and watershed scales. The RMOs provide criteria against which attainment or 

progress toward attainment, of the riparian goals for watershed health is measured. There are 

specific numeric RMOs to which managers aim for during resource management. Design criteria 

and mitigation measures for the proposed pack and saddle stock outfitter-guide project are 

designed so the project would be consistent with the RMOs at sub-watershed and watershed 

scales. 

The RMOs most pertinent to the desired conditions and riparian management objectives within 

the project area, and that were tracked through the analysis are as follows: 

Pool Frequency – varies by channel width (see PACFISH 1995)

Water Temperature – No measurable increase in maximum temperature

Large Woody Debris - > 20 pieces per mile; >12 inch diameter; >35 foot length

Width:Depth Ratio - <10, mean wetted width divided by mean depth

Figure 3.6-10. Alternative comparison of each of the RMOs.

Riparian 

Management 

Objective 

(RMO)

Alternative One-No Action Alternative 2, 4, and 4

Pool 

Frequency > 

96 pools per 

mile in 

streams <10’ 

wide

Would remain the same. Most streams 

are in wilderness or roadless areas with 

little management. Most pool frequencies 

are considered properly functioning. The 

slight reduction in stock and human use 

would not change the existing high 

quality pool habitat across the project 

area. 

Would remain the same. Factors that influence 

pool frequency are fine sediment loads and 

instream wood. From the aquatics analysis, it was 

determined each different alternative would 

produce only small, insignificant amounts of fine 

sediment to the stream network. This impact 

would not be enough to fill in pools in streams, 

which have very low fine sediment levels already. 

All large wood in channels, standing live trees, and 

non-hazardous snags would remain. Therefore,

each of the alternatives would maintain the 

existing high quality pool habitat across the 

project area. 
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Riparian 

Management 

Objective 

(RMO)

Alternative One-No Action Alternative 2, 4, and 4

Water 

Temperature 

60o F. or less

About 1/3 of the streams surveyed in the 

analysis area currently exceed this 

temperature. Natural causes like 

wildfires, aspect, and ground water 

influence are largely responsible for 

stream temperatures. No increase is 

expected, under this alternative. 

With no removal of live vegetation along streams, 

stream temperatures would remain the same. 

Large Woody 

Debris (LWD) 

> 20 pieces 

per mile, 12” 

diameter at 

the small end 

and >35 feet 

in length*

Most streams have sufficient LWD levels. 

Areas with lower levels are not due to 

human factors, rather wood levels natural 

fluctuate and vary depending on 

recruitment and deposition areas. 

Conditions would remain unchanged 

under this alternative. 

With no removal of live vegetation along streams, 

non-hazardous snags, or downed wood >12 

inches in diameter, each alternative would protect 

instream wood levels. 

Width to 

Depth Ratio < 

10 (mean 

wetted width 

divided by 

mean depth) 

Currently some reaches of streams in the 

analysis area not are within the 10:1 

ratio, these are due mostly natural 

conditions since little to no human 

influence occurs at or above these 

streams. No increase is expected, under 

this alternative. 

Use along streambanks is limited due to steep 

terrain and dense vegetation. Additionally, stock 

would be on designated trails, controlled at 

camps, or freegrazing away from streams. Existing 

width to depth ratios would remain under each 

alternative. 

Bank Stability

(non-forested 

systems) 

>80% stable

Bank stability is high across the project 

area (>95% in most cases). Conditions 

would be unchanged under this 

alternative. 

Measures such as requiring stock to use existing 

trails, be tethered 200 feet from streams, and 

loose grazing in designated areas away from 

streams, would protect the existing high quality 

streambank conditions across the allotments for 

each alternative. 
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Riparian 

Management 

Objective 

(RMO)

Alternative One-No Action Alternative 2, 4, and 4

Lower Bank 

Angle > 75% 

of banks with 

<90o angle 

(i.e.: 

Undercut) 

(non-forested 

systems)

This metric has not been monitored 

across the project area. Most of the 

streams are in steep mountainous terrain 

with steep gradients, rocky channels, and 

streambanks are resistant to disturbances 

from bank alteration associated with 

livestock use. Limited data for streams in 

wilderness and roadless areas suggests 

streambanks are in stable condition due 

to the lack of human influence. The 

spatial scale of impacts would not 

compromise the overall high quality fish 

habitat. Therefore, collecting data on 

most or all of the streams and wetlands in 

the project area is not important for 

analyzing overall project effects. Existing 

bank angles would not change under this 

alternative. 

Measures such as requiring stock to use existing 

trails, be tethered 200 feet from streams, and 

loose grazing in designated areas away from 

streams, would protect the existing high quality 

streambank conditions across the allotments for 

each alternative. Additionally, the probability of 

grazing within 200 feet of streams is low. 

Summary of Effects 

All the campsites are within wilderness or other roadless areas where the main disturbances are 

natural disturbances such as fire, avalanches, floods, etc., therefore the RMOs are in all 

likelihood being met. All alternatives would be consistent with the Forest Plan as amended by 

PACFISH because they would be unlikely to hinder the attainment of the RMOs in the long-term. 

The pool frequency RMO will be unaffected since sediment inputs from possible bank trampling 

would be marginal. The large woody debris RMO would be maintained in all streams. The water 

temperature RMO would be maintained because this project would essentially not reduce 

stream shading. The width-to-depth ratio RMOs would be maintained because the camps do not 

occur on a large enough scale to reduce the canopy and cause significant stream channel 

widening. 

Some localized impacts would occur across the project area. However, the PSSO activity would 

have marginal effects at the site scale and virtually no effect at the reach, sub-watershed, or 

watershed scale. Natural upland and instream processes would remain in a highly functional 

condition and the few negative localized effects would have an immeasurable effect on these 

RMO objectives. 

Aquatic Conservation Strategy Objectives

All the alternatives would be consistent with the Aquatic Conservation Strategy Objectives. The 

rationale for this determination is as follows: 

1. Maintain and restore the distribution, diversity, and complexity of watershed and 

landscape-scale features to ensure protection of the aquatic systems to which species, 

populations and communities are uniquely adapted.
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At individual site scales, stock animals can modify features in the riparian areas and in 

upland areas. Within riparian areas associated with campsites and where trails cross 

streams, animals can reduce riparian vegetation and destabilize stream banks. 

However, these areas are not continuous and are less than 1% of riparian areas across 

the landscape. The few impacts would be unnoticeable at the project and 5th field 

watershed scale. Therefore, issuing the permits for 10 years to pack and saddle 

outfitter-guides would not prevent maintaining or restoring the distribution, diversity, 

and complexity of watershed and landscape-scale features sufficient for a healthy 

ecosystem.

2. Maintain and restore spatial and temporal connectivity within and between 

watersheds.

No part of the project effects would change the existing connectivity between 

watersheds. The very small fraction of effects at the site scale would not prevent 

riparian or aquatic dependent species from making normal migration patterns. This 

objective would be maintained. 

3. Maintain and restore the physical integrity of the aquatic system, including shorelines, 

banks, and bottom configurations.

Most of the land in the project boundary is steep, mountainous terrain. Streams have 

mostly steep gradients (4 to >10%) and are characterized by larger sized rocks in the 

channel and streambanks. Stream bank vegetation consists of conifers, alders, willows, 

dogwoods, and coarse substrates. These channel types are consistent with Montgomery 

and Buffington’s (1997) definition of cascade and step-pool morphology channels, which 

occur on steep slopes, confined valleys, and cobble and boulder substrates and tend to 

be very stable that are resistant to bank erosion and channel incision due to the coarse 

bed and bank material (Montgomery and Buffington’s 1997). Lakes vary from having 

wet meadows adjacent to rocky talus type slopes along the margins. Human impacts 

range from none to some areas with heavy localized impacts at campsites. Recreational 

impacts consist generally of campsites, trails around the lake, some lake shore 

trampling. Some lakes have multiple campsites while others have a few or just one. 

Impacts from recreation are generally light on lakes, especially outside of the campsites. 

The areas where outfitter-guide activity, pack animals and clients, could potentially 

disturb shorelines, banks, and bottom configurations are at lakes, wetlands, and streams 

adjacent to campsites, day use areas, and stream crossings on trails. Field review of a 

subset of streams, wetlands, and lakes across the analysis area identified human caused 

impacts occurring in the form of bank and vegetation disturbance where trails cross 

streams, where campsites are close to water, and where stock access wet meadows and 

wetlands (surveys are included in the analysis file). 

Field review of streams near camps and trails indicates current impacts to streambank 

stability and streamside vegetation are minor. At riparian campsites, typically there are 

about 2-10 feet of disturbed streambank and about 5-10 feet where trails cross streams. 

Vegetation browse was observed at the campsites, but little to none was observed 
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along streambanks. Within the Northwest Forest Plan project area, there are 21 riparian 

camps. There is an estimated 2,609 miles of streams in the analysis area, under 

jurisdiction of the Northwest Forest Plan. Based on a distance of 10 feet of disturbed 

stream banks near camps and 10 feet along trails, 0.25 miles total or less than 0.001% of 

disturbed stream banks associated with camps.

There are 306 lakes in or bordering the entire analysis area, within the Northwest Forest 

Plan area. These lakes have an estimated combined distance of 78 miles of lake shore. 

Much of the lake shores around these lakes are rocky slopes, which are highly resistant 

to recreational impacts. Based on lake surveys of human use, the campsites are the 

biggest impacts around lakes. Most campsites are positioned sufficient distance from 

the shores and none of the surveys found more than minor impacts to lake shores. 

Lakes used by pack and saddle stock outfitter-guides include Cooney Lake in the 

Sawtooth Backcountry and Crow, Corral, Sheep, Quartz, Ramon, Remmel, Upper 

Cathedral, Cougar, First Hidden, Middle Hidden, and Big Hidden lakes in the Pasayten 

Wilderness. Outfitters also use Sheep, Quartz, Upper Cathedral, Cougar, Remmel, Crow, 

and Ramon Lakes for day use and/or drop camps. Each of these lakes has been surveyed 

over the years. Based on lake surveys of human use from trails and campsite access 

from a handful of lakes in the project are, lakes that have nearby campsites that are 

within Riparian Reserves or RHCAs will have approximately 25 feet of disturbed 

lakeshore. This equals a combined lakeshore disturbance distance of 0.1miles or less 

than 0.001% disturbed total lakeshores across the project area. Pack and saddle stock 

outfitter-guides have requirements on how close they can camp and how close stock 

can be staged to lakes, which will minimize impacts to lake shores and lake ecology.

Based on the small proportion of lake shores and stream banks impacted by outfitterguide activity in the past, anticipated impacts at the project, 6th field, and 5th field 

watershed scales would be inconsequential. Additionally, current outfitter guide use 

accounts for 3% of the total use in the analysis area. Under the different action 

alternatives, outfitter guide use would stay the same, decrease by one percent, or 

increase by one percent. With the small use under each alternative, a one percent 

change is use would not have any difference in effects over current usage levels. 

Therefore, issuing the permits for a 10 year term would not prevent maintaining or 

restoring the physical integrity of lake and stream channel features sufficient for a 

healthy ecosystem.

4. Maintain and restore water quality necessary to support healthy riparian, aquatic and 

wetland ecosystems. Water quality must remain within the range that maintains the 

biological, physical, and chemical integrity of the system and benefits survival, growth, 

reproduction, and migration of individuals composing aquatic and riparian 

communities.

The project proposes to issue permits to outfitter-guides that use a combined area of 

880,000 acres in the portion of the analysis area under the jurisdiction of the Northwest 

Forest Plan. The party size limitation would be 12 people and 18 head of stock in 

Alternatives 2 & 4 or 12 heartbeats in Alternative 3. Occasionally, oversized parties 

would be allowed, but with the same requirements to meet resource objectives. No part 
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of the proposed activities would create openings next to or over streams or lakes; 

therefore, the project would have no effect to water temperature.

In areas where pack stock cross streams and drink, fecal contamination may occur. This 

could lead to increased nutrient levels at the site scale, but it would be quickly diluted 

and not detectable. Loose grazing would minimize impacts to riparian areas, wetlands, 

and water quality by dispersing stock. Stock would only enter water to drink and when 

crossing streams on trails. Otherwise, stock would graze in the uplands so the amount 

of time in water would be minimal. Stock containment areas within camps would be 

located away from streams and lakeshores. Flat terrain and surrounding ground 

vegetation would trap eroding soil and protect water quality. Outfitter-guides will also 

review and practice minimum-impact travel and camping practices with clients, 

including those at drop camps. The following pamphlets will be used as the standard: 

"Rocky Mountain Leave No Trace Skills and Ethics", "North American Leave No Trace 

Skills and Ethics", and “Horse Use Leave No Trace Skills and Ethics" (Leave-No-Trace 

2001a and 2001b). These measures would reduce the effect of any change in nutrient 

levels to negligible levels and levels would be quickly diluted at the site scale. Some 

increase in nutrient level may occur at the site scale but would be quickly diluted and 

have no effect on aquatic resources. There would be no effects at the 6th and 5th field 

watershed scales.

Fecal coliform levels at lakes and streams may be elevated where livestock access the 

water. Fresh water would quickly dilute the bacteria as water is constantly flowing 

down streams, through wetlands, and circulating in lakes. There are no known 

detrimental fecal coliform bacterial levels for the project area. There are no water 

bodies in the project area listed on the 2012 Washington State 303(d) list for fecal 

coliform. Based on the minimal effects at the site scale, there would be no effects to 

natural fecal coliform levels at the 6th and 5th field watershed scales.

In summary, there would be no effects to temperature and insignificant effects to 

nutrient and fecal coliform levels at the site scale. No changes to nutrients and fecal 

coliform would occur at the 6th or 5th field watershed scales. Therefore, issuing 

outfitter-guide permits for 10 years would not prevent maintaining or restoring water 

quality.

5. Maintain and restore the sediment regime under which aquatic ecosystems evolved. 

Elements of the sediment regime include the timing, volume, rate, and character of 

sediment input, storage, and transport.

The primary source of sediment from outfitter-guide activity is bank trampling when 

pack animals drink and to a lesser degree at stream crossings. From these disturbances 

sediment delivery to lakes and streams would be insignificant. The only time livestock 

would access lake shores and stream banks is to water. All other times, outfitters either 

loose-graze stock in the uplands, or keep stock confined by tethering them to a highline, 

hobbling, or corralling. Some drift may occur to lakes and streams, but it would be 

minimal. Therefore, the amount of time spent at any water body would be short and the 

associated disturbance and sediment delivery minimal. Based on these factors, the 
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amount of sediment generated when pack animals drink or cross streams would be 

inconsequential.

The small effects to sediment at the site scale would not translate to any effect at the 

6th or 5th field watershed scale. Since most streams are in either wilderness or areas 

with few roads, wood levels are generally good to excellent (surveys in analysis file), and 

capable of trapping and sorting any small increase in sediment resulting in no effects 

downstream. Therefore, issuing the permits for 10 years would not prevent maintaining 

or restoring the sediment regime of lake and stream channel features sufficient for a 

healthy ecosystem.

Wildfires which burned in the early to mid-2000s in and around the Pasayten have 

caused an increase in sediment in several of the creeks and rivers. Substrates in Lake 

Creek were low in fine sediment levels prior to the Farewell Fire (2003). A 1995 stream 

survey report (in analysis file) noted cobbles and small boulders were the most common 

substrates in Lake Creek prior to the fire, but found fine sediment in natural flat areas 

(depositional). The amount of fine sediment was considered natural and properly 

functioning. 

Similarly in the upper Chewuch River, prior to the effects of the 2001 Thirtymile Fire, 

fine sediment levels were mostly low (8, 11, and 25%). Fine sediment deposits occur 

naturally in a flat reach in the upper Chewuch. Andrews Creek had low fine sediment 

levels prior to the Farewell Fire in 2003 (<10%). Following the fires, the fine sediment 

increased substantially in these streams. These were natural disturbances that brought 

large quantities of wood and spawning gravels into the creeks and rivers. Fish habitat 

conditions have improved substantially because of the increased habitat complexity 

created by the wood and gravel. 

Habitat conditions were possibly at risk for sediment following the fires; however the 

fires were a natural disturbance, so these elevated levels are within the natural 

disturbance regime. Prior to the fires, fine sediment conditions were good overall. 

Recreation activities, including pack and saddle stock outfitter-guides, have occurred in 

these areas for close to a century and the pre-fire sediment data demonstrates the 

activities have had little to no effect on channel substrate conditions. Years after the 

fire, current fine sediment levels are likely close to pre-fire levels. Habitat conditions in 

rivers and streams have shown to improve following fires in areas with little or no 

human influence, such as the case with burned areas in the Pasayten (Gresswell 1999). 

The primary source of sediment from outfitter-guide activity is bank trampling when 

pack animals drink and to a lesser degree at stream crossings. From these disturbances 

sediment delivery to lakes and streams would be insignificant. The only time livestock 

would access lake shores and stream banks is to water. All other times, outfitters either 

loose-graze stock in the uplands, or keep stock confined by tethering them to a highline, 

hobbling, or corralling. Some drift may occur to lakes and streams, but it would be 

minimal. Therefore, the amount of time spent at any water body would be short and the 

associated disturbance and sediment delivery minimal. Based on these factors, the 
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amount of sediment generated when pack animals drink or cross streams would be 

inconsequential.

The small effects to sediment at the site scale would not translate to any effect at the 

6th or 5th field watershed scale. Since most streams are in either wilderness or areas 

with few roads, wood levels are generally good to excellent (see surveys in project file),

and capable of trapping and sorting any small increase in sediment resulting in no 

effects downstream. Therefore, issuing the permits for 10 years would not prevent 

maintaining or restoring the sediment regime of lake and stream channel features 

sufficient for a healthy ecosystem.

6. Maintain and restore in-stream flows sufficient to create and sustain riparian, aquatic, 

and wetland habitats and to retain patterns of sediment, nutrient, and wood routing.

Instream flows are unlikely to be affected by the outfitter-guide alternatives. There 

would be no measurable effects to stream flow from this project. Please see the 

Hydrology report for details. 

7. Maintain and restore the timing, variability, and duration of floodplain inundation and 

water table elevation in meadows and wetlands.

Pack and saddle stock outfitter-guide activity would not create open areas that would 

result in increased snow-depth and rapid melt-off. Therefore, the alternatives would 

not result in any changes to stream flows.

Water tables in wetlands may be impacted at a few areas on trails and when animals 

loose herd graze. Users that do stay on trails may also widen and deepen impacted 

areas. Water may begin to flow as a stream through the wetland, where the water 

originally infiltrated into the soil within the wetland. The net effect is that water could 

leave the portion of the wetland directly adjacent to trails faster than before. Since 

these wetlands contribute to late season flows in down slope streams, any changes in 

the wetlands may reduce late season flows in nearby downstream locations. However, 

the relative impact on the wetlands in all the areas would be low because the impacts 

would be isolated to areas adjacent to trails, and the affected wetlands are 

approximately 1% of the total wetlands. Any subsequent changes to late season flows 

would be minor and immeasurable. Across the analysis area, previous and current pack 

stock (outfitted and non-outfitted) have accessed only a small fraction of all the 

wetlands. By following the mitigation measures, effects to water tables would be 

minimal at the site scale and would have no effects at the 6th and 5th field watershed 

scales.

8. Maintain and restore the species composition and structural diversity of plant 

communities in riparian areas and wetlands to provide adequate summer and winter 

thermal regulation, nutrient filtering, appropriate rates of surface erosion, bank 

erosion, and channel migration and to supply amounts and distributions of coarse 

woody debris sufficient to sustain physical complexity and stability.
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Minor impacts to riparian vegetation will occur when pack stock access water to drink 

and at stream crossings on occasion. Impacts to riparian vegetation would be limited to 

areas near camps, day use areas, and along trails at stream crossings; this would be a 

small proportion of all riparian resources across the analysis area.

Outfitter-guide pack and saddle stock will be allowed to loose graze in the analysis area,

including in wetlands. This dispersed grazing technique minimizes concentrated effects 

to wetlands. Some soil compaction and displacement occurs, but the relatively small 

number of stock in any given group (maximum party size is 18 head of stock) and the 

short amount of time pack and saddle stock outfitter-guides are operating (typically 

early July through mid-October), minimizes impacts to soil and plant communities in the 

wetlands. The occasional oversized party would not increase the amount of compaction 

because they would be rare, and the number of stock would not be allowed to increase 

to the point of causing additional impacts. In addition, the vast majority of wetlands in 

the analysis area (approximately 99%) are over 500 feet from established campsites, 

and the wetlands are spread across the 1.1 million-acre analysis area. This results in 

most wetlands never being affected by pack and saddle stock grazing, and existing in a 

pristine condition. 

The few impacts to riparian dependent vegetation would have a slight negative effect to 

bank stability by reducing vegetative cover, but not to the extent that surface and bank 

erosion and channel migration would change. Because much of the area is in wilderness 

and areas with few roads, the riparian forest has more than enough trees to supply large 

wood to streams. All fire wood collection in riparian areas would be limited to pieces 

less than 12 inches in diameter. The proposed outfitter-guide activity would not change 

conditions at any spatial scale. Therefore, the existing activity and alternatives would 

not prevent maintaining or restoring species composition and structural diversity of 

plants capable of providing the above protection and complexity at the site, 6th field, or 

5th field watershed scales.

9. Maintain and restore habitat to support well-distributed populations of native plant, 

invertebrate and vertebrate riparian-dependent species.

At the site scale, pack stock have some negative impacts to riparian vegetation and 

habitat associated with lakes and streams when drinking water from trampling banks, 

browsing vegetation, and disturbing wet areas. The few areas along streams and lakes 

impacted when pack stock access water is only a fraction of all water bodies across the 

project area. There are an estimated 306 lakes and 2,609 miles of streams in the 

analysis area covered by the Northwest Forest Plan and there are only 11 camps within 

the Riparian Reserves of lakes and 21 camps in Riparian Reserves of streams. The 

impacted area would represent less than 0.001% of all lake shores and stream bank 

miles. Therefore, the area of riparian habitat impacted currently and the impacts from 

issuance of 10 year permits, with the associated mitigation measures listed in Chapter 2, 

would be inconsequential at the site scale and no effects at the 6th field or 5th field 

scales.
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Summary of Effects 

The ACS acknowledges that disturbance events, such as wildfire, landslides, and floods, 

maintained the long-term productivity of aquatic ecosystems in the NWFP area. These events 

resulted in pulses of materials (i.e. sediment and wood) being delivered to stream channels. 

Consequently, there was a wide variation in conditions at the site and watershed scale over time 

(Naiman et al. 1992, Benda et al. 1997) that were often resulting in periods of degraded 

conditions. The result was a mosaic of conditions in watersheds and sub-watersheds that shifted 

across the landscape with time. Reeves et al. (1995) and Rieman & McIntyre (1993) argued that 

Pacific salmon (Oncorhynchus spp.) and bull trout had life-history attributes that allowed them 

to persist in such an environment. 

The ACS is designed to maintain aquatic ecosystems within the range of variability at the sites 

and small sub-watershed scale and the larger sub-watershed and watershed scale to provide for 

acceptable populations of anadromous salmonids and other targeted organisms. It may be 

expressed as the frequency distribution of productive and non-productive sites and subwatersheds in a sub-watershed or watershed scale, respectively (Benda et al. 1997). When the 

current distribution of habitat conditions are within the acceptable range of variability for the 

watershed or sub-watershed, then the area is in compliance with the ACS. The presence of 

degraded conditions at individual sites or degraded sub-watersheds are not always be 

interpreted as failure to comply with the ACS. Natural events such as floods or wildfires can 

degrade streams reaches or entire drainages, while other areas in a watershed are in properly 

functioning condition. This is natural for landscapes within the Pacific Northwest, where 

ecosystems are dynamic as a result of the physical characteristics, natural disturbance events, 

and climatic features of the region (Reeves 1999). 

Watersheds across the analysis area, within the NWFP, continue to provide a high level of 

properly functioning habitat conditions at the site, sub-watershed, and watershed scale. Natural 

disturbances continue to occur, albeit at a different frequency than historically, but occur and 

function to provide a mosaic of habitat conditions. The extent of aquatic and riparian habitat 

effects from the proposed outfitter guide activity does present small, localized habitat 

disturbances but not sufficient to degrade habitat function or process. At the sub-watershed 

scale and larger, the project has virtually no effect. 

Determining consistency with the ACS at the site or small sub-watershed is not as simple as 

assuming that all sites or small sub-watersheds need to be in "good" condition at all times and 

that any actions that may "degrade" a site or small sub-watershed violates the ACS. Conditions 

at the small sub-watershed may range from very favorable to unfavorable for fish over time. The 

ACS aims to allow for the expression of these variable conditions at a site or small subwatershed. However, it is not possible to evaluate consistency with the ACS at the site scale by 

simply looking at the individual sites alone. The ACS was designed to maintain and restore this 

variability or some desired range of variability similar to the natural range of watersheds that 

will support acceptable levels of fish populations. 

Some localized impacts will occur across the project area. However, the proposed activity would 

have negligible effects at the site scale and virtually no effect at the reach, sub-watershed, or 

watershed scales. Natural upland and instream processes would remain in a highly functional 

condition and the few negative localized effects would have an immeasurable effect on these 

ACS objectives. The ACS objectives would be maintained under each of the action alternatives. 
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3.7 BOTANY

Below is a summary of the Botanical Evaluation for the Pack and Saddle Outfitter-Guide Permit 

Renewal Project which is available in the project analysis file (Baraibar and Ohlson 2012).

REGULATORY FRAMEWORK

The broad objective of Forest Service Manual (FSM) 2620.2 habitat planning and evaluation is to 

provide habitats to meet goals and objectives for wildlife and fish, including endangered, 

threatened, and sensitive animal and plant species set forth in land and resource management 

plans. Specific to this objective is to: 1) Integrate habitat planning into land management and 

project plans to meet National, Regional, and local objectives for wildlife and fish, including 

threatened, and endangered and sensitive animal and plant species; 2) Provide a sound base of 

information to support management decision-making affecting wildlife and fish, including 

endangered, threatened, and sensitive animal and plant species, and their habitats; 3) Identify 

opportunities and management strategies to maintain and improve habitats throughout the 

National Forest System.

Managing for biological diversity and species viability is also outlined in the Forest Service 

Manual (FSM) 2620. The FSM requires a project to consider the distribution and abundance of 

plant and animal species, and their community requirements in order to meet the overall 

multiple-use objectives and to provide a sound base of information to support management 

decision-making. Managing for species viability requires habitat that must provide for the 

number and distribution of reproductive individuals to ensure the continued existence of a 

species throughout its geographic range. 

Specific management for Sensitive species follows Forest Service Region 6 Sensitive Species 

policy as identified in Section 2670 of the Forest Service Manual (FSM). Sensitive Species are 

defined as those plants and animal species identified by a Regional Forester for which 

population viability is a concern, as evidenced by substantial current or predicted downward 

trends in population numbers or density and habitat capability that would reduce a species’ 

existing distribution (FSM 2670.5). Management of sensitive species “must not result in a loss of 

species viability or create significant trends toward federal listing” (FSM 2670.32). The Biological 

Evaluation (BE) in the analysis file is a summary that assesses the effects of the proposed action 

and alternatives on Sensitive and Federally listed plant resources and unique habitats within the 

permitted area of the outfitters and guides included in this analysis as required by the Forest 

Service Policy outlined in Section 2670 of the Forest Service Manual. 

Survey and Manage Species (S/M)

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

issued an order in Conservation Northwest, et al. v. Sherman, et al., No. 08-1067-JCC 

(W.D. Wash.), granting Plaintiffs’ motion for partial summary judgment and finding 

NEPA violations in the Final Supplemental to the 2004 Supplemental Environmental 

Impact Statement to Remove or Modify the Survey and Manage Mitigation Measure 

Standards and Guidelines (USDA and USDI, June 2007). In response, parties entered into 

settlement negotiations in April 2010, and the Court filed approval of the resulting 
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Settlement Agreement on July 6, 2011. Projects that are within the range of the 

northern spotted owl are subject to the survey and management standards and 

guidelines in the 2001 ROD, as modified by the 2011 Settlement Agreement (USDA and 

USDI 2011). 

The Pack and Saddle Outfitter Guide Permit is consistent with the Methow Valley 

Ranger District Resource Management Plan/Forest Land and Resource Management 

Plan as amended by the 2001 Record of Decision and Standards and Guidelines for 

Amendments to the Survey and Manage, Protection Buffer, and other Mitigation 

Measures Standards and Guidelines (USDA and USDI 2001), as modified by the 2011 

Settlement Agreement. 

The 2011 Settlement Agreement states:

“For projects with signed Records of Decision, Decision Notices, or Decision 

Memoranda from December 17, 2009, through September 30, 2012, the Agencies 

will use either of the following Survey and Manage species lists:

a. The list of Survey and Manage species in the 2001 ROD (Table 1-1, Standards 

and Guidelines, pages 41-51).

b. The list of Survey and Manage species and associated species mitigation, 

Attachment 1 to the Settlement Agreement.”

Project Consistency: The Pack and Saddle Outfitter Guide Permit applies the Survey and 

Manage species list in the 2011 Settlement Agreement (Table, Settlement Agreement 

Attachment 1) and thus meets the provisions of the 2001 Record of Decision and Standards and 

Guidelines for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation 

Measures Standards and Guidelines, as modified by the 2011 Settlement Agreement. A Survey 

and Manage Species Tracking Form (See Appendix L) summarizes how this project is meeting 

Standards and Guides. 

Forest Plans

The Okanogan and Wenatchee Forest Plans, as amended, have standards and guidelines that 

pertain to vegetation. Some are forest-wide, and others are specific to particular management 

areas. 

In the Okanogan Forest Plan, the following standards and guidelines apply to this project in 

Management Area 15B (page 4-95; outfitter-guides are allowed to operate in this MA, but not 

the other wilderness management area: MA15A):

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

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

areas to protect wilderness values. 

MA 15B-22A There should be no long-term modification of natural plant succession as a 

result of human activities on areas outside campsites, administrative sites, and designated 

trail tread. Acceptable modifications are those which can recover in one growing season.
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MA 15B-22B Vegetation loss should not exceed 400 square feet (one percent of any acre) at 

any impacted site.

MA15B-22C There should be no loss of trees from recreation activities.

MA 15B-22D There should be fewer than four trees with exposed roots per impacted site.

MA 15B-22E Standing snags should be left, except where removal is necessary to protect 

major bridges and administrative facilities. Removal of snags during fire suppression 

efforts shall be determined on a case by case basis. However, standing snags can also be 

removed if they pose a safety risk to outfitters using the camps.

MA 15B-22F Vegetative impacts along trails shall be confined to the planned location and to 

meet individual trail objectives.

MA 15B-22G Firewood gathering may be permitted for use on site and shall be limited to 

dead and down material. Firewood gathering shall be restricted where necessary. Use of 

small fires and self-contained stoves shall be encouraged.

In the Wenatchee Forest Plan, the following standards and guidelines apply to this project:

Wilderness, Semi-Primitive, a. (1) Vegetation (page IV-73)

Area of vegetation loss, and compacted bare mineral soil at any campsite, should not exceed 

625 square feet.

There should be no loss of trees at any site and only six trees per site with roots exposed or 

which show signs of human use impact.

There should be no long-term modification of plant succession and only short-term 

modification due to human activity or livestock grazing that can recover in one growing 

season.

Dead trees or dead, woody debris may be utilized for campfire wood in amounts that can be 

replaced annually through natural accumulation.

ROD for Amendments to Forest Service and Bureau of Land Management Planning Documents 

Within the Range of the Northern Spotted Owl

The Standard and Guidelines for Management of Habitat for Late Successional and Old-Growth 

Forest Related Species Within the Range of the Northern Spotted Owl in the ROD listed above, 

contains several Aquatic Conservation Strategy Objectives. Below is a list of objectives that 

apply to this project listed in order as they appear in the ROD: 

1. Maintain and restore the distribution, diversity, and complexity of watershed and 

landscape-scale features to ensure protection of the aquatic systems to which species 

populations and communities are uniquely adapted.
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4. Maintain and restore water quality necessary to support healthy riparian, aquatic, and 

wetland ecosystems. Water quality must remain within the range that maintains the 

biological, physical, and chemical integrity of the system and benefits survival, growth, 

reproduction, and migration of individuals composing aquatic and riparian communities.

8. Maintain and restore the species composition and structural diversity of plant 

communities in riparian areas and wetlands to provide adequate summer and winter 

thermal regulation, nutrient filtering, appropriate rates of surface erosion, bank erosion, 

and channel migration and to supply amounts and distributions of coarse woody debris 

sufficient to sustain physical complexity and stability.

9. Maintain and restore habitat to support well-distributed populations of native plant, 

invertebrate and vertebrate riparian-dependent species.

ANALYSIS METHOD

The plant analysis for this project covers species on the 2011 Regional Forester’s Special Status 

Species Lists, which includes the Federally Threatened, Endangered, and Proposed Species 

(TE&P) and Sensitive Species List, provided under the Interagency Special Status & Sensitive 

Species Program (ISSSP). As mentioned above, this analysis will use the 2011 Survey and 

Manage (S/M) list. In the course of writing this document, the S/M species list has changed. 

Species lists were compared to assess changes and additional habitat assessments were 

conducted for changes in the list. The complete list for both Survey and Manage and R6 Special 

Status species can be found in Appendix F. 

Multiple years of observations of outfitter use patterns, knowledge of Sensitive plant species 

and special habitats, across the Chelan, Tonasket, and Methow Districts by District Botanists and 

Wilderness specialists was integral in assessing the effect of outfitter use on Threatened, 

Endangered, and Sensitive plant populations as well as Survey and Manage plant populations. 

Due to the fact this analysis area is over a million acres and use can be requested throughout 

the area by any permitted outfitter, a risk assessment to resources was made using 

Geographical Information Systems (GIS). Field visits were made where necessary, but not all 

the area was sufficiently inventoried during the appropriate season to confirm presence or 

absence of all of the species of concern listed in Appendix F. Field and survey notes taken 

during survey efforts are located in the analysis file. There is a small band of non-wilderness 

land along the north shore of Lake Chelan, for the sake of this analysis; it is being included in the 

Lake Chelan Sawtooth Wilderness subunit. The Fish Creek Base Camp is located in this portion 

of non-wilderness; however it is part of the Chelan Inventoried roadless area. 

The wetland analysis was based on a GIS layer derived from the U.S. Department of Interior and 

Fish and Wildlife Service publication “Classification of Wetlands and Deepwater Habitats of the 

United States” (Cowardin and others 1979). This is the best available information on wetland 

locations and types. This publication provided sufficiently accurate information for the analysis 

of impacts to wetlands from outfitter-guide activities. This wetland classification combines 

information from mapping, aerial photography, plant, soil and other ecological factors to 

designate wetlands. These wetland classifications, of course, are very broad and are being used 

in conjunction with the unique habitat requirements for the various species included in this 
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analysis (Appendix J) and local knowledge of camp sites and use areas. The Forest Service 

Manual provides the regulatory framework for the legality of wetland inventory, which the FSM 

mandates be done in Forest Planning. The Department of Interior’s publication is the standard 

delineation used by the Forest Service and meets Forest Service Manual direction.

Survey and Manage (S/M) Strategic Surveys were also completed by Regional taxa experts and 

District personnel between 1999 and 2003 throughout the Methow Valley RD Field and survey 

notes taken during survey efforts are located in the analysis file. These surveys centered on 

high probability habitat mainly found west of Washington Pass in the North Cascades Scenic 

Highway Corridor and portions of the Pasayten and Lake-Chelan Sawtooth Wildernesses. Due to 

the large scale of the analysis area, surveying high probability habitats was the best strategy for 

locating and managing Survey and Manage S/M populations. 

The Pasayten, Spanish Camp and Sheep Mountain areas were inventoried for Survey and 

Manage species in 2002 and 2003. Field and survey notes taken during survey efforts are 

located in the analysis file. Inventory crews included Regional Office non-vascular taxa experts 

and their crew. The most extensive inventory efforts centered around Spanish Camp and the 

Sheep Mountain areas and were conducted at the same time as the Sensitive plant surveys. 

Other Strategic Surveys were conducted by Regional Office fungi taxa crews in the Hidden Lakes 

area and other portions of the Pasayten, Methow side of the Lake Chelan Wilderness, and North 

Cascades Scenic Corridor between 1999 and 2001. Additional bryophyte surveys were 

conducted by a Regional taxa expert and District Botanists along the North Cascades Scenic 

Corridor, Pasayten, Methow side of the Lake Chelan Wilderness, and the Falls Creek Drainage. 

High probability habitats were targeted during these survey efforts. 

The best available science was used for this analysis, including the methodology and data 

sources described above, to describe the ecological and social conditions within the analysis 

area, and the potential effects of the proposed outfitter-guide use on vegetation. In addition, 

GIS data was used to perform the analysis on all Alternatives. The GIS data was gathered from 

on the ground surveys and describe an array of habitats. 

AFFECTED ENVIRONMENT

Loose Grazing

Loose grazing is frequently referenced in the following discussions regarding the existing 

conditions of plant communities as a result from stock use. Loose grazing refers to allowing 

stock to disperse at will to areas they find to be the best suited for their dietary needs. Free 

ranging animals rarely over graze an area as they can move on to another area after they have 

grazed a plant or spent time in an area. Free roaming animals have less of a tendency to over 

graze an area because they don’t travel over the same ground repeatedly. Plant communities 

are able to recover from the light grazing and trailing pressure without long-term modification 

to the plant biodiversity or community structure (natural plant succession). Sites with large bare 

areas are highly problematic, since re-establishment of vegetation is often difficult (Spildie et al., 

2000). Since pack and saddle stock are allowed to loose graze they may travel through some 

wetland habitats as they access upland grazing areas. 
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Hummocks

In the north east portion of the Pasayten Wilderness hummock pattern ground can be found. 

Earth hummocks are a type of patterned ground occurring in subarctic and alpine environments 

that form in groups, are three-dimensional knoblike shapes covered with vegetation about 14 

inches) tall, and up to 3 feet across. These topographic features are not considered wetland 

habitats. Hummock formation is associated with the fine-grained frost susceptible soils that are 

made up mainly of Mt. Mazama ash. In the Pasayten, hummock origin is speculative at best. 

Earth hummocks in the North America arctic and subarctic regions are mainly associated with 

permafrost, which is the key element in driving the frost heaving process that forms and 

maintains them. Another theory suggests they are relic or fossil formations formed when 

permafrost was once common in the area and the hummocks are now being maintained by 

seasonal frost heaving action. Other hummocks are found in non-permafrost environments and 

are considered fossil topographic formations or are still actively forming during freeze thaw 

periods (Washburn 1956, Zoltai & Scotter 1982).

In the Pasayten, hummocks are found in the transition zones between open wetlands and the 

drier uplands where the transition from wetland to upland is gradual and in small depressions. 

Elsewhere, hummocks form on gentle slopes, less than 30% (200), in small depressions and 

basins were volcanic ash is deposited. In these areas the volcanic ash is thought to have eroded 

from surrounding slopes settling in these basins and small ponds resulting in deep deposits, 

often greater than 50 cm (Zoltai & Scotter 1982, McKay 1980). Although this study was not 

specific to the Pasayten hummocks, the hummocks in the study bare the same characteristics.

In areas with permafrost, in early summer the ice lenses in the surface thaw and soil moisture in 

the hummock migrates downwards to grow more ice lenses near the still frozen permafrost. As 

these ice lenses grow they create an uplift of moisture through the center of the hummock. 

When the moisture reaches the top of the hummock it then cycles out and back toward the 

permafrost zone creating the similar marbled mix of ash, mineral soil, and organic matter as 

found in non-permafrost formed hummocks (McKay 1980). As mentioned above, although this 

study was not specific to the Pasayten hummocks, the hummocks in the study bare the same 

characteristics.

In the Pasayten, the suspicion is that there is no permafrost layer driving this process and that 

these hummocks are either actively forming or were formed at a time when permafrost was 

present and are now being maintained by seasonal freeze thaw cycles. In non-permafrost 

hummocks, the transition between volcanic ash and lacustrine silt is distinct, not distorted, 

indicating the lower parts of the soil remain stable. Radiocarbon dating of the layers within a

hummock found the lower stable layer to be about 3000 years with the active layers within the 

top 9.84 inches (25 cm) to be between 2600 and 1680 years with the youngest material found 

near the apex of the hummock (Zoltai & Scotter 1982). 

Since hummock development is slow, plant communities have evolved with the uplifting action 

that are unique to these mounds. One R6 Sensitive plant that seems to favor hummock habitat 

in the Pasayten is Gentiana glauca (glaucous gentian). Glaucous gentian is a tundra species that 

grows in moist subalpine and alpine environments that are regularly disrupted by frost heaving. 

In the Pasayten it is near or above timberline and above 7,000’ in elevation. The plant 
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communities in the troughs between the hummocks and the mounds themselves are distinctly 

different. On the top of the mounds, crustose lichens (lichens that are paint-like or flat), and 

mosses such as Cetraria ericetorum (cetraria lichen), Thamnolia vermicularis (whiteworm 

lichen), and Cetraria nivalis, frequently cover nearly 80% of the mound surface, with Vaccinium 

caespitosum (dwarf bilberry) and Phyllodoce empetriformis (pink mountain heath) being the 

dominant vascular plants. In the troughs, vascular plants dominate with Lupinus wyethii

(Wyeth’s lupine), Antenaria lanata (wooly pussytoes), Kalmia microphylla (alpine laura), 

Sibbaldia procumbens (creeping sibbaldia), Luzula species (woodrushes), Veronica cusickii

(Cusick’s speedwell), Castilleja parviflora (mountain Indian paintbrush), Carex nigricans (black 

alpine sedge) Phyllodoce empetriformis, and Vaccinium caespitosum being common associates. 

Glaucous gentian is an R6 Sensitive species; none of the other species listed in this paragraph 

are classified as R6 Sensitive or Survey and Manage. 

In some places in the analysis area, such as Bald Mountain, Beaver Creek, Tungsten Mine, and 

other isolated locations, the hummock topography that supports glaucous gentian has been 

trampled as a result of past sheep grazing and pack and saddle stock activities. Populations are 

showing signs of lost vigor. Since hummocks provide a micro-habitat for glaucous gentian, 

disturbance could cause a loss of species viability in these areas. However, the areas of 

hummocks being disturbed by pack and saddle stock are small relative to the total amount of 

the hummock topography and glaucous gentian within the Pasayten. Although some damage to 

hummocks and glaucous gentian within the analysis area is occurring, there is enough hummock 

topography and glaucous gentian in the Pasayten to ensure that loss of individuals would not 

likely result in a loss of population or species viability. Since the majority of the hummock 

patterned ground is beyond any area currently used by outfitters, the change in the condition of 

this unique pattern ground is insignificant relative to the area that is currently unaffected by 

activities in the Pasayten Wilderness. 

Wetlands

A wetland is characterized as a distinct ecosystem that is saturated with water, either 

permanently or seasonally. The primary factor that distinguishes wetlands from other land 

forms is the characteristic vegetation that is adapted to its unique soil conditions: Wetlands 

provide important plant habitat throughout the analysis area. Plant species diversity is generally 

greatest in association with moist meadow and wetland habitats compared to the surrounding 

upland ecosystems. They also support many species of sensitive plants. 

There are 8,357 acres of mapped wetlands and open water habitats in the analysis area; this is 

0.8% of the analysis area. These numbers were derived from the Wetland GIS layer for the 

Okanogan-Wenatchee National Forests. Mapped wetlands, excluding open water habitats, 

make up 0.6% of the analysis area. These habitats are rare throughout the analysis area, with 

highest concentration (67.3% or 5,621 ac) of mapped wetlands and open water habitats 

occurring in the Pasayten Wilderness. Within the Pasayten these habitats are concentrated in 

the northeast portion of the Pasayten, north of Andrews Pass in the vicinity of Bald Mountain, 

Cathedral Peak, Amphitheater Mountain and then east into Horseshoe Basin. Map 3.7-1 in the 

Map Section shows the wetland locations across the analysis area.

Affiliation of Sensitive plants with wetland habitat and wetland edge habitat is high. Emergent 

wetlands, particularly the transition zone between open water and upland habitats, are 
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important habitat for many of the sensitive Carex (sedge) species and Eriophorum 

viridicarinatum (green-keeled cottongrass). This transition zone in the north east portion of the 

Pasayten Wilderness is also where the hummock pattern ground is found. The shrub wetlands, 

typically represented by willow plant communities are important habitats for the sensitive Salix

species as well as many of the Carex species on the list. Geum rivale (purple avens) is an R-6 

Sensitive species that is also a wetland dependant found in open forested wetlands. The vast 

majority of the Sensitive plants identified in this analysis are dependent on wetland or habitats 

maintained by the water supplied by these wetlands (Appendix G).

The wetlands most impacted by pack and saddle stock outfitter-guide activities are those in 

close proximity to camps. Outfitters often let their stock loose graze to reduce impact to soil 

and vegetation that can be caused by corralling or tying stock for extended periods. Stock travel 

approximately two miles from camps, but generally stay closer. The amount of impacts

decreases as the distance from a camp increase because the stock disperse across larger areas. 

Concentrated impacts at campsites have the most impact on vegetation and wetlands, as stock 

containment increases barren core and habitat disturbance. Once stock are allowed to travel 

away from camps, the disturbances disperse to the point of inconsequential impacts. The 

distance where there is no impacts to vegetation and wetland habitats is generally about a 500 

foot radius from camps, however loose grazing stock do pass through wetlands on occasion. As 

discussed earlier, loose grazing stock tend to avoid areas with wet soil, such as wetlands. Any 

impacts, such as vegetation trampling, grazing, soil compaction, or plant morality from urine, to 

wetlands in loose grazing areas is dispersed, rather than concentrated because of the nature of 

the herding stock, therefore not interfering with the functioning of the wetland or causing 

unacceptable damage to wetland plants. Loose grazing areas are monitored, as described on 

page 2-27. 

Outfitter guide camp locations were given a 500 foot radius buffer in order to identify potential 

wetland habitats or Sensitive plant populations that may be affected by outfitter activities. The 

greater the distance the outfitter camps were from the wetlands, the smaller probability of the 

wetlands being disturbed. This also is used as a tool to compare the diversity and amount of 

wetland habitat in proximity to campsites, potential effects of stock use on wetland habitats, 

and Sensitive plant resources. It is not intended to infer stock use has occurred throughout the 

wetlands within the 500 foot buffer radius.

There are 86 acres of wetland identified within 500 foot radius of 35 outfitter camps, excluding 

open water wetland habitats, as R6 Sensitive and S&M plant species would not typically be 

associated with this type of habitat at higher elevations. This is 1% of all the wetlands in the 

analysis area. The rest of the wetlands are over 500 feet from established outfitter camps and 

receive little to no use by pack and saddle outfitters, therefore, impacts to them are negligible. 

Of the 35 camps, 25 are in the Pasayten Wilderness and comprise 73.9 acres within 500 foot 

radius of wetlands. An additional ten outfitter camps are in the Lake Chelan-Sawtooth 

Wilderness and comprise 12.1 acres within 500 foot radius of wetlands. The Beaver Creek 

Camp, Bald Mountain, and Sheep Mountain assigned sites have identified wetlands nearby. The 

two other assigned sites, Crow Lake and Whistler Camps, do not have mapped wetlands within 

500 feet of camp. Refer to Appendix I for a list of mapped wetlands within a 500 foot radius of 

campsites. 
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Standards and guidelines for the portions of the analysis area within the Pasayten and portions 

of the Lake Chelan-Sawtooth wilderness that is on the Methow Valley Ranger District state that 

“campsites should be located at least 200 feet slope distance from meadows, lakes, streams, 

and key interest areas.” Applying a 200 foot linear distance to the camps in wilderness shows 

that there are 64 campsites within 200 feet of meadows, lakes, streams, and key interest areas 

and 22 of those campsites are within 200 feet of wetlands. Twenty of these 22 campsites are in 

the Pasayten Wilderness and 2 campsites are within the Lake Chelan-Sawtooth Wilderness. 

Two of the 22 sites near wetland habitat also have a Sensitive plant population known to occur 

within 200’ of wetlands. These are Horseshoe Creek and Sheep Mountain camps, both have 

Carex heteroneura var epapillosa (different-nerve sedge) populations. This species appears to 

have tolerated the light level of grazing pressure at Horseshoe Creek. At Sheep Mountain the 

species is found in the highest concentrated use area within the campsite and has persisted in a 

camp that had been in use for over 50 years.

Not all the wetlands listed in Appendix H have been impacted by pack and saddle stock use. 

Stock use associated with these affected wetlands areas were typically small and isolated 

incidences. Because of the small scale of the disturbance, wetland ecosystem function across 

the analysis area has not being affected. The majority of wetlands are unaltered and most are 

not near trails or campsites and therefore receive little to no stock use. Since stock are allowed 

to loose graze, they may pass through wetlands to access upland grazing areas but do not linger. 

Some trails are created in these wetland habitats from stock movement. The compacted soil in 

these trails creates pathways for water flow to out of the very small portion of the wetland 

directly adjacent to the trail. This can affect wetland habitat by drying the soil and killing some 

vegetation in scattered pockets. The impact to individual wetlands is minor because there are 

not enough trails to drain entire wetlands. The overall impact to wetland habitat is 

inconsequential because such a small percentage of wetland habitat is involved. 

Special Status Species

Federally Listed Threatened and Endangered

There are no Federally-listed Howellia aquatilis (water howellia), Hackelia venusta (lesser showy 

stickseed), Sidalcea oregano var. calva (Wenatchee Mountains checker- mallow), or Spiranthes 

diluvialis (Ute lady's tresses) populations known to occur in the analysis area. None of these 

species were found during any of the surveys conducted for this project. There is no suitable 

habitat for any of these species known where outfitter activities are occurring.

R6 Special Status Species 

Given the size of the analysis area, sensitive plant surveys of every potential site of pack and 

saddle stock outfitter-guide activity was not practical. The analysis of the effects on sensitive 

plants was done by combining the data from sensitive plant surveys that have been completed, 

assessment of sensitive plant habitats known to occur in the analysis area, abundance of 

wetland habitat, and the likelihood of outfitter activities occurring in or near known sites or 

potential habitat. Sensitive species and their habitats are listed in Appendix J.

Survey and Manage Plant Species

Between the 1999 and 2003 inventory seasons, three Survey and Manage (S/M) species were 

located during pre-disturbance surveys. These include Schistostega pennata, Cudonia 
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monticola, and Gyromitra californica. Ramaria amyloide and Dermaticarpon meiophyllizum are 

known Survey and Manage sites from previous surveys. 

None of the Survey and Manage species listed above would be affected by outfitter guide 

activities, as they are outside of any use area.

Sensitive Plant Habitat for R6 Special Status and S/M Species

Of the 54 R6 Special Status and Survey and Manage plant populations found during surveys or 

that have potential habitat within the analysis area (see Appendix F), the Pasayten Wilderness, 

which includes both the Methow and Tonasket Ranger District portions, supports the greatest 

diversity of these species (37 species) followed by the North Cascades area (20 species). The 

greatest number of site locations is also associated with the Pasayten Wilderness, primarily 

because wetlands are in the highest concentration there and many of the sensitive species are 

wetland associates. The higher density of wetland habitat and more northern latitude provides 

habitat for a greater number of species more commonly associated with the boreal forest region 

to the north. A boreal forest region is defined as the forest areas of the northern North 

Temperate Zone, dominated by coniferous trees such as spruce, fir, and pine. These species are 

typically at the southern-most extent of their range. One example is glaucous gentian, an arctic 

tundra plant. It is at the southern-most extent of its range where it is found just south of the 

Canadian border in Washington and Montana. This species appears to be sensitive to the effects 

of warming temperatures and may prove to be an important species in gauging the health of 

other arctic plants that have found a niche in this area (Lesica and McCune 2004). In 

Washington, glaucous gentian is most abundant east of the Ashnola River in close proximity to 

the Canadian border. Only one site is known to occur west of the Ashnola River and all the 

known populations are within the Pasayten Wilderness. The state range is from just west of the 

Ashnola River east to Chopaka Mountain on Department of Natural Resources land.

A unique topographic feature that supports arctic tundra plant habitat is the pattern ground or 

hummock features which are most abundant in the northeast portion of the Pasayten, east of 

the Ashnola River. Glaucous gentian grows in moist subalpine and alpine environments that are 

regularly disrupted by frost heaving and frequently associated with hummock topography near 

or above timberline, typically above 7,000 feet in elevation. 

Glaucous gentian is apparently secure globally but is Imperiled in Washington and Critically 

Imperiled in Montana. It is considered Vulnerable in Alberta and Apparently Secure in Alaska 

and British Columbia. (Natureserve 2010). Over the next ten years, if global temperatures 

continue to warm, glaucous gentian populations will likely begin to show signs of decline, since 

studies have demonstrated its sensitivity to warming temperatures. This is not unexpected 

since it is an arctic tundra plant at the southern extent of its range. This may mean any further 

loss of individuals, populations or habitat could result in a need to reconsider changes in the 

Federal and State listings. 

For Survey and Manage species, the highest probability habitat and most of the known sites are 

found west of Washington Pass, in the North Cascades subunit of this analysis, where the 

habitat begins to transition into the wetter west side plant communities where mountain 

hemlock, Pacific silver fir, and western hemlock become dominant. 
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In a very general sense, the 54 species found during surveys can be classified by their 

associations with five types of habitat. These are wetland, riparian, and wet to mesic meadow 

habitats; talus and mountain top scree habitats; tree dwelling species; soil substrates; and open 

habitats and dry meadows. 

Wetland, Riparian and Wet to Mesic Meadow Habitats

Seventeen species (16 R6 Special Status Species and 1 S/M species) are associated with 

wetlands, riparian areas, and wet to mesic meadows. Dermatocarpon meiophyllizum (S/M) is an 

aquatic lichen found in streams and is included in with the riparian species. The 17 species 

typically associated with wetlands, riparian areas, and wet to mesic meadow habitats have the 

greatest overlap with outfitter and public pack and saddle stock. Populations and habitats for 

several of these species are within areas used by outfitters. 

The 17 species (16 R6 Special Status Species and 1 S/M species) are: Agrostis mertensii (northern 

bentgrass), Spiranthes porrifolia (Ute’s lady's tresses), Botrychium ascendens (trianglelobe 

moonwort), Carex magellanica spp. irrigua (poor sedge), Botrychium hesperium (western 

moonwort), Carex atrosquama (lesser blackscale sedge), Carex heteroneura var.epapillosa

(different-nerve sedge), Carex media (intermediate sedge), Gentiana glauca (glaucous gentian), 

Geum rivale (purple avens), Salix glauca ssp. glauca var. villosa (glaucous willow), Botrychium 

paradoxum (peculiar moonwort), Gentianella tenalla (Dane's dwarf gentian), Carex gynocrates 

(northern bog sedge), Sanicula marlandica (Maryland sanicle), Eriophorum viridicarinatum 

(green-keeled cottongrass), and Dermatocarpon meiophyllizum (S/M).

Of the R6 Special Status Species that occur within a 500 foot radius of outfitter guide campsites, 

four are found in the riparian, wetland and mesic to wet meadow habitats. These are: differentnerve sedge, glaucous gentian, green-keeled cottongrass, and poor sedge. The Horseshoe Creek 

and Sheep Mountain camps both have different-nerve sedge populations within a 200 foot 

linear distance that was applied to campsites in wilderness.

Talus and Mountain Top Scree Habitats

There are 12 R6 Special Status Species found in talus and mountain top scree habitats. These 

species are: Carex scripoidea var. scirpoidea (northern singlespike sedge), Cryptogramma stelleri

(fragile rockbrake), Draba aurea (golden draba), Draba cana (lance-leafed draba), Erigeron 

salishii (salish fleabane), Eritrichium nanum var. elongatum (pale alpine for-get-me-not), Luzula 

arcuata ssp. unalaschcensis (curved woodrush), Mimulus suksdorfii (Suksdorf’s mimulus), 

Parnassia kotzebuei (Kobzebue’s grass-of-Parnassus), Polemonium viscosum (skunk 

polemonium), Potentilla nivea (snow cinquefoil), and Saxifraga cernua (nodding saxifrage). 

Given the talus and mountain top scree habitats are not hospitable for camp locations and are 

typically very rocky sites that lack much forage opportunity, there is little likelihood these 

species or their habitats are being affected by outfitter activities.

Of the R6 Special Status Species that occur within a 500 foot radius of outfitter guide campsites, 

only three of these are found in the talus and mountain top scree habitats. These three are:

snow cinquefoil, northern singlespike sedge and skunk polemonium. 

Tree Canopy Habitats

The S/M moss species that can be found growing on trees or woody substrates (live and dead) 

is: Schistostega pennata(S/M). This species may be disturbed in association with wood 
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gathering activities. Implementation of current Forest Plan standards and guidelines outlined 

above in the Regulatory Framework section, pertaining to wood gathering and snag removal 

have reduced or eliminated the risk of loss to any of these species. 

None of these tree canopy habitat dependent species are known to occur within a 500 foot 

radius of any camp. 

Soil Substrate Habitats

There are three S/M species of fungi that are found on or in soil substrates. The fungi Cudonia 

monticola, Gyromitra californica and Ramaria amyloidea are found in association with wellrotted wood and duff on the forest floor. These fungi occur in forested habitats not suitable 

for grazing. None of these soil substrate habitat dependent species are known to occur within a 

500 foot radius of any camp. 

Open and Dry Meadow Habitats

There are two R6 Special Status Species typically associated with open habitats and dry 

meadows. They are: Carex proposita (Great Smoky Mountain sedge), and Pellaea brachyptera. 

These species are typically not found where stock have likely grazed or outfitted activities 

occurred.

R6 Special Status Species Plant Populations by Campsite

There are 19 campsites that have known populations of Sensitive R6 Special Status plants or 

potentially occupied habitat within a 500’ radius of a camp. All but two of them are in the 

Pasayten. Nine are located in a relatively small area east of the Ashnola River to Cathedral Peak 

and north of Andrews Pass. These are: Bald Mountain, Charlie Brown, Old Miller Camp, 

Pasayten Hilton, Beaver Creek, Beaver Creek Drop Camp, Bob Creek, Cathedral Camp, and 

Ptarmigan Creek. West of the Ashnola River are the Sheep Mountain and Timberwolf 1 camps. 

East of Cathedral Peak are Horseshoe Creek and Horseshoe Basin camps. All 13 of these camps 

are near the Canadian Border. In the southern half of the Pasayten and north of Harts Pass 

there are Silver Lake, Ferguson Lake, Drop Camps B and C campsites. Two camps, Bernice 3(E) 

and Fish Creek Base Camp, are on the Chelan side of the Lake Chelan-Sawtooth Wilderness. 

Assigned sites receive the greatest amount of use on an annual basis, since tents are set up and 

limited supplies are kept at the site season long. Current assigned sites are Bald Mountain, 

Beaver Creek and Sheep Mountain. In addition to providing the full-service camping 

experience, these camps are used as base camps for outfitters to work out of after dropping 

clients in the area. These sites have the greatest amount of ground disturbance associated with 

stock containment, grazing, firewood gathering, and trampling of vegetation in and around the 

camps by both stock and humans.

These camps are set up for the client’s needs and are situated for handling and turning stock out 

to loose graze away from camp. The better distribution of stock grazing that occurs away from 

the assigned camps helped to reduce the potential for over grazing.

For this analysis, the non-assigned full-service camps are those camps where overnight use 

occurred with outfitter stock. They are the sites associated with the second greatest potential 

for disturbance, compared to assigned sites because full-service camps typically have larger 
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parties compared to drop camps, and the stock are kept with the party for the duration of the 

trip.

A substantial amount of pack and saddle stock outfitter-guide activity had been during the fall 

hunting season when soils are dry and vegetation has gone dormant for the season. Fall use had 

the least potential to affect plant recovery during the following growing year.

Appendix K includes a list of camps used by outfitter-guides that are within 500 feet of sensitive 

plants. A description of each camp follows.

Bald Mountain Camp – Assigned Site, Full-service, drop

The Bald Mountain assigned site is located near 5 acres of emergent wetland that is 

temporarily or seasonally flooded. The sedge dominated wetlands are located on a 

bench approximately 1⁄4 of a mile above the camp to the south and west. To the south, 

the horses access drinking water from the camp in a small stream that feeds the sedge 

wetland on the other side. Horses cross there and head through the wetland and up the 

hill. The different-nerve sedge site is located to the west, and the habitat for this 

species borders the wet sedge meadow. This stringer of wetlands is located along the 

travel route the pack stock use to reach their main loose grazing area to the west.

An R6 Sensitive population of different-nerve sedge near the Bald Mountain camp has 

been part of the occasionally used grazing area associated with this full-service assigned 

campsite. This area has not been the primary graze area but one that has been used for 

short visits with a few animals or when outfitters have chosen to keep the animals close 

and do not turn them out onto the open upland area on the west side of Bald Mountain 

overnight. No grazing was observed in this wet sedge meadow in 2011 or 2012.

When stock are turned out onto Bald Mountain to graze they travel through the above 

mentioned wetlands on the old boundary trail to access the drier Danthonia intermedia 

(timber oatgrass) and Festuca viridula (green fescue) meadow habitat up on the 

northwest flank of Bald Mountain where the majority of the suitable graze is 

located. The trail drainage structures are no longer being maintained and stock have 

created multiple braided trails in association with this old trail as they pick their way 

through the wet areas and down timber. In addition, this old trail has been used by 

other outfitters, hikers, and private parties with stock. It is a known short cut across to 

the Ashnola River and into the Sheep Mountain area. Springs along the north slope of 

Bald Mountain associated with the trail have been sheared from hoof action and traffic 

along the trail allowing for a more rapid dewatering of spring and slope erosion. 

Glaucous gentian is found on the hummocks above these springs. Horses travel through 

the area and trample this population and the perennially moist springs which results in a 

loss of viability to this specific population. However, there are many other unaffected 

populations that insure species viability. Hoof tracks often sink into the soil 4” to 6” and 

the spring flow is being diverted down the old boundary trail causing soil erosion. 

Once pack and saddle stock reach the upland grazing area, there is better forage 

opportunities so they disperse. Dispersed loose grazing reduces long term ecosystem 

impacts. Although some species loss may occur to different-nerve sedge and glaucous 
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gentian, there are many other unaffected populations that ensure species 

viability. Detailed information taken at this site indicates the area is currently in good 

ecological condition. Past use has not resulted in any long-term modification of the 

natural plant communities. 

The description of the Bald Mountain camp and impacts to nearby wetlands were 

updated in this FEIS using new monitoring information. The DEIS stated that the camp 

was “problematic”. Further analysis of the wetland near the camp determined that the 

impacts to the wetland habitat and species there are in fact inconsequential to overall 

wetland habitat and species viability because the vast majority of habitat is unaffected 

by outfitter-guide activities.

Beaver Creek Camp – Full-service, Assigned Site

Beaver Creek assigned site has two R6 Sensitive plants within 500 feet of camp. These 

are: glaucous gentian and different-nerve sedge. This camp also is in association with 

the largest amount of designated wetland. There are 9.7 acres of willow wetland that 

are temporarily or seasonally flooded within 500 feet of the campsite. Most of this 

wetland area is directly west of the camp. Horses do not graze in this wetland but they 

travel through it to access grazing areas above and to the north. Stock have been well 

dispersed when travelling through this area and there is no evidence that long-term 

modification of the wetland habitat has been occurring. To the north of the campsite 

there are some small open water wetlands surrounded by hummocks that support

glaucous gentian. This is a relatively large area in good ecological condition because 

stock are allowed to loose graze. Horses travel to and from night grazing areas just to 

the northwest of this hummock ground and wetlands. There is little evidence, if any, 

that horses spend time in this area. Current stock use has not altered the integrity of 

this population or habitat. 

Glaucous gentian is also found to the east behind the campsite, in small openings 

between the trees and often in association with depressions that appear to be old 

remnant hummocks that have possibly been destroyed from past trampling or grazing. 

The trail to Border Ridge goes through this area. Current stock use and human use in 

the area may have resulted in loss of a few individuals. Loss of individuals would not 

likely result in a loss of population or species viability because of the species wide 

distribution in the analysis area and the relatively small amount of total area being 

disturbed.

Just above this Salix planifolia (diamondleaf willow) dominated community, vegetation 

grades into a green fescue meadow with inclusions of timber oatgrass and pockets of 

moist forbs with an abundance of Trollius (globeflower) and Caltha (marsh marigold) 

species. Within the moist forb inclusions R6 Special Status Species, different-nerve 

sedge, is found. Stock use of this area has been light and there is no detectible evidence 

that the level of use is threatening the viability of these Sensitive plants or their habitat.

On the south side of the camp, within 100 feet of the tent site, there is a small wetland 

surrounded by hummocks. Additional field data was gathered after the DEIS was 

published to assess this area. The DEIS incorrectly stated that C. saxatillis is present in 

this wetland. The updated field data showed that the outfitted stock do not regularly 
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mingle around the camp in this wetland. The area has been grazed by commercial and 

recreational livestock since the early 1990s, and despite this, the sensitive plant 

populations are still viable and hummock structures are still functioning. The pack and 

saddle stock outfitter guide activities are not impacting the species viability of Gentiana 

glauca nor causing unacceptable impacts to the hummocks. The stock are loose grazed 

around this camp, and therefore do not stay in the wetland or hummock area because 

their preferred forage species do not grow there.

Beaver Creek Camp has been used by outfitters for over 15 years. Despite the ecological 

diversity and complexity of sensitive plant and wetland issues at this camp, impacts to 

vegetation has been moderate and most of the area is in fair to good ecological 

condition. Most of the damage has been occurring close to camp, such as in the 100 

feet from the south side of the camp as described in the paragraph above. Aside from 

this spot, stock are well-dispersed from camp, this contributes to the moderate to low 

trampling damaging to the surrounding vegetation and wetlands. 

Beaver Creek Drop Camp – Drop Camp

Beaver Creek Drop has one R6 Sensitive species associated with the camp; the species, 

green-keeled cottongrass, has suitable habitat within 500 feet. This species has not 

been documented in the actual camp area. There is no suitable habitat for green-keeled 

cottongrass in the immediate vicinity of camp. Given this camp is used primarily as a 

drop camp during the hunting season and stock do not reside at the site for any length 

of time, it is unlikely that green-keeled cottongrass is being affected by current use. 

Bob Creek, Cathedral Camp, Bernice 3(E), Drop Camp B, and Drop Camp C – Drop Camps

Bernice 3(E), Bob Creek, and Cathedral camps are used primarily during the fall hunt 

season as drop camps. No effect to wetlands or sensitive plants has occurred from 

current use at these camps. Drop camps B and C have been used as drop camps, but 

outfitter stock have not been kept in camp or turned out to graze in any of these areas, 

so no identifiable alteration of sensitive plant resources or wetland habitats has 

occurred.

Charlie Brown and Pasayten Hilton – Drop Camps

Charlie Brown and Pasayten Hilton camps are both very wet sites, but there is little 

impact to vegetation because they are drop camps. Stock are not kept overnight at 

drop camps, so grazing is not an issue. Both sites have poor sedge in close proximity. 

These sites are in locations that would more likely be damaged by humans walking along 

the edge of waterways and boggy pond margins to gather water for camp use or 

washing. This is the situation at Charlie Brown. This site is also popular with private 

parties season long. The situation is similar at Pasayten Hilton campsite, which is also 

popular with private parties. Neither of these drop camps has been used often by the 

outfitters nor have they used them overnight. The poor sedge associated with these 

two camps are secure at this time and outfitter-guide activities are not affecting 

population viability.

Of the two camps, Charlie Brown is the most popular with private parties. The grazing 

area below the camp is in a moist meadow where there are historic records of a 

population of a non R6 Sensitive species, Botrychium simplex. During inventory efforts 
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in 2001 Botrychiums were found in the area but identification was not confirmed. There 

were no samples taken to confirm identity. A photo was taken and identification could 

not be determined. Suitable habitat for different-nerve sedge is identified in the grazing 

area associated with this camp. 

Ferguson Lake, Silver Lake, and Ptarmigan Creek – Ferguson Lake and Ptarmigan are 

past drop Camps; Silver Lake is a progressive camp.

Of the other camps listed in Appendix H, Ferguson Lake, Silver Lake, and Ptarmigan 

Creek do not have suitable habitat in any of the camp use areas. Use in these camps has 

not had any effect on the Sensitive species thought to be in the area because the 

habitats for R6 Sensitive species are far enough from the camps to be affected by use. 

Silver Lake is not well suited to stock use due to the wet and boggy nature of the site 

late into the season. Due to the lack of suitable Sensitive species habitat, the type of 

camp use and the unsuitable conditions for stock use at Sliver Lake outfitter use has not 

likely had any effect on Sensitive plant or wetland resources at these camps.

Old Miller Camp – Drop Camp

The different-nerve sedge populations near Old Miller Camp are within a nearby moist 

meadow. The camp is used as a drop camp by the pack and saddle outfitter guides. 

Outfitters have not affected the population since stock are not grazed at the camp. 

Sheep Mountain – Assigned Site

Sheep Mountain is located in the vicinity of a confirmed population of different-nerve 

sedge. There are 0.3 acres of willow wetland that is temporarily or seasonally flooded 

located across the creek from camp. There has been no stock or human use associated 

with this willow wetland. 

Field inspections (see the analysis file for field notes taken at the site) at Sheep 

Mountain camp indicate that the different-nerve sedge population south of the camp is 

in a high traffic area this has been actively grazed. The population is between the camp 

site and water source for both the stock and camp. This population is in an area that 

has been regularly grazed as part of this camp for at least 60 years. There is still 

adequate vegetative cover to protect soil resources, however, the community 

composition is altered compared to other similar sites and is now dominated by non R6 

Sensitive species, Phleum alpinum (alpine timothy) with an abundance of low growing 

forbs such as Antennaria (pussy toes), Fragaria (strawberry), and Potentilla (cinquefoil) 

species. The individual populations of the R6 Sensitive species, different-nerve sedge, 

are struggling in this area due to the high use it has been receiving to the point that they 

are at risk of loss. However, despite rarity of this species further south, it appears to be 

rather widespread throughout the Sheep Mountain and Spanish Camp areas. 

These changes in community composition have occurred long before pack and saddle 

outfitter guides used this camp. Past sheep grazing in this area contributed to a 

majority of the shift in plant composition. Compared to past sheep grazing activities, 

vegetative recover is on an upward trend.
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There is another wet meadow nearby that stock travel through to reach from night 

grazing areas. Other than the trail going through this area, the site has not been grazed 

or seen any other disturbance. 

Timberwolf 1 –Drop Camp

Timberwolf 1 camp is surrounded to the north and west by wet to mesic willow and 

sedge dominated meadows where the R6 Sensitive species, different-nerve sedge, is 

located. These are the areas of concern. This camp has only been used as a drop camp 

in the past so stock have not resided there. There is some evidence of stock use in the 

area from private parties, however, the campsite received little use overall and the 

pasture area was in moderate to good ecological condition. This population is likely 

secure given the current low volume of use by the public and occasional use as a drop 

camp site by outfitters. 

Horseshoe Basin and Horseshoe Creek – Overnight Camp

Horseshoe Basin and Horseshoe Creek campsites both support moist meadow habitats 

where R6 Sensitive species, different-nerve sedge, is suspected to occur. The species 

has not been confirmed within the 500 foot buffer area around these camps. Horseshoe 

Creek also includes emergent wetland habitat. At both sites, outfitters overnight with 

stock. These sites have been used infrequently by outfitters because of remote access 

and location relative to the other campsites which are accessible from within the 

Methow River drainage. Grazing behavior and preferences of stock in this area are likely 

similar to those seen in Spanish Camp. 

Fish Creek Base Camp – Base Camp

At Fish Creek Base Camp stock are kept in the corrals and feed is brought in on the 

barge. Stock have not been turned out to graze and disturbance to Special Status 

Species would be from trampling, mainly by humans. 

Crow Lake – Assigned Site, drop, full-service

Crow Lake is an assigned site that is not in close proximity (500’) of any known wetlands 

or Sensitive plant populations. It is located in a small grove of Larix lyalii (larch) in the 

overstory with Vaccinium scoparium (grouse whortleberry) and Luzula hitchockii

(Hitchcock's smooth woodrush) as the dominant understory species. Once out of the 

barren core area of camp, stock disperse well. A population of R6 Sensitive species, 

different-nerve sedge, was found in a narrow stringer meadow dominated by 

globeflower and marsh marigold within the area stock was grazing north of camp. The 

grazing by stock showed minimal trampling in August when the inventory was made 

(see field notes in the analysis file). This demonstrates resiliency of the moist forb 

meadow communities. This community shows only mild signs of reduction in cover of 

the key species such as green fescue, American globeflower , and white marshmarigold. 

The steep south slope facing into Gabril Creek is a green fescue community. There are 

still signs of terracing across the slope from past sheep grazing that contribute to its 

overall condition. It does not appear that stock are using this area or the stinger of wet 

tall forb meadows, and springs associated with the mature Picea engelmannii

(Engelmann spruce) below. The surrounding area showed only minor amounts of 

trampling damage to communities and most areas were in at least fair or good 
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condition, with the except of the steep south slope noted above. Past outfitter camp 

activities at this site only appear to be having minor effects to botanical resources 

(Kovalchik 2003).

Whistler Camp – Assigned Site

Whistler Camp is often approved for extended use. This was an old sheep camp during 

the height of past sheep grazing. The landscape is wide open and gentle. There are no 

known sensitive plant populations or wetlands within the 500’ radius of camp. Past 

records (see field notes in the analysis file), indicate overgrazing by sheep changed much 

of the dominant native species in the community and has been replaced by short 

herbaceous species such as Antenaria lanata (woolly pussytoe) and cinquefoil. A short 

tufted grass is the dominant grass species, but site records do not provide a species 

name. 

Whistler Camp is in an area with low to moderate potential for post disturbance 

recovery. Dominance of grouse whortleberry in the area would indicate the resiliency 

to be low while a dominance of moister, herbaceous plant species would indicate a 

higher resiliency. Past grazing practices and use as a sheep camp has left this area 

highly altered. Since outfitter guide activities are contributing only a minimal amount of 

disturbance compared to past sheep grazing activities, vegetation is being allowed to 

recover. 

Natural Plant Succession

In the late 1800’s large bands of sheep first were first introduced into the area later designated 

as the Lake Chelan Sawtooth and Pasayten Wildernesses, Sawtooth Backcountry, up the 

Methow Drainage and into the Harts Pass area. Past commercial grazing numbers appear to 

have peaked between 1925 and 1950 for both cattle and sheep. There was a general trend to 

shift from sheep to cattle in the 1940’s which changed the dynamics where overgrazing was 

occurring. Overgrazing shifted from bedding areas associated with sheep grazing to increased 

use in riparian areas with cattle. Vegetation began to recover when switched from sheep to 

cattle grazing. Past grazing practices likely delayed plant recovery in these fire areas since there 

were few grazing utilization standards in place.

Past livestock grazing resulted in changes in natural plant succession over much of the Pasayten 

and Lake Chelan-Sawtooth Wildernesses. Large numbers of pack and saddle stock used by 

outfitter-guides and members of the public prior to the current Forest Plans also affected this 

succession. Elimination of commercial grazing and establishment of party size controls in 

wilderness as part of the Forest Plans allowed the areas to begin to recover; the overall 

ecological condition has been improving ever since (see survey notes in the analysis file). Pack 

and saddle stock use in popular areas in the recent past has been slowing the recovery in and 

around campsites, however, the trend is still upward (see survey notes in the analysis file). The 

use in the recent past has been consistent with Forest Plan standards and guidelines that speak 

to natural plant succession. Loose grazing in these areas contributes to light intensity and low 

impacts to vegetation which allows for recovery which complies with Forest Plan standard and 

guide 15B-22A.
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In general, plant communities showing the greatest resilience and over-winter recovery are in 

the warmer, moister environments with longer growing seasons and the greatest composition 

of grasses. Those showing the least resiliency are those in colder environments subject to 

frequent frost and are typically low shrub dominated communities. At the lower trampling 

intensities (less than 100 passes/year) vegetation loss did not increase substantially after the 

first season. The effect of multiple seasons of use appears to be more important than the 

number of days within the season trampling occurred. Even in the most resilient communities, 

the greater the number of years of use the less resilient is the community (Cole 1987). 

The two primary plant communities associated with the majority of grazing throughout the 

analysis area are the green fescue and timber oatgrass meadows. Green fescue meadows are 

more often associated with mid-slopes or flats and concave micro-topography on upper slopes 

where finer textured soils accumulate and usually at lower elevations than the timber oat grass 

meadow type. Timber oatgrass meadows are typically found on the shallow coarser textured 

soils on the upper slopes and ridges, typically at higher elevations than the green fescue 

meadow type.

Timber oatgrass meadows are slower to recover from past overgrazing due to the harsher sites 

inhabited. Overgrazing of green fescue meadows was common during the height of sheep 

grazing. In one 50 year study in the Wallow Mountains, recovery of overgrazed green fescue 

meadows, where soils were intact, required at least 20 years. On moister sites, with intact soils, 

green fescue was able to re-colonize sites within 13 to 14 years. Where loss of most of the 

topsoil had occurred forming rocky erosion pavement or remaining soils were rocky, well 

drained, and shallow after 50 years the plant cover was sparse (10%-30%) with little green 

fescue in the composition (Reid et al. 1991). 

Sheep and cattle grazing had been eliminated over much of the analysis area in the mid-1900’s 

for sheep and 15 years for cattle. Even the most resilient sites likely have not yet fully 

recovered. The amount of stock grazing associated with the outfitters and private parties has 

been in localized, small areas relative to the extent of past livestock grazing, and not affecting 

natural plant succession. The end result is an overall trend toward improvement in the current 

ecological condition of plant resources.

In the Pasayten, most of the disturbance is associated with pack and saddle outfitter guide stock 

traveling through wet areas to reach preferred grazing sites. Most of the grazing is occurring in 

timber oatgrass, green fescue and to a lesser extent mesic forb meadows. Stock use was well 

distributed at the grazing sites inventoried and they were typically in fair to good ecological 

condition (Kovalchik 2002 and 2003). This is attributed in part to the higher precipitation levels 

and available moister associated with the Pasayten and the large expansive gentle open rolling 

meadow terrain, which allows for better stock distribution.

In the Lake Chelan-Sawtooth Wilderness and Sawtooth Backcountry, environments are drier and 

less resilient to grazing pressure or trampling. Terrain is steeper and open grazing ground is less 

expansive or abundant. Green fescue dominated meadows provide the greatest forage base. 

Loss of green fescue is evident in Mid Oval SW horse camp on the Methow side of the Sawtooth 

(Ohlson, personal observation). As a result of the sheep herder camps, the productive green 

fescue is being replaced by less palatable species such as pussy toes and cinquefoil by past and 

recent past use. Portions of this area consist of alpine heather communities which are generally 
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intolerant of even moderate levels of trampling. Impacts to these communities are often long 

lasting.

Wildfires are a natural part of the successional dynamics of the plant communities. During the 

2006 Tripod fire, 67% of this subunit burned over. The camps in the Bear/Ramsey/Volstead subsection (outside of the Wilderness boundary), are used as drop camps and there is no impact 

from grazing livestock. 

In the 2001 Rex Creek fire, along the north shore of Lake Chelan, 10 campsites were identified 

within the fire perimeter that was within the Lake Chelan-Sawtooth Wilderness. In the 2003 

Farewell/Needles fire, four campsites were burned over in the Andrews Creek drainage, 

Pasayten Wilderness subunit and one in Middle Fork Methow drainage, North Cascades subunit. 

The fires in 2006 burned over three campsites within the Pasayten Wilderness subunit. One, 

Horseshoe Creek camp, has suitable habitat for R6 Sensitive species, different-nerve sedge. This 

species is associated with wet rich forb meadows and both this species and its habitat are 

expected to respond favorably to fire disturbance.

Figure 3.7-1: Fire History Highlights from circa 1900 thru 2006.

Analysis Area Subunits

1917 

thru 

1919

1926 1929 1970

1984 

thru 

1986

Since

2000

Total Ac 

Burned 

since 

1900

Bear/Ramsey/Volsted 6,951 2,359 509 339 38,648 49,387

Sawtooth Backcountry 5,265 3,530 3,638 12,870

Middle Methow 686 1,206 62 1 4,061

North Cascades 246 169 96 690 29,745 38,371

Pasayten Wilderness 13,153 19,286 47,708 605 3,199 131,451 250,413

Sawtooth Wilderness 169 2,930 1,885 603 4,522 36,107 49,070

ENVIRONMENTAL CONSEQUENCES

Direct and Indirect Effects 

Alternative 1

There would be no pack and saddle stock outfitters in the analysis area with implementation of 

this alternative. This would result in a 15% reduction in the expected number of pack and 

saddle stock use across the area. The remaining non-outfitted pack and saddle stock use by the 

general public would continue to trample vegetation in and around the campsites. Many camps 

with barren core areas and number of damaged trees exceeding standards and guidelines would 

continue to exist and be used by the general public. The disturbance at continually used camps 

would continue to a slightly lesser degree. There would be no assigned sites to pack and saddle 

outfitter-guides. 

Wetlands

Most of the existing campsites would continue to be used by private pack and saddle stock 

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

continue to be used by the general public. As a result, the impacts to nearby wetlands would 
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continue, but the overall 15% reduction in the number of pack and saddle stock would also 

reduce the amount of vegetation trampling, selective grazing, and soil damage. Damage in 

some wetlands not being used may begin to recover. Approximately 0.01% of the wetland 

habitats in the analysis area that are within a 500 foot buffer of campsites would continue to be 

impacted by private pack and saddle stock use. The remaining 99% of the wetlands would 

remain in good ecological condition or would continue to recover from effects of past 

commercial livestock grazing. 

Federally Listed Threatened and Endangered

There are no Federally listed water howellia, lesser showy stickseed, Wenatchee Mountains 

checker- mallow, or Ute lady's tresses populations known to occur in the analysis area. This 

alternative would have “no effect” on any of these species or their habitats.

R6 Special Status Species

Pack and saddle stock outfitter guides would have no impacts on R6 Special Status Species. 

Non-outfitted pack and saddle stock may continue to affect some sensitive plant species by 

trampling and a loss of some populations or individuals may occur where species are in close 

proximity to established camps and use patterns are known to overlap habitat. Overall, there 

would be less risk of damage than is currently occurring due to the decreased numbers of 

animals. These camps and associated species are described in Appendix K. The species that 

may be affected are: different-nerve sedge, poor sedge and glaucous gentian. 

Where different-nerve sedge and glaucous gentian occur, populations are widely dispersed but 

concentrated in a small geographical area. Loss of individuals, where non-outfitted use overlaps 

occupied habitat, would not likely result in a loss of population or species viability because of 

the species wide distribution and the relatively small amount of habitat being affected

R6 Sensitive species, Poor sedge, is a riparian and wetland species and may be affected by 

private stock trailing through wetland habitats. Since private use is unregulated, use mat not 

comply with Forest Plan standards and guides. 

Of the 54 R6 Special Status Species and Survey and Manage plant species found during surveys 

or that have potential habitat within the analysis area, and their nearly 360 populations that 

occur within the analysis boundary, the risk to these species is low. This is due to the small 

amount of area being impacted by private use relative to the large amount of area in the 

Wilderness where sensitive and Survey and Manage species and their habitats are not impacted. 

There is no outfitter guide use associated with this alternative. This alternative would not result 

in a trend toward further listing of any species considered. 

Natural Plant Succession

There would be less overall grazing pressure on plant communities due to the reduced number 

of stock. Except for the assigned Beaver Creek, Bald Mountain, Whistler Camp, Sheep 

Mountain, and Crow Lake camps, campsite use by stock would change very little. The general 

public may shift part of their use to the assigned sites since these sites would not be occupied by 

outfitters. Private stock users are less likely to turn their animals out to graze any distance from 

camp, which may result in smaller isolated and concentrated grazing areas close to the 

campsites that are no longer being used as assigned sites for outfitted use. Some private parties 

use electric fencing and staking, in addition to highlines to keep stock close to camp. This results 
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in more concentrated disturbance to vegetation around camps and may result in a shift of 

grazing use associated with some camps. It is the timing and concentration of use on a given 

piece of ground that drives recovery more than the overall number of animals using an area. 

And since private parties are less likely to loose graze their animals, the shift in animal use 

occurring closer to camps would likely result in isolated overgrazing near these campsites. Use 

patterns at these camps were established decades ago, often in association with past 

commercial livestock grazing, so much of the plant community alteration has already occurred. 

With overall fewer stock numbers, plant communities would continue to recover throughout the 

analysis area. 

The rate of recovery would be dependent on the soil condition and vegetative community 

involved. Where non-outfitted associated grazing is occurring in moist, forb rich meadows, the 

risk of soil displacement or compaction is increased. This would create isolated areas with slow 

post-grazing recovery. However, these communities are the most resilient to trampling and are 

expected to recover within a growing season following most types of use. Grass dominated 

meadow systems will be intermediate in post-grazing recovery if excessively trampled or 

overgrazed, but would be expected to recovery sufficiently if the excessive use is not recurring 

annually. Low shrub dominated communities are not expected to recover rapidly from human 

or stock use and one season of use can require decades for an area to recover. Past use has 

already altered these communities; continued use will not affect the overall recovery rate in 

assigned camps.

Hummocks

The Beaver Creek camp would remain open for public use. If the general public shifts part of 

their use to assigned camps, such as Beaver Creek, public users are less likely to turn their 

animals out to graze any distance from camp, which may result in smaller isolated and 

concentrated grazing areas close to the campsites. The extensive, intact hummock community 

to the north of camp would become vulnerable to trampling since private users are more likely 

to keep stock close to camp , versus loose grazing used by outfitters. Visitors may try to water 

their stock in the small open water ponds associated with the hummocks near camp. The area 

around the small hummock community near the existing camp would be used by private parties 

and the effects to this little wetland would not change. 

The Bald Mountain camp would be open to public use. Non-outfitted stock would likely be kept 

closer in to camp increasing the grazing pressure in the wet meadows near camp where the R6 

Sensitive species, different-nerve sedge, is found. However, there would likely be reduced 

trampling of the glaucous gentian ( R6 Sensitive) site associated with the hummocks and spring 

seep that the past permitted outfitter stock traveled through to access their night graze on Bald 

Mountain As a result, some recovery of this area would be expected with the removal of 

outfitter stock use. Loss of individuals, where camp use overlaps occupied habitat, would not 

likely result in a loss of population or species viability because of the species wide distribution in 

the analysis area and the relatively small amount of total area being used by outfitters.

Since the majority of the hummock patterned ground is beyond any area recently used by 

outfitters, the change in the condition of this unique pattern ground would be insignificant 

relative to the area that is currently unaffected by activities in the Pasayten Wilderness. 
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Effects Common to Alternatives 2, 3, and 4

Federally Listed Threatened and Endangered and R6 Special Status Species

There are no Federally listed water howellia, lesser showy stickseed, Wenatchee Mountains 

checker- mallow, or Ute lady's tresses populations known to occur in the analysis area. 

Alternatives 2,3 and 4 would have “no effect” on any of these species or their habitats.

R6 Special Status Species

Poor sedge is a riparian and wetland species. Where these species occur, the Standards and 

Guidelines in the Okanogan and Wenatchee Forest Plans for Aquatic Resources (see Aquatic 

Resources 3.1) are in place regulating activities in order to minimize disturbance in these 

sensitive wetland habitats and any sensitive species would also benefit from these regulations. 

Outfitter pack and saddle stock may affect some R6 Sensitive plant species by trampling and a 

loss of some populations or individuals may occur where species are in close proximity to 

established camps and use patterns are known to overlap habitat. Currently, there is less risk of 

population loss compared to the past commercial livestock grazing era, and the sensitive plant 

resources as a whole would continue to improve under these alternatives. The decreased 

numbers of animals and the small isolated areas where stock use occurs would minimize or 

eliminate risk of population loss or loss of species viability. Implementation of mitigation 

measures in Chapter 2 would further ensure species viability is not compromised across the 

analysis area. 

1c states that outfitters would not be allowed to use more than the specified amount of 

barren core, and that Camp Management Plans would be developed for these sites with 

the specific area of allowed use identified in the plan. This mitigation would ensure that 

outfitters don’t increase the amount of disturbance in the camps and holds outfitters 

accountable for their actions. 

4 speaks to the rules and regulations that outfitters must follow, these rules and 

regulations help ensure that other mitigations in Chapter 2 would protect sensitive 

plants and their habitats. 

8d would prohibit overnight picketing of stock in subalpine meadows, which would be 

effective in protecting sensitive plant habitats from stock use. 

8e and g would limit outfitter-guide stock grazing to suitable grazing areas, and require 

outfitters to pack in all necessary feed when range conditions do not allow loose 

grazing. These mitigations would be effective at avoiding overgrazing in areas where 

range or vegetation conditions cannot support livestock grazing.

10a would be effective at avoiding damage to vegetation that could be caused by 

unapproved trail maintenance, cutting green trees or other live vegetation, or trampling 

vegetation beyond those impacts likely to recover within one growing season.

10c would be somewhat effective at minimizing impacts to wetlands and wet meadows 

as stock travel between campsites and grazing areas. Concentrating stock on a 

minimum number of trails through these areas, damage to soil and vegetation would be 

reduced.

In addition, monitoring (see Chapter 2 for a more detailed information) of assigned sites as part

of special use permit administration would ensure that use either maintains or increase the 

ecological integrity of the area. This would be accomplished by monitoring a representative 
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sample of outfitter-guide camps seasonally for compliance with the terms of the permit, 

operating plan, and applicable laws and regulations. The filed inspection forms used to monitor 

include seven items, one of which addresses resource protection. Assigned sites are the most 

heavily used sites; information gained from monitoring these sites would be of value for 

predicting ecological trends at similar sites in the analysis area.

Natural Plant Succession

The overall ecological recovery of the plant resources within the analysis area is expected to 

improve with the implementation of any of the action alternatives. This is because past 

commercial livestock use has had a substantially greater effect on the existing plant community 

composition and recovery than the level of recreational and outfitter stock has or would have in 

the future. 

Plant communities would continue to recover throughout the analysis area because of reduced 

stock use compared to historic use. The pattern of use at these camps was established decades 

ago often in association with past commercial livestock grazing, so much of the plant community 

alteration has already occurred. Use within the campsites would continue to result in some 

additional disturbance, but this use is small relative to the size of the analysis area. Monitoring 

(see Chapter 2 for a more detailed information) of assigned sites as part of special use permit 

administration would ensure that use either maintains or increase the ecological integrity of the 

area. This would be accomplished by monitoring a representative sample of outfitter-guide 

camps seasonally for compliance with the terms of the permit, operating plan, and applicable 

laws and regulations. The field inspection forms used to monitor include seven items, one of 

which addresses resource protection. Assigned sites are the most heavily used sites; 

information gained from monitoring these sites would be of value for predicting ecological 

trends at similar sites in the analysis area. In addition, limiting the transport of noxious weeds 

through awareness and camp surveillance would also ensure vegetation recovery.

The rate of recovery would be dependent on the soil condition and vegetative community 

involved. Recent past use in moist forb rich meadow communities are the most resilient to 

trampling and are expected to recover within a growing season following most types of use. 

Grass dominated meadow systems would be intermediate in post-grazing recovery if trampled 

or overgrazed, but would be expected to recover sufficiently if excessive use is not recurring 

annually. Low shrub dominated communities are not expected to recover rapidly from human 

or stock use and one season of use can require decades for an area to recover. Use patterns at 

these camps were established decades ago, often in association with past commercial livestock 

grazing, so much of the plant community alteration has already occurred.

Forest Plan use standards would continue to regulate activities that maintain or enhance plant 

community recovery. Alternatives 2, 3, and 4 are complying with Forest Plan standard and 

guideline 15B-22A which addresses modification of natural plant succession and recovery. 

Outfitter pack and saddle stock grazing in and around campsites would not result in further 

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

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

the public.
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Alternative 2

In Alternative 2 there would be 4,620 service days available for use by permitted outfitters. The 

party size would continue to be 12 people and 18 head of stock. There would be five assigned 

sites (Sheep Mountain, Beaver Creek, Bald Mountain, Crow Lake, and Whistler Camp) for fullservice trips and five sites near trailheads for use as base camps (Andrews Creek, Billygoat, Slate 

Creek, Fish Creek, and Crater Creek). Additional sites could be assigned in the future following 

the mitigation measure number 1.g in Chapter 2. There are no new campsites, trails, or other 

ground disturbing activities permitted in this alternative. If an assigned site has to be closed to 

protect resources, additional site may be designated and approved by the Forest Service. 

There are two Forest Plan amendments associated with this alternative. One amendment 

would allow pack and saddle stock outfitter camps to use up to 5,250 square feet of barren core 

in camps where the existing amount exceeds that level. All outfitters would be required to use 

the same 5,250 square feet on successive trips, allowing the remaining barren core the potential 

to recover. The other amendment would allow pack and saddle stock outfitter-guides to use 

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

Pasayten and Lake Chelan-Sawtooth wilderness areas to avoid degradation of wilderness 

character and resources.

The assigned sites would result in monitoring and regulating outfitter activities in regularly used 

sites. These sites are used by outfitters already, and would not be open for the general public. 

This would allow better management opportunities for ensuring ongoing resolution of resource 

issues. These sites would continue to receive the highest levels of use of the outfitter camps. As 

stated above, this alternative would amend Forest Plans; camps that are smaller than 5,250 

square feet of barren core would remain at their current size. Outfitters would not be 

permitted to create additional barren core. At assigned sites, the amount of barren core would 

be reduced over time, since they would be closed to use by the general public and barren core 

would be limited to 5,250 square feet within these larger sites, which would allow recovery to 

begin in the area not permitted for use by pack and saddle outfitter-guides. At all other camps 

used by outfitter, the amount of barren core the outfitters could use would be limited to 5,250 

square feet, but continued use by the general public would likely perpetuate the existing 

amount of barren core.

The mitigation measures in Chapter 2 would also prohibit the outfitters from creating new travel 

routes (10.c), establishing new camps (1.g), increasing the amount of bare mineral soil in 

established camps (1.e), and exposing roots on any more trees at existing campsites (1.f). 

Measures 8 a- j would minimize impacts to vegetation from grazing. These would be effective 

since they would be part of the operating plans for the outfitters, so compliance would be 

required. Outfitter-guides are required under their permit to comply with the terms and 

conditions of their permit, including adherence to their operating plan. Outfitters who do not 

comply with terms and conditions will be issued a letter of non-compliance. Continued failure to 

meet terms and conditions can result in suspension or revocation of the permit.

The forest plan amendment regarding campsite location would allow outfitters to continue to 

use the approximate 98 established campsites within 200 feet of meadows, lakes, streams, and 

special interest areas. Current affects to wetlands would continue and still comply with Forest 

Plan standard and guidelines. 
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Wetlands

The existing campsites would continue to be used by pack and saddle stock outfitter-guides, 

potentially impacting approximately 86 acres of wetlands. The impacts caused by recent past 

use to nearby wetlands would continue, resulting in small, isolated areas of vegetative 

trampling, selective grazing, and soil damage in approximately 1% of the wetland habitats in the 

analysis area that are within a 500 foot buffer of campsites. The remaining 99% of the wetlands 

would remain in good ecological condition or would continue to recover from effects of past 

commercial livestock grazing. 

The existing campsites would continue to be used by pack and saddle stock outfitter-guides, 

potentially impacting approximately 86 acres of wetlands. The impacts caused by recent past 

use to nearby wetlands would continue, resulting in small, isolated areas of vegetative 

trampling, selective grazing, and soil damage in approximately 1% of the wetland habitats in the 

analysis area that are within a 500 foot buffer of campsites. The remaining 99% of the wetlands 

would remain in good ecological condition or would continue to recover from effects of past 

commercial livestock grazing. 

Mitigation measure 10c would require that stock travel routes through wetlands and wet 

meadows be managed to concentrate stock on a minimum number of pathways by placing 

obstacles in braided trail areas a way to minimize trails and damage to vegetation and soil. This 

would be moderately effective at reducing impacts to wetlands by minimizing the amount of soil 

compaction and erosion. 

R6 Special Status Species

Outfitter pack and saddle stock may affect some R6 Sensitive plant species by trampling. Some 

populations or individual loss could occur where species are in close proximity to established 

camps and use patterns are known to overlap habitat at Bald Mountain, Beaver Creek, Old 

Miller Camp, Sheep Mountain, Timberwolf 1, and Crow Lake. Currently, there is less risk of 

population loss compared to the past livestock grazing era and the sensitive plant resources as a 

whole are expected to continue to improve with this alternative over the larger area. The 

number of outfitted stock and the small isolated areas where stock use occurs, relative to the 

size of the analysis area, would not contribute to the risk of population loss or loss of species 

viability. Implementation of mitigation measures in Chapter 2 would further ensure species 

viability is not compromised. Specifically, measures included in Chapter 2, would mitigate 

potential effects to sensitive species and wetland habitat by encouraging loose grazing, 

prohibiting overnight picketing of stock in meadows, requiring use of approved handling 

facilities, minimizing trampling and removal of greenery, plus limiting the transport of noxious 

weeds through awareness and camp surveillance. These would be effective since they would 

be part of the operating plans for the outfitters, areas of concern would be identified, and 

compliance would be required through the special use permit. As mentioned above, outfitterguides are required under their permit to comply with the terms and conditions of their permit, 

including adherence to their operating plan. 

Camps where outfitter stock overnight that may affect individuals or populations are: Bald 

Mountain: blackened sedge, different-nerve sedge, and glaucous gentian; Beaver Creek: 
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different-nerve sedge, and glaucous gentian; Sheep Mountain: different-nerve sedge; 

Horseshoe Basin: different-nerve sedge; and at Horseshoe Creek: different-nerve sedge. 

Where different-nerve sedge and glaucous gentian occur populations are widely dispersed but 

concentrated in a small geographical area. In areas where camps overlap with occupied 

habitat, some individuals may be damaged or killed. This would not likely result in a total loss of 

population or species viability, due to the wide distribution of the species and the relatively 

small area of use by outfitters. 

Of the 54 R6 Special Status and Survey and Manage species found during surveys or that have 

potential habitat within the analysis area and their nearly 360 populations that occur within the 

analysis boundary, the risk to these species is very low. Since the pattern of use would not 

change with the implementation of this alternative, the risk to sensitive plants is not expected to 

increase. Use associated with Alternative 2 may result in the loss of some individuals at the Bald 

Mountain and Beaver Creek camps, but would not result in loss of species or population 

viability. Implementation of Alternative 2 would not result in a trend toward further listing of 

any species considered. There would be slightly more pack and saddle stock in the analysis area 

with this alternative compared to Alternative 3 and slightly less compared to Alternative 4. This 

alternative would have the same use as the existing condition of recent past use explained in 

the Affected Environment, but would increase over time. Use associated with Alternative 2 may 

result in the loss of some individuals but would not result in loss of species or population 

viability since there are enough populations in the analysis to ensure species viability. 

Implementation of Alternative 2 will not result in a trend toward further listing of any species 

considered. 

Natural Plant Succession

Alternative 2 would continue to allow plant community recovery across the analysis area. The 

pattern of use at these camps was established decades ago often in association with past 

livestock grazing, so much of the plant community alteration has already occurred. Use around 

the campsites would continue to result in some disturbance, but this use is small relative to the 

size of the analysis area. Alternatives 2 complies with Forest Plan standard and guideline 15B22A which addresses modification of natural plant succession and recovery. 

Hummocks

By continuing to use Beaver Creek camp as an assigned site, the large intact hummock 

community to the north of camp would remain in good ecological condition because when the 

stock are turned out to graze they are well dispersed and avoid this area. 

Use of the Bald Mountain site would still result in some expected use of the hummocks and 

spring seep the stock travel through to reach their night graze. There would still be potential 

for trampling of the hummocks and glaucous gentian population in this travel route which may 

result in the loss of this population. However, enough populations of glaucous gentian remain 

to ensure species viability; use would not result in a loss of species viability, even though there is 

potential for a loss of individuals with continued use of the camp 

Since the majority of the hummock patterned ground is beyond any recently permitted outfitted 

use, and would remain so in this alternative, the disturbance at the Bald Mountain camp would 

be insignificant relative to the area where it is found in the Pasayten Wilderness. 
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Alternative 3

In Alternative 3, the number of service days would be reduced to 2,660. There would be three 

assigned sites (Sheep Mountain, Crow Lake, and Whistler Camp) for full-service trips and five 

sites near trailheads for use as base camps (Andrews Creek, Billygoat, Slate Creek, Fish Creek, 

and Crater Creek), but pack and saddle outfitter-guides would be prohibited from using the Bald 

Mountain and Beaver Creek Camps because of their proximity to wetlands. The assigned base 

camps at the Andrews Creek, Billygoat, Slate Creek, Fish Creek, and Crater Creek trailheads 

would be permitted. Other than designating new assigned sites to replace the Bald Mountain 

and Beaver Creek sites, no new campsites, trails, or other ground disturbing activities would be 

permitted in this alternative. 

This alternative would amend the Okanogan and Wenatchee Forest Plan standards and 

guidelines in wilderness, allowing pack and saddle stock outfitter-guide camps to use up to 

2,800 square feet of barren core in camps where the existing amount exceeds that level. All 

outfitters would be required to use the same 2,800 square feet on successive trips, allowing the 

remaining barren core the potential to recover. Camps that are smaller than 2,800 square feet 

of barren core would remain at their current size. Outfitters would not be permitted to create 

additional barren core. 

The plan would also be amended to reduce party size for pack and saddle stock outfitter-guides 

to 12 heartbeats (people and stock). The mitigation measures in Chapter 2 would also prohibit 

the outfitters from creating new travel routes (10.c), establishing new camps (1.g), increasing 

the amount of bare mineral soil in established camps (1.e), and exposing roots on any more 

trees at existing campsites (1.f). Measures 8 a- j would minimize impacts to vegetation from 

grazing These would be effective since they would be part of the operating plans for the 

outfitters, so compliance would be required. Outfitter-guides are required under their permit to 

comply with the terms and conditions of their permit, including adherence to their operating 

plan. Outfitters who do not comply with terms and conditions will be issued a letter of noncompliance. Continued failure to meet terms and conditions can result in suspension or 

revocation of the permit.

This alternative would amend the Okanogan Forest Plan to prohibit outfitters from using 

established camps within 200 feet of wetlands, lakes, streams, or key interest areas in 

wilderness. This language allows outfitters to use dry meadow habitats for grazing their stock 

while in the backcountry. Applying the 200 linear foot distance to the camps in wilderness 

shows that there are 98 campsites with 200 feet of meadows, lakes, streams, and key interest 

areas and 18 of those campsites are within 200 feet of wetlands. Forty-six of the 153 

established wilderness campsites consistently used by outfitter-guides in this analysis area 

would no longer be available to them. Included in these 46 camps are two previously assigned 

sites: Bald Mountain and Beaver Creek. There would be no further impact from outfitter-guide 

activities to the wetlands near these camps, but impacts from stock could likely continue to 

some degree since the campsites may still be used by the public. 

Assigned sites under this alternative would not be open to public use, which allows better 

monitoring of resource impacts caused by outfitter activities. These sites would continue to 

receive the highest levels of use of all the outfitter camps. At assigned sites, the amount of 
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barren core would be reduced over time, since they would be closed to use by the general 

public and pack and saddle outfitter-guides would be restricted to 2,800 feet of these assigned 

sites. 

The smaller party size could result in outfitters needing to make multiple trips to a site in order 

to accommodate clients as a result of the reduced party size, thus increasing stock use over a 

season Grazing duration might also increase, as stock would graze when the clients are at the 

site and on the potential additional trips. This increased stock grazing would be expected 

particularly at assigned and full-service camp sites where stock use is already the highest. If the 

outfitters instead adjust to the reduced party size by reducing the number of stock used instead 

of taking additional trips, the impacts from grazing would be reduced.

Approximately 6% fewer pack and saddle stock would be in the analysis area compared to 

recently permitted numbers that resulted in the existing condition. Campsite use would remain 

the same compared with Alternative 2 and 4, with the exception of those campsites within 200 

feet of wetlands, which would be closed to outfitter use as noted above. Since these campsites 

would still be used by the public, there is not expected to be any difference in vegetative 

recovery compared with Alternative 2 and 4.

Wetlands

Since pack and saddle outfitter-guides would not be permitted to use existing campsites within 

200 feet of wetlands, the impacts to wetlands near these camps caused by recent past use by 

the pack and saddle outfitters would cease. Due to the non-use of campsites within 200 feet of 

wetlands by outfitter-guides, the number of wetland acres within a 500 foot buffer of campsites 

that could continue to be disturbed by pack and saddle stock would drop to 25.2. This equates 

to 0.003% of the wetland habitats in the analysis area that are within a 500 foot buffer of 

campsites which is a decrease from 86 acres or 1% of wetland habitats in Alternatives 2 and 4. 

There would be less vegetation trampling, selective grazing, and soil damage in wetland habitat 

in the analysis area. Where there are isolated cases of impacts to wetlands from stock use, 

recovery would occur relatively quickly, as wet habitats tend to be more resilient (Cole, D.N. 

1995a, 1995b). Wetlands would continue to recover from historic livestock use.

The Forest Plan amendment prohibiting campsites within 200 feet of wetlands could result in a 

higher concentration of use from outfitters across available sites. There could be more damage 

to vegetation as a result of concentrating grazing in areas that are the least resilient to grazing 

pressure, such as dry meadows and low shrub communities dominated by heather and 

huckleberry species. Mitigation measure 10c would reduce impacts as described on 3-260.

R6 Special Status Species

Outfitter pack and saddle stock may affect some R6 Sensitive plant species by trampling and a 

loss of some populations or individuals may occur where species are in close proximity to 

established camps and use patterns are known to overlap habitat. Currently, there is less risk of 

population loss compared to the past commercial livestock grazing era, and the sensitive plant 

resources as a whole would continue to improve under this alternative. The decreased numbers 

of animals and the small isolated areas where stock use occurs would minimize or eliminate risk 

of population loss or loss of species viability. Implementation of mitigation measures in Chapter 

2 would further ensure species viability is not compromised across the analysis area. 
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Okanogan-Wenatchee National Forest

Camps where outfitter stock currently overnight within 200 feet of wetlands would no longer be 

permitted for use by the pack and saddle outfitter-guides. The potential for individuals or 

populations to be impacted by pack and saddle outfitter-guides would be eliminated at those 

sites. The campsites and species that may continue to be impacted by outfitter use are; 

Horseshoe Basin: different-nerve sedge and Horseshoe Creek: different-nerve sedge. The 

species has not been confirmed within the 500 foot buffer area around these camps. Horseshoe 

Creek also includes emergent wetland habitat. 

Where different-nerve sedge and glaucous gentian occur at Old Miller, Sheep Mountain, 

Timberwolf 1, and Crow Lake, populations are widely dispersed but concentrated in a small 

geographical area. In areas where camps overlap with occupied habitat, some species may be 

damaged or killed. This would not likely result in a total loss of population or species viability, 

due to the wide distribution of the species and the relatively small area of use by outfitters. 

Even with outfitter use of campsites within 200 feet of wetlands being eliminated, stock use 

would likely overlap with suitable habitat for these species. 

Of the 54 Special Status and Survey and Manage species found during surveys or that have 

potential habitat within the analysis area and their nearly 360 populations that occur within the 

analysis boundary, the risk to these species is very low. Alternative 3 proposes the greatest 

reduction in use days and is the most restrictive on allowable barren core. Plant community 

recovery following a season of use may be slightly better than Alternative 2 and Alternative 4, 

respectively, but the use patterns are not expected to change the overall ecological condition or 

effects to any Sensitive plant populations or habitat within the analysis area. Use associated 

with Alternative 3 may result in the loss of some individuals but would not result in loss of 

species or population viability since there are enough populations in the analysis to ensure 

species viability. Implementation of Alternative 3 will not result in a trend toward further listing 

of any species considered. 

Natural Plant Succession

There would be less overall grazing pressure on plant communities with Alternative 3 relative to 

existing conditions. Alternative 3 is the most restrictive, the expected change in vegetative 

response from use at these sites would have more of an upward trend when compared with 

Alternatives 2 and 4 except in locations where campsites are closed and use shifts to drier, less 

resilient areas. 

The general public may shift part of their use to the assigned sites since these sites would not be 

occupied by outfitters. Private stock users are less likely to turn their animals out to graze any 

distance from camp, which may result in smaller isolated and concentrated grazing areas close 

to the campsites that are no longer being used as assigned sites for outfitted use. Some private 

parties use electric fencing and staking, in addition to highlines to keep stock close to camp. 

This results in more concentrated disturbance to vegetation around camps and may result in a 

shift of grazing use associated with some camps. It is the timing and concentration of use on a 

given piece of ground that drives recovery more than the overall number of animals using an 

area. And since private parties are less likely to loose graze their animals, the shift in animal use 

occurring closer to camps could likely result in increased grazing near these campsites. Use 

patterns at these camps were established decades ago, often in association with past 

commercial livestock grazing, so much of the plant community alteration has already occurred. 
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Okanogan-Wenatchee National Forest

Alternatives 3 complies with Forest Plan standard and guideline 15B-22A since there would be 

no long term modifications to natural plant succession as a result of pack and saddle stock 

outfitter-guide activities, and any impacts to vegetation would recover in one growing season. 

Hummocks

Beaver Creek and Bald Mountain camps would no longer be permitted for these outfitters to 

use, so impacts from stock traveling through the nearby hummocks would be reduced. The 

large intact hummock community to the north of the Beaver Creek camp would remain in good 

ecological condition because when the stock is turned out to graze they are well dispersed and 

avoid this area. 

Impacts from outfitters to the hummocks near the Bald Mountain camps would cease. Since the 

majority of the hummock patterned ground is beyond any current outfitted use, the change in 

the condition of this unique pattern ground would be insignificant relative to the area where it is 

found in the Pasayten Wilderness. 

Alternative 4

In Alternative 4 there would be 6,700 service days available for use by permitted outfitters. The 

party size would continue to be 12 people and 18 head of stock. There would be five assigned 

sites (Sheep Mountain, Beaver Creek, Bald Mountain, Crow Lake, and Whistler Camp) for fullservice trips and five sites near trailheads for use as base camps (Andrews Creek, Billygoat, Slate 

Creek, Fish Creek, and Crater Creek). 

This alternative would amend the Okanogan Forest Plan by stating that outfitters could use 

existing barren core in campsites but not create more barren core. All campsites with more 

than 5,250 square feet of barren core would have a Camp Management Plan to track the barren 

core and ensure it is not increasing. This amendment would continue the overall trend of nondegradation of wilderness conditions, specifically related to campsite conditions. The area of 

potential recovery at some sites would be reduced from Alternatives 2 and 3. This increase 

would not result in a substantial change in the overall ecological condition of the plant resources 

across the analysis area compared to Alternative 2 or Alternative 3 because the impacts already 

exist on the ground and are likely to persist because the rest of the area would still be open to 

the non-outfitted public. 

The mitigation measures in Chapter 2 would also restrict the outfitters from creating new travel 

routes (10.c) to minimize the impacts to wet soils and meadow areas, establishing new camps 

(except where the Forest Service may designate new camps as a result of closing existing 

campsites for resource protection), increasing the amount of bare mineral soil in established 

camps (1.d), and exposing roots on any more trees at existing campsites (1.f). Measures 8 a- j 

would minimize impacts to vegetation from grazing.

This alternative would also amend the Okanogan Forest Plan to allow outfitter guides and their 

stock to use established campsites within 200 feet of meadows, lakes and streams in wilderness. 

There are 64 campsites which have been noted to have meadows, lakes and streams within 200’ 

of the camp. Outfitters would continue to use these established campsites. There would still be 

small isolated areas where impacts are occurring, but these would not interfere with the natural 

ecological processes at the scale of the analysis area. Overall, the ecological integrity of the 
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Okanogan-Wenatchee National Forest

plant resources across the analysis area are in an upward, recovering, trend since the removal of 

commercial livestock grazing. Therefore, implementing Alternative 4 would not result in any 

increase in native plant community alteration. 

The assigned sites would allow better opportunity to monitor and regulate outfitter activities in 

regularly used sites. These sites have been used exclusively used by outfitters already, and 

would not be open for the general public. This would allow better management opportunities 

for ensuring ongoing resolution of resource issues. These sites would continue to receive the 

highest levels of use of all the outfitter camps. At assigned sites, the amount of barren core 

would not increase, since they would be closed to use by the general public and Pack and saddle 

stock outfitter-guides would not be allowed to increase the existing amount of barren core 

(bare, mineral soil) in established campsites. 

Monitoring (see Chapter 2) of assigned sites as part of special use permit administration would 

ensure that use either maintains or increases the ecological integrity of the area. Since assigned 

sites are the most heavily used sites, information gained from monitoring these sites would be 

of value for predicting ecological trends at similar sites in the analysis area.

As stated above, outfitters would not be permitted to increase the size of barren core in 

campsites. These would be effective since they would be part of the operating plans for the 

outfitters, so compliance would be required. Outfitter-guides are required under their permit to 

comply with the terms and conditions of their permit, including adherence to their operating 

plan. Outfitters would be required to comply with the terms and conditions of the permits.

Wetlands

The existing campsites would continue to be used by pack and saddle stock outfitter-guides, 

potentially impacting approximately 86 acres of wetlands. The impacts caused by recent past 

use to nearby wetlands would continue, resulting in small, isolated areas of vegetative 

trampling, selective grazing, and soil damage in approximately 1% of the wetland habitats in the 

analysis area that are within a 500 foot buffer of campsites. The remaining 99% of the wetlands 

would remain in good ecological condition or would continue to recover from effects of past 

commercial livestock grazing. Mitigation measure 10c would reduce impacts as described on 3-

260.

R6 Special Status Species

Outfitter pack and saddle stock may affect some R6 Sensitive plant species by trampling and a 

loss of some populations or individuals may occur where species are in close proximity to 

established camps and use patterns are known to overlap habitat. Currently, there is less risk of 

population loss compared to the past commercial livestock grazing era and the sensitive plant 

resources as a whole are expected to continue to improve with this alternative. The decreased 

numbers of animals and the small isolated areas where stock use occurs that overlaps with past 

commercial grazing impacts, would minimize or eliminate risk of population loss or loss of 

species viability. Implementation of mitigation measures in Chapter 2 would further ensure 

species viability is not compromised. Specifically, measures included in numbers 6, 8, 10, and 

14, would mitigate potential effects to sensitive species and wetland habitat (the effects of 

these mitigations for alternatives is discussed in the Effects Common to all Alternatives section). 

They would be effective since they would be part of the operating plans for the outfitters, and 

compliance would be required through the special use permit.
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Okanogan-Wenatchee National Forest

Camps where outfitter stock overnight that may affect individuals or populations are: Bald 

Mountain: blackend sedge, different-nerve sedge, and glaucous gentian; Beaver Creek: 

different-nerve sedge and glaucous gentian; Sheep Mountain: different-nerve sedge; Horseshoe 

Basin: different-nerve sedge; and Horseshoe Creek: different-nerve sedge. 

Where different-nerve sedge and glaucous gentian occur populations are widely dispersed but 

concentrated in a small geographical area. In these areas where camps overlap with occupied 

habitat, some species may be damaged or killed. This would not likely result in a total loss of 

population or species viability, due to the wide distribution of the species and the relatively 

small area of use by outfitters. 

Of the 54 R6 Special Status and Survey and Manage found during surveys or that have potential 

habitat within the analysis area and their nearly 360 populations that occur within the analysis 

boundary, the risk to these species is very low under Alternative 4. Use associated with 

Alternative 4 proposes the greatest number of service days and the most allowable amount of 

barren core compared to Alternatives 2 and 3. Use associated with Alternative 4 may result in 

the loss of some individuals but would not result in loss of species or population viability since 

there are enough populations in the analysis area to ensure species viability. The number of 

outfitted stock and the small isolated areas where stock use occurs, relative to the size of the 

analysis area, would not contribute to the risk of population loss or loss of species viability. 

Plant community recovery following a season of use may be slightly slower than Alternative 2 

and Alternative 3 but the use patterns are not expected to change the overall ecological 

condition or effects to any Sensitive plant populations or habitat within the analysis area. 

Natural Plant Succession

Increasing the use days to 6,700 and permitting existing campsite barren core size would allow 

more barren core to be used in campsites compared to Alternative 2 and Alternative 3. The 

barren core would not expand out beyond what is already being used. The increased number of 

service days could reduce the potential annual recovery of associated graze areas. The overall 

ecological recovery of the plant resources within the analysis area is expected to improve with 

the implementation of any of the action alternatives. This is because past commercial livestock 

use has had a substantially greater effect on the existing plant community composition and 

recovery than the level of recreational and outfitter stock has or would have in the future. 

Alternatives 4 complies with Forest Plan standard and guideline 15B-22A which addresses 

modification of natural plant succession and recovery.

Hummocks

The large intact hummock community to the north of the Beaver Creek assigned site would 

remain in good ecological condition because when the stock are turned out to graze they are 

well dispersed and avoid this area. 

Use of the Bald Mountain site would still result in some expected use of the hummocks and 

spring seep the stock travel through to reach their night graze. There would still be potential 

for trampling of the hummocks and glaucous gentian population in this travel route which may 

result in the loss of this population. However, enough populations of glaucous gentian remain 

to ensure species viability; use would not result in a loss of species viability, even though there is 

potential for a loss of individuals with continued use of the camp.
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Okanogan-Wenatchee National Forest

Since the majority of the hummock patterned ground is not within areas used by pack and 

saddle outfitter guide use, and would remain so in this alternative, the disturbance at the Bald 

Mountain camp would be insignificant relative to the area where it is found in the Pasayten 

Wilderness. 

Cumulative Effects

The spatial boundary for this cumulative effects analysis is the analysis area. The temporal 

boundary is from the early 1900s through 2024, when the 10-year permits would expire and 

effects associated with the permits would cease. Past actions with continuing effects 

overlapping effects of the pack and saddle stock outfitter-guides are included in the Current 

Condition section.

Present and Reasonably Foreseeable Future Actions

Present Actions

Grazing is permitted in the lower elevation habitats in all but the wilderness sub-sections, upper 

reaches of the Methow drainage in the North Cascades subunit, and the Sawtooth Backcountry 

subunit. This use does not interface with outfitter activities and has no effect on any actions 

associated with is analysis. Outfitters and permitees don’t use the same areas, so the 

disturbance doesn’t occur in the same place and at the same time. 

As discussed in the affected environment section where R6 Sensitive plant populations are 

associated with outfitter camp sites pack stock activities are part of the use. Occasionally, 

clients will ride their own stock in and will care for them while in the area and hire the outfitters 

to haul gear. Most of the camps are drop camps and typically not used overnight for pack and 

saddle stock. In these situations, grazing use is from private stock, not outfitter stock.

Reasonably Foreseeable Future Actions

Reasonably foreseeable future actions in the analysis area that may affect R6 Sensitive and 

Survey and Manage plant species, such as wetland and meadow habitats, are a continuation of 

the present actions. Use of the analysis area, especially the North Cascades Highway Corridor, 

by private recreationists is predicted to increase. Managing wildfire for resource benefits would 

continue to be an option in the Pasayten and Lake Chelan-Sawtooth Wilderness Areas and may 

become an option in non-wilderness portions of the analysis area. Meadow enlargement, 

creation, or enhancement from wildfires is more likely to occur in the future than it was in the 

past.

The cumulative effects of any of the alternatives with the present and reasonably foreseeable 

future actions discussed at the beginning of Chapter 3 would have no impacts on R6 Sensitive 

and Survey and Mange plant species habitat or species viability. The cumulative effects would 

not contribute to a downward trend or further listing of R6 Sensitive and Survey and Mange 

plant species. The cumulative effects of any of the alternatives with the present and reasonably 

foreseeable future actions would not contribute to long-term modification of natural plant 

succession or recovery.
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-269 February 2013

Okanogan-Wenatchee National Forest

Alternatives 1, 2, 3, and 4

The large fires in the 2000s combined with the past high density of commercial livestock grazing 

in these areas modified the natural plant succession across much of the analysis area, especially 

in the Pasayten and Lake Chelan-Sawtooth Wilderness Areas. Given the short growing seasons, 

post-grazing recovery to plant communities takes decades. As a result the majority of grazing 

effects seen across the analysis area are tied to past commercial livestock grazing practices and 

not the result of pack and saddle stock outfitter-guide or private party stock use. Recent past 

stock use by both pack and saddle outfitter-guides and private parties is slowing the recovery in 

small, localized areas by favoring less palatable species, or where wetlands are being trampled. 

Given the size of the analysis area, the effects of past grazing practices, and past fire history, the 

effects of pack and saddle outfitter-guide use across the landscape are inconsequential. 

The general public would be not allowed to use assigned camps. In all other camps used by 

outfitter-guides, continued use by the general public would likely perpetuate the existing 

amount of barren core.

Campsites within 200 feet of wetlands in Alternatives 1 or 3 would not be permitted for use by 

pack and saddle outfitter-guides. However, the private stock parties would still be allowed to 

use these areas. Although impacts by outfitters to wetlands near these camps would cease, use 

by private stock parties would still be have an effect on wetlands near camps. Private stock 

would still trample wetland vegetation, selectively graze, and cause soil damage to the wetlands 

habitat in the analysis area. 

As mentioned above in the direct/indirect effects of Alternative 3, there would be less overall 

grazing pressure on plant communities relative to existing conditions except around some 

popular private stock camps where confinement stock grazing is likely to occur. Existing 

campsites would continue to be used by private parties and would involve use of some wetland 

and wet meadow habitat and small isolated areas of trampling would continue unchanged. 

Some of the alterations in plant communities are still evident on the landscape, particularly in 

the drier habitats where sheep regularly bedded and trailed. However, these areas are slowly 

showing signs of recovery since commercial livestock have been removed. Since the removal of 

cattle grazing, there has been a rapid and visible recovery of riparian and wetland habitats in the 

Spanish Camp area in the Pasayten Wilderness (Kovalchik 2002). The Chelan side of the Lake 

Chelan-Sawtooth Wilderness and Sawtooth Backcountry has the most campsites that will likely 

exhibit the longest recovery period from past commercial grazing due to drier conditions.

The cumulative effect of any of the alternatives and the other past, present, and reasonably 

foreseeable future actions would result in an upward trend in vegetation condition, a slow 

return to natural, unmodified plant communities and succession. Areas would continue to 

recover from past overgrazing and the effects of wildfires. Isolated spots across the analysis 

area would see be slower to recover as a result of permitting pack and saddle stock grazing, but 

this would be inconsequential.
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Okanogan-Wenatchee National Forest

CONSISTENCY FINDINGS

Based on the findings in this analysis, this project complies with the provisions outlined in the 

Forest Service direction which requires activities not result in loss of species viability across their 

range nor will it result in a species becoming Threatened, Endangered, or create trends toward 

Federal listing. All action alternatives would reduce the potential loss of individual plants and 

population viability except in a small isolated area at the Bald Mountain Camp. However, with 

the isolated disturbance at Bald Mountain compared to the large scale of the analysis area all 

action alternatives would not contribute to a downward trend of Federally Listed Threatened or 

Endangered, R6 Special Status or Survey and Manage species across the analysis area.

All alternatives would be consistent with the Forest Plan, as amended. 

There would be no long-term modification of natural plant succession (MA 15B-22A), 

Okanogan Forest Plan; Wilderness, 2. a. (1) (c) and Wilderness, 3. a. (1) (c), Wenatchee 

Forest Plan). 

Alternatives would be consistent with all Forest Plan standards and guidelines pertaining 

to soil conditions (see Soils Resources section). In all alternatives, non-outfitted pack 

and saddle stock users, in addition to all recreationists would continue to use camps 

with barren cores and number of trees with exposed roots that exceed standards and 

guidelines. Forest Plan amendments would restrict outfitters to 5,250 square feet of 

barren core in Alternative 2, in Alternative 3 to 2,800 square feet, and no more than the 

existing amount of barren core for Alternative 4 and would include a Camp 

Management Plan to track the barren core when it is larger than 5,250 square feet to 

ensure it is not increasing. 

Party size restrictions apply only to Alternative 3, where party size would be limited to 

12 heartbeats. In Alternatives 2 and 4 the party size limit remains at 12 people and 18 

head of stock. Outfitter-guides would continue to use existing campsites within 200’ of 

lakes, streams, wetlands, and other unique habitats. In Alternative 3 pack and saddle 

outfitter-guides would be prohibited from using camps within 200 feet of wetlands. 

Mitigation measures apply to all three action alternatives and would prohibit outfitters 

from creating new travel routes (10.c), establishing new camps (1.g), and not exposing 

roots on trees at existing camps (1.f). These mitigation measures ensure that pack and 

saddle stock outfitter guide activities are consistent with Forest Plan.

3.8 TERRESTRIAL WILDLIFE

The section below is a summary of the Wildlife Report and Biological Assessment which are 

available in the record (Rohrer 2012). This section is organized to include the following: 

Management Indicator Species, Landbirds, Late-Successional Habitat, and Endangered, 

Threatened, and Sensitive Wildlife.

REGULATORY FRAMEWORK

Regulatory requirements vary for many of the species considered and are addressed in the 

report subsections that deal with individual wildlife groups and species that follow.
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Okanogan-Wenatchee National Forest

ANALYSIS METHOD FOR ALL SPECIES

Field surveys for this project include personal observations made on numerous trips to portions 

of the analysis area from 1991 through 2009. Most of these trips were associated with other 

projects. In late August 2000 this included participation in a review team that traveled to part of 

the Pasayten Wilderness specifically to observe and review effects of pack and saddle outfitterguide use.

Literature was reviewed to determine what research had shown for effects of similar activities in 

similar habitats. Forest Service GIS layers were used to determine the acreage of high elevation 

meadows and wetlands in the study area.

Digitized maps of forest roads and trails were used to analyze effects on grizzly bear core areas, 

and security habitat for all wide-ranging carnivores. Bear management units (BMU) were the 

scale used for reporting grizzly bear core area percentages.

During this analysis process, the best available science was incorporated to describe the 

ecological conditions within the analysis area and the potential effects of the proposed activities 

on terrestrial wildlife species and habitat.

MANAGEMENT INDICATOR SPECIES

In 2011 a status review was completed for Management Indicator Species (MIS) for the 

Okanogan-Wenatchee National Forest (Status of Management Indicator Species on the 

Okanogan and Wenatchee National Forests, April 2011, Unpublished document, 78pp). These 

species and their habitats are listed in Figure 3.8-1. This analysis used viability outcomes to 

describe the probability of the planning unit (National Forest) to support a population of each 

MIS based on current habitat and risk factors. It also included an estimate of the amount of 

habitat available at the Forest scale. Figure 3.8-1 includes the viability outcome for each MIS 

and a description of those viability outcomes. 
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Okanogan-Wenatchee National Forest

Figure 3.8-1. Summary of Management Indicator Species (MIS) for the Okanogan and 

Wenatchee National Forest Plans (USFS 1989:II-131 – 134, III-76 – 83; USFS 1990:III-48)

MIS Habitat Description

Habitat 

Present in 

Project 

Area

Species 

Present in 

Project Area

Forest Level 

Viability 

Outcome1

Acres of 

Habitat on 

OkanoganWenatchee 

National 

Forest

Northern spotted 

owl

Mature and oldgrowth conifer Yes Documented E

703,221

Barred owl 

(Oka NF only)

Mature and oldgrowth conifer Yes Documented A

170,799

Pileated 

woodpecker

Mature and oldgrowth conifer Yes Documented C

125,098

Three-toed 

woodpecker

Mature and oldgrowth conifer Yes Documented B/C 1,756,49

American marten Mature and oldgrowth conifer Yes Documented B/C 196,572

Mountain Goat

(Wen NF only)

Rockland, alpine, 

high elevation oldgrowth coniferYes Documented B

218,446

Mule deer Winter range Yes Documented A 321,775

Rocky Mountain 

elk (Wen NF only)

Winter range 

shrub, grass, and 

cover

Yes Documented A

152,581

Beaver

(Wen NF only)

Riparian with 

deciduous Yes Documented B/C 177,118

Ruffed grouse Riparian and 

deciduous Yes Documented A193,891

Canada lynx (Oka 

NF only) Lodgepole pine Yes Documented B

63,847

Primary Cavity Excavators

Pileated 

woodpecker

Dead and 

defective trees Yes Documented C

Three-toed 

woodpecker

Dead and 

defective trees Yes Documented B/C

Black-backed 

woodpecker

Dead and 

defective trees Yes Documented B/C

Downy 

woodpecker

Dead and 

defective trees Yes Documented A

Hairy 

woodpecker

Dead and 

defective trees Yes Documented A

Lewis’ 

woodpecker

Dead and 

defective trees Yes Documented C

White-headed 

woodpecker

Dead and 

defective trees Yes Documented C

Williamson’s 

sapsucker

Dead and 

defective trees Yes Documented B/C

Red-naped 

sapsucker*

Dead and 

defective trees Yes Documented B

Northern Flicker Dead and 

defective trees Yes Documented A
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Okanogan-Wenatchee National Forest

*The yellow-bellied sapsucker listed in the Okanogan Forest Plan (USFS 1989:III-78), was taxonomically split into three 

species in 1983: red-naped, red-breasted, and yellow-bellied sapsuckers (AOU 1983, Walters

et al. 2002); only the red-naped sapsucker occurs in Eastern Washington.

1Outcome A – Suitable environments are broadly distributed and of high abundance. The combination of distribution 

and abundance of environmental conditions provides opportunity for continuous or nearly continuous intra-specific 

interactions for the MIS species. MIS species with this outcome are likely well-distributed throughout the planning 

area.

Outcome B - Suitable environments are broadly distributed and of high abundance, but there are gaps where suitable 

environments are absent or only present in low abundance. However, the disjunct areas of suitable environments are 

typically large enough and close enough to permit dispersal among subpopulations and to allow the species to 

potentially interact as a metapopulation. Species with this outcome are likely well-distributed throughout most of the 

planning area.

Outcome C – Suitable environments are distributed frequently as patches and/or exist at low abundance. Gaps where 

suitable environments are either absent or present in low abundance are large enough such that some 

subpopulations are isolated, limiting opportunity for intra-specific interactions. There is opportunity for 

subpopulations in most of the planning area to interact, but some subpopulations are so disjunct or of such low 

density that they are essentially isolated from other populations. For species for which this is not the historical 

condition, reduction in the species’ range in the planning area may have resulted. Species with this outcome are likely 

well-distributed in only a portion of the planning area.

Outcome D – Suitable environments are frequently isolated and/or exist at very low abundance. While some of the 

subpopulations associated with these environments may be self-sustaining, there is limited opportunity for 

population interactions among many of the suitable environmental patches. For species for which this is not the 

historical condition, reduction in species’ range in the planning area may have resulted. These species are likely not 

well-distributed in the planning area.

Outcome E – Suitable environments are highly isolated and exist at very low abundance, with little or no possibility of 

population interactions among suitable environmental patches, resulting in strong potential for extirpations within 

many of the patches, and little likelihood of recolonization of such patches. There has likely been a reduction in the 

species’ range from historical conditions, except for some rare, local endemics that may have persisted in this 

condition since the historical time period. Species with this outcome are not well-distributed throughout much of the 

planning area.

Primary Cavity Excavators

Regulatory Framework

Primary cavity excavators are forest dwelling birds specialized for nesting and foraging in dead 

and dying trees and downed logs. The Okanogan Forest Plan identifies the Lewis’s, pileated, 

three-toed, black-backed, downy, hairy, and white-headed woodpeckers; red-naped and 

Williamson’s sapsuckers; and Northern flicker as management indicator species for dead and 

defective tree habitat. The Wenatchee Forest Plan identifies primary cavity excavators as 

management indicator species for dead and defective tree habitat. Details on habitat use, 

ecology, and viability on the Forest are in the Wildlife MIS Status Report (2011). Both of the 

Forest Plans have standards and guidelines for maintaining minimal levels of dead and defective 

trees and downed logs, although these were amended by the Northwest Forest Plan and 

PACFISH.
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Okanogan-Wenatchee National Forest

Affected Environment

Dead and defective tree habitat is abundant in the Pasayten and Lake Chelan-Sawtooth 

Wilderness Areas, the North Cascades, Sawtooth Backcountry, and most of the Middle Methow 

portions of the analysis area. Due to the relative lack of past management activities the 

majority of these areas have dead and defective tree habitat occurring at natural levels. Much 

of these areas are high elevation forest of subalpine fir, Engelmann spruce, lodgepole pine, and 

Douglas-fir, though there are a few areas with ponderosa pine. Recent forest insect and disease 

activity has resulted in an abundance of dead and defective tree habitat in some areas. Pine 

beetle activity has killed large numbers of mature lodgepole pine trees and root-rots have killed 

many pockets of Douglas-fir. Recent large wildfires in the analysis area have consumed some 

dead and defective tree habitat, but have also created many new snags.

Snags and downed logs have been used for camp firewood by overnight users of the analysis 

area, including outfitter-guides and clients, though most collected wood is small in diameter. 

Firewood collection predominantly occurs in and adjacent to camp sites. Wood is cut with an 

axe or saw and carried or dragged to the camp. At most camps firewood is collected from 

within a 200-300 foot radius of camp (3-6 acres). At a few of the more regularly used camps, 

such as those in the Spanish Camp area of the Pasayten wilderness, wood had been collected 

from further distances and the evidence of years of firewood collection is apparent from the 

number of sawed stumps and branches. However recent forest insect and disease activity has 

resulted in an abundance of new snags near these and other camps in the analysis area. 

There are 148 campsites that have been used in the recent past by outfitter-guides. If, on 

average at each camp, most snags have been removed from an area within a 300 foot radius of 

the camp (6 acres), then 1,116 acres of the analysis area have been impacted by past use. 

Figure 3.8-2 shows number of outfitter camps and estimated percent of area impacted by 

firewood collection by administrative area:

Figure 3.8-2. Percent of Area Impacted by Outfitter-Guide Camps.

Sub-Area Sub-Area Acres Outfitter Camps Acres 

Impacted

Area Impacted

Pasayten Wilderness 531,541 75 444 0.08%

Lake Chelan-Sawtooth 

Wilderness

153,129 78 468 0.3%

North Cascades 270,435 16 96 0.03%

Sawtooth Backcountry 35,149 17 102 0.3%

Middle Methow 50,550 0 0 0

Bear/Ramsey/Volstead 58,114 1 6 0.01%

Alta Lake 3958 0 0 0

Total 1,102,876 149 1,116 0.1%

Dead and defective tree habitat is not as abundant in the Bear/Ramsey/Volstead area as other 

portions of the analysis area. Recent timber harvest in portions of this area has resulted in 

lower numbers of snags. Snags are scarce in areas immediately adjacent to open roads due to 

firewood cutting. Much of the area is a mid-elevation forest of Douglas-fir and ponderosa pine, 

though there are a few areas with lodgepole pine, subalpine fir, and Engelmann spruce. The 
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Tripod fire burned through much of this area creating pockets of dead and defective tree 

habitat.

The Alta Lake area is largely unforested but there are scattered ponderosa pine and small 

isolated stands of ponderosa pine and Douglas-fir. These stands have dead and defective tree 

habitat occurring at natural levels. In addition, outfitter-guides do not gather wood for 

campfires in the Alta Lake area. They only use that area for day rides. 

Environmental Consequences

Direct and Indirect Effects

Alternative 1

Outfitter-guide permits would not be issued, so outfitter-guides would not use existing camp 

sites. However, most, if not all, of the camps would continue to be used by the public. Snags 

and downed logs would continue to be used for camp firewood, but by fewer users than in the 

past. There would be 24,420 pack and saddle stock visitor days in the analysis area (all nonoutfitted), which would be 15% less than the existing number. Less than one tenth of 1% of the 

analysis area has been affected by past snag-felling for firewood. New snags would continue to 

be created by insects, disease, wildfire, and drought. These snags would eventually fall over, 

creating a supply of downed wood. There would be some additional loss of habitat around 

recreation camps, but abundant habitat exists away from these isolated spots, so primary cavity 

excavator populations as a whole would be largely unaffected. Alternative 1 would not change 

the viability outcomes listed in Figure 3.8-1. It would not contribute to a negative trend in 

viability on the Okanogan-Wenatchee National Forest for primary cavity excavator populations.

Alternative 2

In addition to the public, outfitter-guides and clients would use camps and collect firewood from 

surrounding areas. There would be 29,040 pack and saddle stock visitor days in the analysis 

area (4,620 outfitted), which would be 0.6% more than the existing number. Less than one 

tenth of 1% of the analysis area has been affected by past snag-felling or downed wood 

gathering for firewood. New snags would continue to be created by insects, disease, wildfire, 

and drought. These snags would eventually fall over, creating a supply of downed wood. 

This alternative includes mitigation measures that would prohibit outfitter-guides from 

establishing new camps (1.g) and not allow cutting snags for firewood (3.c). These would be 

effective in mitigating potential effects since they would be part of the operating plans, and 

compliance would be required by the special use permits. Non-compliance may result in permit 

action. There would be some loss of habitat around camps used by outfitters, since downed 

wood could be used for firewood, but abundant habitat exists away from these isolated spots, 

so primary cavity excavator populations as a whole would be largely unaffected. Alternative 2 

would not change the viability outcomes listed in Figure 3.8-1. It would not contribute to a 

negative trend in viability on the Okanogan-Wenatchee National Forest for primary cavity 

excavator populations. 
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Alternative 3

In addition to the public, outfitter-guides and clients would use camps and collect firewood from 

surrounding areas. There would be 27,080 pack and saddle stock visitor days in the analysis 

area (2,660 outfitted), which would be 6% less than the existing number. Less than 0.1% of the 

analysis area has been affected by past snag-felling or downed wood gathering for firewood. 

New snags would continue to be created by insects, disease, wildfire, and drought. These snags 

would eventually fall over, creating a supply of downed wood. 

This alternative includes mitigation measures that would prohibit outfitter-guides from 

establishing new camps (1.g) and not allow cutting snags for firewood (3.c). These would be 

effective in mitigating potential effects since they would be part of the operating plans, and 

compliance would be required by the special use permits. Non-compliance may result in permit 

action. There would be some loss of habitat around camps used by outfitters, since downed 

wood could be used for firewood, but abundant habitat exists away from these isolated spots, 

so primary cavity excavator populations as a whole would be largely unaffected. Alternative 3 

would not change the viability outcomes listed in Figure 3.8-1. It would not contribute to a 

negative trend in viability on the Okanogan-Wenatchee National Forest for primary cavity 

excavator populations. 

Alternative 4

In addition to the public, outfitter-guides and clients would use camps and collect firewood from 

surrounding areas. There would be 31,136 pack and saddle stock visitor days in the analysis 

area (6,700 outfitted), which would be 8% more than the existing number. Less than one tenth 

of 1% of the analysis area has been affected by past snag-felling or downed wood gathering for 

firewood. New snags would continue to be created by insects, disease, wildfire, and drought. 

These snags would eventually fall over, creating a supply of downed wood. 

In spite of the potential for more user days, the effect to snag habitat should not increase 

because this proposal includes mitigation measures that would prohibit outfitter-guides from 

establishing new camps (1.g) and not allow cutting snags for firewood (3.c). These would be 

effective in mitigating potential effects since they would be part of the operating plans, and 

compliance would be required by the special use permits. Non-compliance may result in permit 

action. There would be some loss of habitat around camps used by outfitters, since downed 

wood could be used for firewood, but abundant habitat exists away from these isolated spots, 

so primary cavity excavator populations as a whole would be largely unaffected. Alternative 4 

would not change the viability outcomes listed in Figure 3.8-1. It would not contribute to a 

negative trend in viability on the Okanogan-Wenatchee National Forest for primary cavity 

excavator populations. 

Cumulative Effects

The spatial boundary for the cumulative effects analysis is the analysis area as described in 

Chapter 1. The temporal boundary is from the early 1900s through 2023, when the 10 year 

permits would expire.
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Past Actions

Past activities in the analysis area that affected primary cavity excavators include snag-felling for 

camp firewood by outfitter-guides, by non-outfitted users, and by sheepherders. In addition, 

wildfires, wildfire suppression, and timber management have affected primary cavity excavator 

habitat. Wildfires have consumed some dead and defective tree habitat in the analysis area but 

also created many new snags and habitat for primary cavity excavators. Nearly 20% of the 

analysis area has been affected by wildfires in the last 5 years. Wildfire suppression has also 

affected snag habitat. Wildfire suppression began in the 1920s and slowly changed forest 

structure, especially in lower elevations of the analysis area. Snags on ridge-tops were often 

felled in the name of fire prevention. The reduction in wildfires, due to suppression, created 

dense stands of small diameter trees. These denser stands were more susceptible to insects 

and diseases which resulted in an increase in snag habitat. In the Bear/Ramsey/Volstead area, 

dead and defective tree habitat has also been impacted by snag-felling near roads for firewood, 

timber management projects, and prescribed fires. Timber management projects have 

generally reduced the amount of snag habitat, though maintaining minimum levels prescribed in 

the forest plans in 1989 and 1990. Prescribed fires have both removed some existing snags and 

created new ones.

Present Actions

Present activities in the analysis area that may affect primary cavity excavators include snagfelling for camp firewood by other non-pack and saddle outfitter-guides, and by private, nonoutfitted users. In the Bear/Ramsey/Volstead area, snag-felling for firewood by the general 

public occurs near open roads.

Reasonably Foreseeable Future Actions

Reasonably foreseeable future activities in the analysis area that may affect primary cavity 

excavators are a continuation of the present actions. Use of the analysis area, especially the 

North Cascades Highway Corridor, by private recreationists is predicted to increase in the future.

Alternatives 1, 2, 3, and 4

When considered in conjunction with other activities affecting dead and defective tree habitat, 

each of the four alternatives would have little cumulative effect on primary cavity excavators. 

Snags may continue to diminish around camps due to private party use and other permitted 

activities, but not as a result of pack and saddle outfitter-guides because this proposal prohibits 

snag felling by these outfitter-guides (mitigation measure 3.c). Abundant habitat would exist 

away from these sites, so primary cavity excavator populations as a whole would be largely 

unaffected.

Consistency Findings

Each of the four alternatives considered in this project would be consistent with the Okanogan 

and Wenatchee Forest Plan standards and guidelines for primary cavity excavators. Based on 

the analysis above this project would not contribute to a negative trend in viability on the 

Okanogan-Wenatchee National Forest for the pileated, three-toed, black-backed, downy, hairy, 

Lewis’ and white-headed woodpeckers; red-naped and Williamson’s sapsuckers; and Northern 

flicker.
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Marten, Pileated Woodpecker, Three-toed Woodpecker, Northern Spotted 

Owl and Barred Owl

Regulatory Framework

The Okanogan Forest Plan identifies the American marten (mis-identified in the Forest Plans as 

“pine” marten), pileated woodpecker, three-toed woodpecker, northern spotted owl and the 

barred owl as management indicator species for mature or old growth habitats in mixed conifer, 

lodgepole pine, and/or subalpine fir forest types. The Wenatchee Forest Plan identifies the 

American marten, pileated woodpecker and three-toed woodpecker and northern spotted owl 

as management indicator species for mature and old growth habitats. The Okanogan Forest 

Plan has standards and guidelines for maintaining old growth habitat; specifically that no old 

growth that meets the definition in the Forest Plan be removed. Both the Okanogan and 

Wenatchee Forest Plans also have management requirement (MR) standards for marten, 

pileated woodpecker, three-toed woodpecker and the northern spotted owl. These MRs were 

replaced by the Northwest Forest Plan in 1994 within the range of the northern spotted owl. 

The analysis area for this project extends east of the range of the northern spotted owl and 

these MRs apply in the eastern most part of the analysis area. The Wenatchee Forest Plan has 

forest management objectives for old growth habitat. In addition, for the portions of the 

analysis area within Late-Successional Reserves (LSR) of the Northwest Forest Plan there are 

standards and guidelines to ensure all projects have a neutral or beneficial effect on latesuccessional habitats in late successional reserves. Although only applicable to timber sales, 

Regional Forester Amendment #2 also ensures the maintenance of adequate late-successional 

habitat.

Affected Environment

The American marten is a small forest carnivore that inhabits mature/old growth habitats, 

especially those with an abundance of downed woody debris. The pileated woodpecker inhabits 

mixed conifer stands and the three-toed woodpecker inhabits lodgepole pine and subalpine fir 

forest types. Northern spotted and barred owls are management indicator species for mixed 

conifer old growth and mature habitats. The northern spotted owl is discussed in the biological 

assessment below. Details on habitat use, ecology, and amount of habitat on the forest for each 

of these species are in Wildlife MIS Status Report (2011). The amount of habitat on the Forest 

for each of these species is also listed in Figure 3.8-1, as is the viability outcome from the 2010 

Status Report. 

Mature and old growth habitat in mixed conifer, lodgepole pine, and subalpine fir forest types is 

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

Sawtooth Backcountry, and most of the Middle Methow portions of the analysis area. Due to 

the relative lack of management activities the majority of these areas have mature and old 

growth habitat occurring at natural levels. However, these habitats in the portion of the 

analysis area on the Chelan Ranger District were reduced by the Rex Creek Fire of 2001 and the 

Safety Harbor Fire of 1968. Additionally, mature and old growth habitat is not as abundant in 

the Bear/Ramsey/Volstead area as in the others. Much of the area is mid-elevation forest of 

Douglas-fir and ponderosa pine, though there are a few areas with lodgepole pine, subalpine fir, 

and Engelmann spruce. Past timber management activities have resulted in lower amounts of 
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mature and old growth habitat than would naturally occur. The Alta Lake area does not contain 

any mature/old growth habitat in mixed conifer, lodgepole pine, and subalpine fir forest types.

Environmental Consequences

Direct, Indirect, and Cumulative Effects

Outfitter-guide activities do not alter forest stands except for the removal of snags and downed 

logs which are used for camp firewood when on overnight trips. Firewood collection 

predominantly occurs in and adjacent to camp sites. See the section above on primary cavity 

excavators for the discussion on effects to snags and downed logs.

The spatial boundary for the cumulative effects analysis is the analysis area as described in 

Chapter 1. The temporal boundary is from the early 1900s through 2023, when the 10 year 

permits would expire and the effects to late successional habitat would cease.

Alternatives 1, 2, 3, and 4

None of these alternatives would alter forest stands with the exception of firewood use in and 

around campsites. Abundant habitat exists away from the campsites, so American marten, 

pileated woodpecker, three-toed woodpecker, and barred owl populations as a whole would be 

largely unaffected. They would not change the viability outcomes listed in Figure 3.8-1. This 

minor effect to old-growth or mature stands would not have any effect on the character of any 

management requirement areas for the pileated woodpecker, marten, three toed woodpecker, 

or northern spotted owl. 

None of the alternatives in this project would contribute to a negative trend in viability on the 

Okanogan-Wenatchee National Forest for marten, pileated woodpecker, three-toed 

woodpecker, northern spotted owl, or barred owl.

Consistency Findings

The above analysis shows that each of the four alternatives considered in this project would be 

consistent with the Okanogan and Wenatchee Forest Plans (as amended by the Northwest 

Forest Plan and PACFISH) for mature, late-successional and old growth habitats.

Ruffed Grouse and Beaver

Regulatory Framework

The Okanogan Forest Plan identifies the ruffed grouse as the management indicator species of 

deciduous and riparian habitats. The Wenatchee Forest Plan identifies the beaver and the 

ruffed grouse as management indicator species for riparian habitats. In the Okanogan Forest 

Plan standard and guideline 6-13 addresses perpetuating hardwood stands (deciduous trees). 

Both Forest Plans have several standards and guidelines regarding riparian habitat management. 

In addition, each Forest Plan has been amended by the Northwest Forest Plan which includes 

the aquatic conservation strategy, and the Okanogan Plan was amended by PACFISH outside the 
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range of the northern spotted owl; PACFISH includes riparian management objectives and 

standards and guidelines require that special use permits avoid adverse effects to listed fish.

Ruffed grouse are primarily associated with habitats that contain dense stands of aspen trees or 

other deciduous trees and shrubs along streams. The beaver is a semi-aquatic mammal that 

lives in streams and ponds and requires deciduous trees and shrubs for food and for lodge and 

dam building materials. Details on habitat use, ecology, and amount of habitat on the Forest for 

ruffed grouse and beaver are in Wildlife MIS Status Report (2011). The amount of habitat on the 

Forest for each of these species is also listed in Figure 3.8-1, as is the viability determination.

More impacts to riparian habitat and standards and guidelines can be found in the Aquatics 

section of this Chapter. 

Affected Environment

Deciduous and riparian habitats occur throughout the analysis area. Due to the relative lack of 

management activities in the Pasayten and Lake Chelan-Sawtooth Wilderness Areas, the North 

Cascades, Sawtooth Backcountry, and most of the Middle Methow portion of the analysis area, 

these areas have essentially the same deciduous and riparian habitat that occurs under natural 

conditions. Some of the deciduous and riparian habitat in the Bear/Ramsey/Volstead area has 

been cut and removed by timber management activities and road construction, although the 

Forest now plans timber sales to perpetuate aspen and protect or enhance riparian habitat 

under current management direction. The Alta Lake area has a limited amount of deciduous 

and riparian habitats. They have been impacted in the recent past by cattle grazing and 

drought.

Forested riparian habitats in the analysis area generally receive little, if any, impact from 

humans or livestock and are functioning properly (Recreation Activity Review, Appendix C). 

Streams that flow through high elevation meadows are more easily accessed by humans and 

their grazing livestock and are very susceptible to impacts from heavy grazing and trampling. 

Pack and saddle stock grazing associated with outfitter-guide activities has impacted isolated 

spots of the grass/forb components of non-forested riparian habitats (see also Botany section of 

this chapter).

High elevation wetlands are similar to other riparian habitats; the importance to wildlife is 

disproportionately greater than availability on the landscape (Kauffman et al. 2001). These 

areas provide a predictable water source, favorable microclimate, a high diversity of plants that 

offer various structures for nesting and security, and a diverse forage supply. Long-toed 

salamanders and spotted frogs reproduce, deposit eggs, and spend the larval stage and most of 

the adult stage of life in wetlands. Lincoln’s sparrows forage in shrubs and nest on the ground 

around high elevation wetlands (Degraaf et al. 1991). Water voles and northern bog lemmings 

utilize the grass/forb layer for food and cover (O’Neil et al. 2001). High elevation wetlands are 

distributed throughout the analysis area. There are about 8,200 acres of high elevation 

wetlands in the analysis area. A notable concentration occurs in the Ashnola River watershed of 

the Pasayten Wilderness. The wetlands of Sheep Mountain, Bald Mountain, Beaver Creek, Bob 

Creek, and the Spanish Camp area are included in this concentration.
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Most of the high elevation meadows and wetlands in the analysis area were heavily grazed by 

domestic sheep in the early 1900s (for details see Range section of this chapter) which affected 

riparian habitat by removal of vegetation and trampling of banks. From 1995 to present, 

domestic livestock grazing in this area has been limited to that of recreational users including 

outfitter-guide activities.

In August 2000, a Forest Service administrative review team found that riparian areas in the 

Spanish Camp area were well-vegetated and stable with a few localized exceptions associated 

with trail crossings and stock watering sites (Recreation Activity Review, Spanish Camp and 

Remmel Lake Area, Pasayten Wilderness, USDA Forest Service 2000c). Some sites appeared to 

still be recovering from heavy impacts of historical grazing by sheep and cattle. The findings of 

this report are summarized in Appendix F. A field trip to the same areas in August 2011 resulted 

in similar findings (J. Rohrer, field notes, August 2011, analysis file). 

Many outfitter-guide camps are located near high elevation meadows and wetlands. The 

abundant grasses and forbs in meadows provide forage for outfitter horses, mules, burros, or 

llamas. During wildlife habitat reviews in the Spanish Camp area of the Pasayten Wilderness in 

August 2000 and August 2011, it was found that the existing amount of recreational grazing use 

was, with a few notable exceptions, not substantially altering the structure or function of the 

high elevation meadows and wetlands as food and cover for wildlife (J.Rohrer, field notes, 

analysis file). Popular camp areas, such as the immediate areas around Spanish Camp cabin and 

Remmel Lake, had been grazed enough to reduce the cover value for ground nesting birds and 

small mammals. There are riparian and wetland areas where stock regularly travel across or 

come to water. These sites are trampled and unvegetated and offer little as wildlife habitat. 

However, outside of these impacted sites and away from trails, wetlands were in good to 

excellent shape and showed little, if any, evidence of livestock grazing. Grasses and forbs 

provide both food and cover. Amphibian larvae are common in small wetland ponds on Bald 

Mountain and along Bob and Beaver Creeks. In addition, there are numerous wetlands in the 

analysis area that are not accessible to livestock. Most areas on the Chelan portion of the 

analysis area show minimal evidence of long-term stock use, with some exceptions of limited 

areas at frequently used sites.

Environmental Consequences

Direct and Indirect Effects

Alternative 1

Outfitter-guides would not use the trails and camps, though use would continue by the public. 

The existing trail crossings of streams and stock watering sites would likely continue to be used, 

but by fewer stock than in the past. This alternative includes 24,420 pack and saddle stock 

visitor days, which would be 15% lower than the current level. Some sites might partially 

revegetate with the lower amount of use. This alternative would result in a slight decrease in 

the amount of riparian habitat trampled by livestock compared to the existing condition. 

Abundant ruffed grouse and beaver habitat exists away from these trail crossings and stock 

watering sites, so populations as a whole would be largely unaffected. Alternative 1 would not 

change the viability outcomes listed in Figure 3.8-1. It would not contribute to a negative trend 

in viability on the Okanogan-Wenatchee National Forest for ruffed grouse or beaver.
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Alternative 2

Outfitter-guides and livestock would continue to use trails and camps and impact nearby 

riparian areas. There would be a total of 29,040 pack and saddle stock visitor days in the 

analysis area, and 4,620, or 16% would be associated with outfitter-guides. This would be a 4% 

increase from the current permitted pack and saddle outfitter-guide use and a 0.6% increase 

from the current total pack and saddle stock use. Existing trail crossings and watering sites 

would continue to be trampled and unvegetated. As stated above these impacts are limited to a 

few heavily used sites and are only occurring on a small portion of the landscape. 

This alternative includes an amendment that would allow the use of established campsites that 

are within 200 feet of meadows, lakes, and streams in the Pasayten and Lake Chelan-Sawtooth 

wilderness areas. 

This alternative includes mitigation to limit use in wilderness to existing trails (6.a), minimize use 

of wet soil and meadow areas (10.c), and ensure that riparian protection occurs (12 a-g). These 

mitigation items should result in improved riparian habitat conditions. Abundant ruffed grouse 

and beaver habitat exists away from these trail crossings and stock watering sites, so ruffed 

grouse and beaver populations as a whole would be largely unaffected. Alternative 2 would not 

change the viability outcomes listed in Table 3.8-1. It would not contribute to a negative trend 

in viability on the Okanogan-Wenatchee National Forest for ruffed grouse or beaver.

Alternative 3

Outfitter-guides and livestock would use trails and camps and impact nearby riparian areas. The 

number of permitted pack and saddle stock visitor days would be reduced by 40% from current 

levels and the total number of pack and saddle stock visitor days would be reduced by 6% from 

its current level. Existing trail crossings and watering sites would likely continue to be trampled 

and unvegetated. Alternative 3 includes a Forest Plan amendment that would limit existing 

barren core areas to 2,800 square feet. It includes a Forest Plan amendment that would reduce 

the wilderness party size to 12 people and stock combined. It includes a Forest Plan 

amendment that would allow outfitter-guides to use existing campsites within 200 feet of dry 

wetlands, but prohibit camping within 200 feet of wetlands, lakes streams and key interest 

areas in the Pasayten and Lake Chelan-Sawtooth wilderness areas. These amendments in 

conjunction with a slightly lower amount of use than proposed in Alternative 2 and less use than 

in the recent past, would create improvements at some of existing stream/trail crossings and 

watering sites. 

As stated above these impacts are limited to a few heavily used sites and are only occurring on a 

small portion of the landscape. 

This alternative also includes mitigation to limit use in wilderness to existing trails (6.a), 

minimize use wet soil and meadow areas (10.c), and ensure that riparian protection occurs (12

a-g). Abundant ruffed grouse and beaver habitat exists away from these trail crossings and 

stock watering sites, so populations as a whole would be largely unaffected. Alternative 3 would 

not change the viability outcomes listed in Figure 3.8-1. It would not contribute to a negative 

trend in viability on the Okanogan-Wenatchee National Forest for ruffed grouse or beaver.
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Alternative 4

Outfitter-guides and livestock would continue to use trails and camps and impact nearby 

riparian areas. There could be a total of 31,136 pack and saddle stock visitor days in the analysis 

area, and 6700 or 14% would be associated with outfitter-guides. This would be an 8% increase 

in total pack and saddle stock days over the current and a 50% increase in the permitted pack 

and saddle stock days. Existing trail crossings and watering sites would continue to be trampled 

and unvegetated. As stated above these impacts are limited to a few heavily used sites and are 

only occurring on a small portion of the landscape. 

This alternative includes an amendment that would allow the use of established campsites that 

are within 200 feet of meadows, lakes, and streams in the Pasayten and Lake Chelan-Sawtooth 

wilderness areas. 

This alternative also includes mitigation to limit use in wilderness to existing trails (6.a), 

minimize use wet soil and meadow areas (10.c), and ensure that riparian protection occurs 

(12.a-g). Abundant ruffed grouse and beaver habitat exists away from these trail crossings and 

stock watering sites, so ruffed grouse and beaver populations as a whole would be largely 

unaffected. Alternative 4 would not change the viability outcomes listed in Figure 3.8-1. It 

would not contribute to a negative trend in viability on the Okanogan-Wenatchee National 

Forest for ruffed grouse or beaver.

Cumulative Effects

The spatial boundary for the cumulative effects analysis is the analysis area as described in 

Chapter 1. The temporal boundary is from the early 1900s through 2023, when the 10 year 

permits would expire, and the effects to beaver and ruffed grouse would cease.

Past, Present, Reasonably Foreseeable Future Actions

Other activities in the analysis area that would affect deciduous and riparian habitat include 

timber sales, road construction and maintenance, wild fires, prescribed fires, grazing by livestock 

from non-outfitted users, and commercial livestock grazing. Most recreational livestock use 

occurs in the same areas used by outfitter-guides, i.e., those accessed by trails. There are 

several active livestock allotments in the analysis area. The Ramsey C & H (cattle and horse) 

allotment is in the Bear/Ramsey/Volstead portion of the analysis area. The Alta Coulee C & H 

allotment is in the Alta Lake portion of the analysis area. Parts of the Goat C & H allotment, 

parts of the Wolf C & H allotment, and Boulder C & H allotment are in the Upper Methow 

portion of the analysis area. A portion of the Buttermilk sheep and goat allotment is in the Lake 

Chelan-Sawtooth Wilderness and Middle Methow portion of the analysis area. Forage 

utilization by the cattle and sheep on these allotments is closely monitored to not remove more 

than 45% of current annual growth of grasses/forbs.

Alternatives 1, 2, 3, and 4

The cumulative effect of any of the alternatives and the other past, present, and reasonably 

foreseeable future actions would be the loss of some riparian habitat due to pack and saddle 

stock trampling in and around campsites. Although Alternatives 1 and 3 would allow for some 

recovery of camps within 200 feet of wetlands, streams and lakes, any recovery would likely be 

offset by non-outfitted use of those campsites. Abundant ruffed grouse and beaver habitat 
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exists away from these trail crossings and stock watering sites, so ruffed grouse and beaver 

populations as a whole would be largely unaffected.

Consistency Findings

Each of the four alternatives considered in this project would be consistent with the Okanogan 

and Wenatchee Forest Plans for managing riparian habitats. The impacts are limited to a few 

heavily used sites and are only occurring on a small portion of the landscape. This proposal 

includes mitigation to limit use in wilderness to existing trails (6.a), minimize use of wet soil and 

meadow areas (10.c), and ensure that riparian protection occurs (12.a and 12.b). These 

mitigation items should result in improved riparian habitat conditions. Abundant ruffed grouse 

and beaver habitat exists away from these trail crossings and stock watering sites, so ruffed 

grouse and beaver populations as a whole would be largely unaffected. They would not change 

the viability outcomes listed in Figure 3.8-1. They would not contribute to a negative trend in 

viability on the Okanogan-Wenatchee National Forest for ruffed grouse or beaver. 

Mule Deer

Regulatory Framework

The Okanogan identifies mule deer as the management indicator species for winter range 

(USDA, 1989, page III-77). The Wenatchee Forest Plan identifies mule deer as the management 

indicators species for shrubs, grass, meadows, thermal and hiding cover (USDA, 1990, page III48). Both plans have standards and guidelines for managing cover levels on summer and winter 

ranges. Details on habitat use, ecology, and amount of winter range habitat on the Forest for 

mule deer are in Wildlife MIS Status Report (2011). The amount of habitat on the Forest is also 

listed in Figure 3.8-1, as is the Forestwide viability determination. 

Affected Environment

Mule deer winter ranges are primarily lower elevation areas where bitterbrush and other shrubs 

exist along with forest habitat to provide both forage and cover. The Bear/Ramsey/Volstead 

and Alta Lake portions of the analysis area contain winter range. Mule deer summer ranges are 

primarily higher elevation areas of forested and alpine habitats. The Pasayten wilderness, Lake 

Chelan-Sawtooth wilderness, North Cascades, Sawtooth Backcountry, and Middle Methow areas 

of the analysis area contain summer range. 

Environmental Consequences

Direct, Indirect, and Cumulative Effects

The proposed outfitter-guide activities would have no effect on thermal or hiding cover levels 

for deer. Those activities that would occur on winter range in Bear/Ramsey/Volstead or Alta 

Lake would occur during summer and fall.

During the fall hunting season outfitter-guides take hunters into the analysis area. Deer hunting 

is regulated by the Washington Department of Fish and Wildlife. Hunting has not been 
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identified as a limiting factor for deer herds in the analysis area. The proportion of deer hunters 

in the area that use an outfitter-guide is small.

Some outfitter-guides have placed salt blocks at camps for livestock and also for mule deer. 

Having salt available keeps deer from chewing on saddles, reins, and other leather items which 

are salty from sweat. This has resulted in some deer habituating to camps and losing caution 

around people. Placing salt for deer can change habitat use patterns and can result in deer 

habituating to people (O’Neil et al. 2001). This is affecting a small number of deer in a limited 

area. 

The alternatives include mitigation to limit establishing new camps (1.g), prohibit feeding 

wildlife (11.a), require storage of food in a manner that makes it unavailable to wildlife (11.c), 

and require salt to be applied in such a manner to minimize wildlife attraction (11.f). These 

measures would greatly reduce the potential for deer to habituate to outfitter camps, though 

private parties may still continue the practice.

The spatial boundary for the cumulative effects analysis is the Methow River watershed, the 

portions of the Ashnola, Pasayten and Skagit River watersheds on the Methow Valley Ranger 

District, and the portion of the Chelan District north of Lake Chelan. The temporal boundary is 

from the early 1900s through 2023, when the 10 year permits would expire, and the effects to 

deer from outfitter-guide use would cease.

Alternatives 1, 2, 3, and 4

The outfitter-guide activities proposed in each of the alternatives would have no effect on mule 

deer winter range or summer range cover levels. Few of the trails and camps used by outfitterguides are in mule and white-tailed deer winter range. Those in winter range are not used by 

the outfitter-guides when deer are there during winter. The project would not affect the health 

of mule and white-tailed deer populations.

Consistency Findings

Each of the four alternatives considered in this project would be consistent with the Okanogan 

and Wenatchee Forest Plans for managing mule and white-tailed deer winter range habitats 

because no habitat would be changed. They would not change the viability outcomes listed in 

Figure 3.8-1. They would not contribute to a negative trend in viability on the OkanoganWenatchee National Forest for mule deer or white-tailed deer.

Mountain Goats and High Elevation Meadows

Regulatory Framework

The Wenatchee Forest Plan identifies mountain goats as a management indicator species with

standards and guidelines for managing cover levels, roads, and human activities in mountain 

goat ranges. Details on habitat use, ecology, and amount of habitat on the Forest for mountain 

goat are in Wildlife MIS Status Report (2011). The amount of habitat on the Forest for this 

species is also listed in Figure 3.8-1. 
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Although mountain goats are not an MIS on the Okanogan National Forest, a specific 

management area prescription from the Forest Plan applies to these animals. All of the 

mountain goat habitat allocated to this management prescriptions falls within the permit areas 

for pack and saddle outfitter guides. The only standard and guidelines pertaining to pack and 

saddle stock use prohibits new trail access that encourages use during the kidding and wintering 

season. 

Affected Environment

Mountain goats use cliff habitats at lower elevations during the winter, and in summer and fall 

utilize high elevation meadows and peaks. Mountain goats inhabit all portions of the analysis 

area except the Bear/Ramsey/Volstead and Alta Lake areas. In addition to mountain goats, 

there are a number of bird and mammal species that rely on high elevation meadows for food 

and/or cover (O’Neil et al. 2001). The white-tailed ptarmigan, American pipit, and horned lark 

are examples of birds that feed and nest on the ground in high elevation meadows (Martin 

2001). Hoary marmots and pikas are other examples of mammals that forage on the grasses 

and forbs in high elevation meadows, and, like mountain goats, take refuge on adjacent rock 

features such as talus and cliffs (Martin 2001). High elevation meadows are distributed 

throughout the analysis area. The south and east facing slopes of most major ridges have this 

habitat type. There are 196,444 acres of alpine/subalpine meadows in the analysis area.

Most of the high elevation meadows in the analysis area were grazed by domestic sheep in the 

early 1900s. Some areas were so heavily grazed that the effects are still evident (Range section 

of Chapter 3). From 1995 to present, domestic livestock grazing in this area has been limited to 

recreational users and outfitter-guide activities. 

In August 2000 a Forest Service administrative review team found that some meadows in the 

Spanish Camp area of the Pasayten Wilderness were still recovering from past over-grazing by 

domestic herds of sheep and cattle (USDA Forest Service 2000c). Evidence of trailing, bedding, 

and over-grazing was still apparent in some areas. Refer to Appendix C for a summary of the 

review team’s findings.

Grazing by domestic livestock shortens the height of the grass/forb layer which decreases 

vegetative structure. Heavy grazing reduces security and nesting cover and can increase the 

susceptibility of small mammals and birds to predation. It also reduces the amount of forage, 

and, if excessive, can result in the establishment of invasive plant species. On the other hand, 

grazing can stimulate growth of shrubs and small trees and rejuvenate perennial bunchgrasses. 

The altered grass/forb layer can affect different wildlife species in different ways. A literature 

review on the effects of livestock grazing on songbirds showed that some bird species respond 

positively to grazing, some negatively, and for others results were mixed or uncertain (Bock et 

al. 1993). Ivey (1996) reviewed literature and found the same for the effects of grazing on small 

mammals. Generally, species considered to be habitat generalists are not negatively impacted 

by grazing while species that are habitat specialist are more sensitive to impacts. In terms of 

species that utilize high elevation meadows, the horned lark has shown a positive response to 

grazing while the Lincoln’s sparrow has shown a negative response (Bock et al. 1993). Deer mice 

respond positively to grazing, while voles and lemmings are dependent on good ground cover 

and can be negatively affected (Johnson 1981, Kauffman et al. 1981, Oldemeyer and AllenJohnson 1988).
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Most outfitter-guide camps are located near meadows. The abundant grasses and forbs provide 

forage for the outfitter horses, mules, burros, or llamas. Small meadows surrounded by dense 

forest are susceptible to overgrazing. This has occurred in the past when stock were kept in 

these small meadows too long. Loose grazing of pack and saddle recreational stock in recent 

years has allowed stock to disperse and lessen the impacts.

Some wildlife species would likely not find suitable forage or cover at overused sites or near 

camps when they are occupied by humans. However, outside of localized sites the majority of 

these habitats receive little, if any, domestic grazing pressure and retain the structure and 

ground cover necessary to provide wildlife habitat. During the habitat review in the Spanish 

Camp area in August 2000 and during a field trip in August 2011 (J. Rohrer, 2011 field notes, 

analysis file), it was found that the existing amount of recreational grazing use (including 

outfitter-guide use) was, with a few notable exceptions, not substantially altering the structure 

or function of the high elevation meadows as food and cover for wildlife. Popular camp areas, 

such as the immediate areas around Spanish Camp cabin and Remmel Lake, had been grazed 

enough to reduce the cover value for ground nesting birds and small mammals. However, 

outside of these small impacted sites and away from trails, meadows were in good to excellent 

shape and showed little, if any, evidence of livestock grazing. Grasses and forbs provided both 

food and cover. Currently, the portions of the analysis area that receive the most pack and 

saddle use are the Spanish Camp/Remmel Lake area and Sheep Mountain area. Grass was 

measured in August 2010 near an outfitter camp in the Remmel Lake area and it was estimated 

that utilization was 17.5%. Forest Plan standards and guides for grazing utilization allow 45-55% 

utilization depending on the meadow type (Chapter 3 Range). 

Environmental Consequences

Direct and Indirect Effects

Alternative 1

Outfitter-guide stock would not graze in the analysis area. Use by public stock would continue. 

The meadows around existing camp sites would likely continue to be used, but by fewer stock 

than in the past. There would be 24,420 pack and saddle stock visitor days in the analysis, which 

would be 15% lower than the current level. This alternative would result in a decrease in the 

amount of meadow habitat being grazed by livestock. Sites still showing evidence of past overgrazing would recover slightly quicker under this alternative. The overall amount of meadow 

habitat in the analysis area negatively impacted by livestock use would be small, and none of it 

would be from pack and saddle outfitter guides. Abundant habitat for mountain goats and 

other meadow-dependent wildlife exists away from these recreation sites, so populations as a 

whole would be largely unaffected. Alternative 1 would not change the viability outcome listed 

for mountain goat in Figure 3.8-1. It would not contribute to a negative trend in viability on the 

Okanogan-Wenatchee National Forest for mountain goat.
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Alternative 2

Outfitter-guide livestock would continue to graze meadows near camp sites in the analysis area. 

There would be a total of 29,040 pack and saddle stock visitor days in the analysis area, and 

4,620 would be associated with the outfitter-guides, representing a 4% increase in outfitterguide use and a 0.6% increase in total pack and saddle stock use. Meadows adjacent to existing 

camps would continue to be grazed at approximately the same intensity as in the recent past. 

Impacts to meadow habitat would be limited to a few heavily used sites and occurring on a small 

portion of the landscape. This alternative includes an amendment that would allow the use of 

established campsites that are within 200 feet of meadows, lakes, and streams in the Pasayten 

and Lake Chelan-Sawtooth wilderness areas. 

Mitigation measures would limit use to existing trails in the wilderness (6.a), and prevent 

picketing of stock overnight in alpine meadows (8.d), which would be highly effective in limiting 

impacts in meadows. The amount of outfitter-guide use proposed in Alternative 2 would not 

substantially impact meadow habitat in the analysis area. A slow recovery of past heavy use by 

sheep and cattle should continue. 

Abundant habitat for mountain goats and other meadow-dependent wildlife is present away 

from heavily used recreation sites, so populations as a whole would be largely unaffected. 

Under this alternative, outfitter-guides are restricted to existing trails so no new trail access 

would be created that encourages use during the winter or kidding season. Alternative 2 would 

not change the viability outcome listed for mountain goat in Figure 3.8-1. It would not 

contribute to a negative trend in viability on the Okanogan-Wenatchee National Forest for 

mountain goat or other species dependent on high elevation meadows.

Alternative 3

Outfitter-guide stock would continue to graze meadows near camp sites in the analysis area. 

There would be a total of 27,080 pack and saddle stock visitor days in the analysis area, and 

2,660 would be associated with the outfitter-guides, representing a 40% decrease in outfitterguide use and a 6% decrease in total pack and saddle stock use. 

This alternative includes a Forest Plan amendment that would reduce the wilderness party size 

to 12 people and stock combined. It includes a Forest Plan amendment that would allow 

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

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

Chelan-Sawtooth wilderness areas. The reduced use and reduction of party size to 12 

heartbeats would reduce impacts to a slightly greater degree compared to Alternative 2 and to 

existing conditions. Meadows adjacent to existing camps would continue to be grazed but at 

decreased intensity from the recent past. Impacts to meadow habitat would be limited to a few 

heavily used sites and occurring on a small portion of the landscape. 

Mitigation measures would limit use to existing trails in the wilderness (6.a), and prevent 

picketing of stock overnight in alpine meadows (8.d) which would be highly effective in limiting 

impacts in meadows. 
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Abundant habitat for mountain goats and other meadow-dependent wildlife away from heavily 

used recreation sites is available, so these species as a whole would be largely unaffected. 

Under this alternative, outfitter-guides are restricted to existing trails so no new trail access 

would be created that encourages use during the winter or kidding season. Alternative 3 would 

not change the viability outcome listed for mountain goat in Figure 3.8-1. It would not 

contribute to a negative trend in viability on the Okanogan-Wenatchee National Forest for 

mountain goat or other species dependent on high elevation meadows.

Alternative 4

Outfitter-guide livestock would continue to graze meadows near camp sites in the analysis area. 

There would be a total of 31,136 pack and saddle stock visitor days in the analysis area, and 

6,700 would be associated with the outfitter-guides, representing a 50% increase in outfitterguide use and an 8% increase in total pack and saddle stock use. A large portion of the increase 

would be in day rides in the Alta Lake and North Cascades areas which entails no overnight 

grazing of stock. 

This alternative includes an amendment that would allow the use of established campsites that 

are within 200 feet of meadows, lakes, and streams in the Pasayten and Lake Chelan-Sawtooth 

wilderness areas. Meadows adjacent to existing camps would continue to be grazed and at a 

higher intensity than in the recent past. Impacts to meadow habitat would still be limited to a 

few heavily used sites. Use at those sites would likely expand to adjacent areas, however even 

this expanded use would be occurring on a small portion of the landscape. 

Mitigation measures would limit outfitter-guide use to existing trails in the wilderness (6.a), and 

prevent picketing of stock overnight in alpine meadows (8.d) which would be highly effective in 

limiting impacts to meadows. 

The amount of outfitter-guide use proposed in Alternative 4 would not substantially impact 

meadow habitat in the analysis area. A slow recovery of past heavy use by sheep and cattle 

should continue. Abundant habitat for mountain goats and other meadow-dependent wildlife is 

present away from heavily used recreation sites, so populations as a whole would be largely 

unaffected. Under this alternative, outfitter-guides are restricted to existing trails so no new 

trail access would be created that encourages use during the winter or kidding season. 

Alternative 4 would not change the viability outcome listed for mountain goat in Figure 3.8-1. It 

would not contribute to a negative trend in viability on the Okanogan-Wenatchee National 

Forest for mountain goat or other species dependent on high elevation meadows.

Cumulative Effects

The spatial boundary for the cumulative effects analysis is the analysis area as defined in 

Chapter 1. The temporal boundary is from the early 1900s through 2023, when the 10 year 

permits would expire, and the effects from these permits to mountain goats would cease.

Past Actions

Past activities in the analysis area that affected meadow habitats include grazing by outfitterguide livestock, grazing by general public stock, commercial livestock grazing, wildfire, general 

recreational use, and wildfire suppression. Effects from historic grazing by sheep and cattle 

were discussed in the affected environment above and in the Range section of this chapter. 
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Past wildfire suppression may have reduced the amount of meadow habitat in the analysis area, 

since periodic fires can keep conifer trees from meadow encroachment. Conversely, some of 

the recent, large wildfires may have enlarged some meadows by killing encroaching conifers. It 

is not known how much this has affected meadow habitat in the analysis area.

Present Actions

Present activities in the analysis area that affects meadow habitats include grazing by general 

public stock, commercial livestock grazing, and wildfire suppression. There are several active, 

commercial livestock allotments in the analysis area (Chapter 3 Range). Forage utilization by the 

cattle and sheep on these allotments is closely monitored to not remove more than 45-55% of 

the current annual growth of grasses/forbs. Meadow enlargement, creation, or enhancement 

from wildfires is more likely to occur now than it was in the past.

Reasonably Foreseeable Future Actions

Reasonably foreseeable future actions in the analysis area that may affect meadow habitats are 

a continuation of the present actions. Use of the analysis area, especially the North Cascades 

Highway Corridor, by private recreationists is predicted to increase. Managing wildfire for 

resource benefits would continue to be an option in the Pasayten and Lake Chelan-Sawtooth 

Wilderness Areas and may become an option in non-wilderness portions of the analysis area. 

Meadow enlargement, creation, or enhancement from wildfires is more likely to occur in the 

future than it was in the past.

Alternatives 1, 2, 3, and 4

When considered in conjunction with other activities affecting meadow habitat, each of the 

alternatives would potentially degrade habitat for mountain goats and other meadowdependent wildlife in and around campsites. Habitat for mountain goats and other meadowdependent wildlife is abundant away from these sites, so populations as a whole would be 

largely unaffected.

Consistency Findings

Each of the four alternatives considered in this project would be consistent with the Wenatchee 

Forest Plan for managing mountain goat habitats. Cover levels and roads would not be affected 

by these alternatives, and human use would remain the same since outfitter-guide use would be 

restricted to existing trails and camps. They are also consistent with the Okanogan Land and 

Resource Management Plan Mountain Goat management area prescription since no new trails 

could be created by pack and saddle outfitter-guides. They would not change the viability 

outcome listed for mountain goat in Table 3.8-1. They would not contribute to a negative trend 

in viability on the Okanogan-Wenatchee National Forest for mountain goat.

Elk

Regulatory Framework

Elk are a Management Indicator Species in the Wenatchee Forest Plan, however standards and 

guidelines specify that winter ranges on the portion of the analysis area on the Chelan Ranger 

District (all Wenatchee National Forest System Lands north of the Wenatchee River) will be 
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managed for deer, (Wenatchee Forest Plan IV-114). According to the FEIS for the Forest Plan 

(FEIS III-51), the Washington Department of Wildlife has established management objectives 

that maintain or increase elk populations south of US. Highway 2, but reduce populations north 

of the highway. The purpose of the management strategy north of U.S. Highway 2 is to avoid 

damage to orchards from wintering elk. Elk are rarely present in the portion of the analysis area 

on the Chelan Ranger District, and are not a management priority there. They will not be 

addressed further in this analysis. 

Consistency Findings

The proposed alternatives would not impact summer cover for elk and because winter ranges 

on the Wenatchee portion of the National Forest are not managed for elk, all alternatives would 

be consistent with management direction for elk.

LANDBIRDS

Regulatory Framework

The Landbird Strategic Plan (USDA Forest Service 2000a) set goals to provide habitat for 

sustainable landbird populations. The guidance in the 2000 Plan is to be considered in all Region 

6 Forest Service actions. In addition, Executive Order 13186, 66 Fed. Reg. 3853 (2001) 

Responsibilities of Federal Agencies to Protect Migratory Birds, along with the Memorandum of 

Understanding between the USDA Forest Service and the US Fish & Wildlife Service to Promote 

the Conservation of Migratory Birds (2008) require proposed federal actions to be evaluated for 

effects on migratory birds. 

The Partners in Flight Conservation Strategy for Landbirds of the East-Slope of the Cascades 

Mountains in Oregon and Washington (Altman 2001) lists priority habitats, habitat attributes, 

focal species, and management considerations that are appropriate for birds in the analysis 

area. Landbird habitat attributes that may be impacted by outfitter-guide activities are snags, 

meadows or forest openings, and wetlands. The impacts to these habitats are addressed above 

in Primary Cavity Excavators, Ruffed Grouse and Beaver, and Mountain Goat sections.

Consistency Findings

Each of the four alternatives considered in this project would be consistent with the Landbird 

Strategic Plan, Executive Order 13186, and the 2008 MOU. Migratory bird habitat was 

evaluated and potential for incidental take was minimized. Habitat for landbirds would be 

affected in and around camps used by outfitted and non-outfitted pack and saddle stock, 

through loss of snag and downed wood debris habitat, trampling and loss of vegetation at trail 

crossings and watering sites, and grazing in meadows. The effects would be limited to a very 

small percentage of these habitats and abundant habitat would continue to exist away from 

camps, trails, and grazing areas. Populations as a whole would be largely unaffected.
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LATE SUCCESSIONAL RESERVES

Regulatory Framework

The Okanogan and Wenatchee Forest Plans were amended by the Northwest Forest Plan, which 

included designation of late-successional reserves (LSR) and established standards and 

guidelines for their management.

Affected Environment

There are 210,025 acres of LSR in the analysis area. This includes portions of the Upper 

Methow, Twisp River, and Sawtooth LSRs.

Environmental Consequences

Direct, Indirect, and Cumulative Effects

Alternatives 1, 2, 3, and 4

None of the alternatives would have any effect on LSRs or habitat since pack and saddle stock 

recreation would not result in any alteration of forest stands. They would not retard or prevent 

attainment of LSR objectives. 

Consistency Findings

All alternatives would be consistent with the standards and guidelines for LSRs in the amended 

Forest Plans because the alternatives would have a neutral effect on the LSR.

ENDANGERED, THREATENED AND SENSITIVE SPECIES

The following list of endangered, threatened and sensitive wildlife species are known or 

suspected to occur on the Okanogan-Wenatchee National Forest.

Endangered or Threatened

gray wolf

lynx

grizzly bear

northern spotted owl

marbled murrelet (project area outside range)

There is designated Critical Habitat for northern spotted owl and lynx within the analysis area.

Sensitive Sensitive Invertebrate Species

bald eagle astarte fritillary

California mtn. kingsnake meadow fritillary

common loon freija fritillary

fisher Labrador sulphur

gray flycatcher lustrous copper
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great gray owl melissa arctic

harlequin duck great basin fritillary

Lewis’ woodpecker tawny-edged skipper

Moose Peck’s skipper

Mountain goat zigzag darner

northwestern pond turtle subarctic darner

pallid bat subarctic bluet

peregrine falcon

sandhill crane

sharptail snake

sharp-tailed grouse

striped whipsnake

Townsend’s big-eared bat

Western gray squirrel

white-headed woodpecker

wolverine

Endangered or Threatened

Gray Wolf

Regulatory Framework

Management guidance for gray wolves and their habitat is found in Forest Service Manual 2670 

and the Endangered Species Act, as amended. A biological assessment (BA) is required for all 

projects planned, funded, executed, or permitted by the USDA Forest Service (FSM 2672.4, 

USDA Forest Service 2005b). If the BA concludes that the project that may affect an endangered 

or threatened species, the Forest Service must consult with the U.S. Fish and Wildlife Service. 

Although the Okanogan Forest Plan requires that recovery plans be followed, no recovery plan 

has yet been developed for wolves in the state of Washington.

Affected Environment

Gray wolves were Federally listed as an endangered species in 1978. Wolves are wide-ranging 

predators that can exist in a wide variety of habitat types. They are habitat generalists in terms 

of terrain and vegetation (Boyd 1999, Oakleaf et al. 2006). They are not wilderness dependent, 

but their survival depends on the availability of cover and relatively secure areas that allow 

them to avoid humans and escape persecution (Carroll et al. 2003). To successfully inhabit an 

area they require a year-round prey base of wild ungulates (Boyd et al. 1994, Fritts and Carbyn 

1995). Mule deer are likely the main prey item for wolves in the Methow Valley since they are 

by far the most abundant ungulate. White-tailed deer, moose, mountain goats, beavers, wild 

turkeys, marmots, and other small mammals are probably preyed on also.

The basic social unit of a wolf population is a mated pair, and a wolf pack is generally a mated 

pair along with one or more generations of their offspring (Mech 2000, Mech and Boitani 2003). 

Pups are born at a natal den in spring (generally mid-to late April) and remain there with their 
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mother for about 2 months (Mech 1970, Boyd 1999). During this time any disturbance that 

results in the female leaving the den may expose the pups to predation or inclement weather. 

The sensitivity of females to human disturbances at den sites varies greatly among individuals 

(Boyd 1999). From the den the pups are moved to a rendezvous site, where they remain, 

usually under the care of 1 adult, while other adult members of the pack hunt. Wolf packs vary 

widely in the number of rendezvous sites they may use in a summer and the amount of time 

spent at them (Boyd 1999). Frame et al. (2007) tested the response of wolves to human 

disturbance at both den and rendezvous sites and found that though the wolves may have 

moved in response to the disturbance, it did not reduce reproductive success nor effect the reuse of the sites in subsequent years. For more detailed information on gray wolf biology see 

Mech and Boitani (2003) or the Washington Department of Fish and Wildlife website at 

http://wdfw.wa.gov/wlm/diversty/soc/gray_wolf/. 

Gray wolves are believed to occur throughout the analysis area, but confirmed sightings were 

not common until 2008. In early 2008 a series of wolf sightings and photographs resulted in the 

documentation of the Lookout Pack in the Methow Valley, the first wolf pack known to exist in 

Washington since the 1930s. To date, this is the only known reproductive wolf pair in the 

analysis area. The Lookout Pack has inhabited areas during the summer and fall that are within 

the Middle Methow, Sawtooth Backcountry, and Lake Chelan-Sawtooth wilderness portions of 

the analysis area. 

Environmental Consequences

Potential effects of proposed outfitter-guide activities on wolves include:

disturbance to a natal den or rendezvous site;

outfitter-guide hunting client accidentally or intentionally shooting;

reduction of prey availability due to outfitter-guide deer hunting clients.

Current outfitter-guide activities could disturb a wolf den or rendezvous site. However, 

disturbance would more likely be caused by use occurring off maintained trails and outside of 

popular areas since wolves tend to establish den and rendezvous sites in remote areas. There 

are no known den sites in the analysis area. The known den site for the Lookout Pack and the 

known rendezvous sites are outside the analysis area.

Coyote hunting is allowed in the analysis area. Hunter misidentification of wolves as coyotes is 

not known to have happened in the North Cascades, but it is a possibility. Hunting is regulated 

by the Washington Department of Fish and Wildlife. The annual big game hunting regulation 

pamphlet contains information on how to distinguish coyotes from wolves. 

During the fall hunting season outfitter-guides take hunters into the analysis area. Deer hunting 

is regulated by the Washington Department of Fish and Wildlife. Hunting has not been 

identified as a limiting factor for deer herds in the analysis area. The proportion of deer hunters 

in the area that use an outfitter-guide is small.
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Direct and Indirect Effects

Alternative 1

Outfitter-guide stock would not use the analysis area. Use would continue by public stock users. 

There would be 24,420 pack and saddle stock visitor days in the analysis, which would be 15% 

lower than the current level. Alternative 1 would have “no effect” on the gray wolf because no 

pack and saddle outfitter-guide permits would be issued.

Alternative 2

Outfitter-guide livestock would continue to use the analysis area. There would be a total of 

29,040 pack and saddle stock visitor days in the analysis area, and 4,620 would be associated 

with the outfitter-guides, representing a 4% increase in outfitter-guide use and a 0.6% increase 

in total pack and saddle stock use. This alternative would not result in any increases in 

motorized access or new trail construction. It would not result in unacceptable reductions to 

wolf prey species. 

The alternative includes mitigation measures that limit outfitter-guides from establishing new 

camps (1.g) and from creating new travel routes (6.a), so the potential for disturbance to den or 

rendezvous sites would be low. To reduce the possibility of species misidentification, this 

alternative includes mitigation (11.b) that would require the outfitter-guides to make clients 

aware of this issue and the consequences of shooting a wolf. Mitigation measure 6.b would be 

effective since it would be part of the operation plans, with compliance required by the special 

use permit; should outfitters be found in non-compliance permit action would be taken. 

Alternative 2 “may effect, but would not likely adversely affect” the gray wolf.

Alternative 3

Outfitter-guide stock would continue to use the analysis area. There would be a total of 27,080 

pack and saddle stock visitor days in the analysis area, and 2,660 would be associated with the 

outfitter-guides, representing a 40% decrease in outfitter-guide use and a 6% decrease in total 

pack and saddle stock use. The proposed outfitter-guide activities would not result in any 

increases in motorized access or new trail construction. They would not result in unacceptable 

reductions to wolf prey species. 

The alternative includes mitigation measures that limit outfitter-guides from establishing new 

camps (1.g) and from creating new travel routes (6.a), so the potential for disturbance to den or 

rendezvous sites would be low. To reduce the possibility of species misidentification, this 

alternative includes mitigation (11.b) that would require the outfitter-guides to make clients 

aware of this issue and the consequences of shooting a wolf. This mitigation measure, number 

11.b would be effective since it would be part of the operation plans, with compliance required 

by the special use permit. Alternative 3 “may effect, but would not likely adversely affect” the 

gray wolf.

Alternative 4

Outfitter-guide livestock would continue to use the analysis area. There would be a total of 

31,136 pack and saddle stock visitor days in the analysis area, and 6,700 would be associated 

with the outfitter-guides, representing a 50% increase in outfitter-guide use and an 8% increase 

in total pack and saddle stock use. This alternative would not result in any increases in 
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motorized access or new trail construction. It would not result in unacceptable reductions to 

wolf prey species. 

The alternative includes mitigation measures that limit outfitter-guides from establishing new 

camps (1.g) and from creating new travel routes (6.a) so the potential for disturbance to den or 

rendezvous sites would be low. To reduce the possibility of species misidentification, this 

alternative includes mitigation (11.b) that would require the outfitter-guides to make clients 

aware of this issue and the consequences of shooting a wolf. This mitigation measure, number 

11.b would be effective since it would be part of the operation plans, with compliance required 

by the special use permit. Alternative 4 “may effect, but would not likely adversely affect” the 

gray wolf.

Cumulative Effects

The spatial boundaries for the cumulative effects analysis are the Bear Management Units 

described in the grizzly bear analysis below. The temporal boundary is from early 1900s through 

2023, when the 10 year permits would expire.

Past Actions

Past actions that affected gray wolves in the analysis area included shooting, trapping, and 

poisoning individual wolves to the point that they were extirpated from the state of Washington 

by the 1930s. 

Present and Foreseeable Future Actions

Present actions that may affect gray wolves in the analysis area include recreational use that 

might result in human disturbance to natal den or rendezvous sites, accidental or intentional 

shooting, permitted grazing by domestic livestock (Chapter 3 Range), and large wildfires that 

may temporarily reduce wolf prey species.

Alternative 1

Alternative 1 and all past, present, and reasonably foreseeable future actions would have no 

cumulative effect on gray wolf because no pack and saddle outfitter-guide permits would add 

incremental effects.

Alternatives 2, 3, and 4

When considered in conjunction with other activities affecting gray wolves, Alternatives 2, 3, 

and 4 may affect, but would not likely adversely affect gray wolves. Shooting, trapping, and 

harassing wolves are illegal in Washington. Disturbance to a den or rendezvous site is always a 

possibility on public lands but there are no known wolf den or rendezvous sites in the analysis 

area. If a wolf den or rendezvous site was discovered in the analysis area, appropriate actions 

would be taken in consultation with other wildlife agencies. Domestic grazing allotments are 

managed to avoid or minimize conflicts between livestock and wolves. 
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Consistency Findings

Each of the four alternatives considered in this project would be consistent with Forest Service 

Manual 2670 (USDA Forest Service 2005b) and the Endangered Species Act, as amended 

because a Biological Assessment has been completed, and consultation with the U.S. Fish & 

Wildlife Service is forthcoming. No federal recovery plan has yet been developed for the gray 

wolf in Washington State.

Grizzly Bear 

Regulatory Framework

Management guidance for grizzly bears and their habitat is located in the Forest Service Manual 

2670 (USDA Forest Service 2005b) and the Endangered Species Act, as amended. The Okanogan 

Forest Plan additionally requires the Forest to follow any recovery plans. A BA is required to be 

prepared for all projects that are planned, funded, executed, or permitted by the USDA Forest 

Service (FSM 2672.4). If the BA concludes that the project that may affect an endangered or 

threatened species, the Forest Service must consult with the U.S. Fish and Wildlife Service. The 

Grizzly Bear Recovery Plan (USDI Fish and Wildlife Service 1997) incorporates the Interagency 

Grizzly Bear Guidelines (USDA Forest Service 1986) which includes specific guidelines for 

managing grizzly bears and their habitat. Those pertinent to this project include:

a) Proposed outfitter-guide pack and saddle stock grazing areas and camps will be 

evaluated to determine their compatibility with grizzly bear habitat requirements.

b) For dispersed recreation all human and prepared livestock and pet foods and human 

refuse will be made unavailable to grizzly bears through proper storage, handling and 

disposal.

Affected Environment

The analysis area is within the North Cascades Grizzly Bear Recovery Zone. The number of 

grizzly bears in the 6,473,314 acre recovery zone is estimated to be less than 50, possibly as few 

as 10-20 (Almack et al. 1993). There have been 5 confirmed reports of grizzly bears on the 

Methow Valley Ranger District; 2 in the Pasayten Wilderness and 3 in non-wilderness areas. 

There has been one confirmed report in the Lake Chelan-Sawtooth Wilderness on the Chelan 

side of the mountains.

The search for food dictates grizzly bear movements and habitat use (USDI 1993). They are 

omnivorous and opportunistic feeders that will prey, scavenge, or forage on almost any 

available food including rodents, ungulates, carrion, garbage, grasses/forbs, nuts, roots, berries, 

bulbs, fungi, and tree cambium. In spring they typically will be in lower elevation areas where 

they forage on herbaceous plants as new shoots emerge, and through spring and summer follow 

plant phenology up to higher elevations. Important habitats are riparian areas, deer winter 

ranges, meadows, avalanche chutes, whitebark pine stands, and areas with berry-producing 

shrubs. Grizzly bears enter winter dens in late October to November and emerge in late March 

to early May (IGBC 1987). In the North Cascades, grizzly bear denning habitat is suspected to be 

high elevation, steep, northerly aspect slopes that accumulate deep snow (Almack et al. 1993). 

There are no known grizzly bear den sites in the analysis area. Denning habitat was not 
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identified as a limiting habitat component in the North Cascades recovery zone (Almack et al. 

1993). 

Hunting of black bears is regulated by the Washington Department of Fish and Wildlife. Hunter 

misidentification of a grizzly bear as a black bear is not known to have happened in the North 

Cascades, but it is a possibility. It has occurred in other grizzly bear recovery areas. If it were to 

occur it would most likely happen during the black bear hunting seasons in the late summer and 

fall. Several of existing Forest Service outfitter-guides take hunters into the backcountry during 

the fall hunting seasons.

Current outfitter-guide activity in the analysis area provides potential for a bear/human 

interaction since camps are in the backcountry. On the Okanogan-Wenatchee National Forest 

all employees, permittees, contractors, and outfitter-guides are required to properly store all 

attractants (eg. human food, prepared livestock feed, human garbage) while on the Forest to 

prevent bears from becoming habituated to human camps and the attractants in them. 

The current pack and saddle stock outfitter-guide activities are not resulting in any structural 

habitat modifications or increases in motorized access. They also are not reducing grizzly bear 

foods. The potential impact of human disturbance to den sites is discountable due to the fact 

that the vast majority of outfitter-guide activities occur outside the denning season. The 

possibility of a hunter accidentally/intentionally shooting a grizzly for a black bear exists, but has

been mitigated with educational efforts.

Environmental Consequences

Potential effects of outfitter-guide activities on grizzly bears include:

Human disturbance to a den or foraging site;

outfitter-guide hunting client accidentally or intentionally shooting a grizzly bear; and

bears accessing food or garbage at an outfitter backcountry camp and becoming food 

conditioned.

Direct and Indirect Effects

Alternative 1

There would be no pack and saddle stock outfitter-guide activity in the analysis area. 

Alternative 1 would have “no effect” on the grizzly bear.

Alternatives 2 , 3 and 4

None of these alternatives would result in any structural habitat modifications or increases in 

motorized access. They would not result in unacceptable reductions to bear prey species or 

forage items (see Ruffed Grouse and Beaver section above for effects to riparian habitat, Mule 

Deer section for effects to deer, and Mountain Goat section above for effects to high elevation 

meadow forage). Outfitter-guides would not be permitted to establish new camps or trails. The 

potential effects of human disturbance to den sites would be insignificant and discountable due 

to the fact that the outfitter-guide activity would occur outside the den season. Several of the 

outfitter-guides take hunters into the backcountry during the fall hunting seasons. To reduce 

the possibility of species misidentification, these alternatives include mitigation (11.b) that 
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requires the outfitter/guides to make their clients aware of this issue, of the differences 

between black and grizzly bears, and the consequences of shooting a grizzly bear. Mitigation 

should be highly effective in preventing accidental or intended shooting of a grizzly bear.

Outfitter-guide activity would provide potential for a bear/human interaction. The proposed 

permits include backcountry camping. To minimize the potential for bears to access human 

food, garbage or other attractants, these items are required to be stored in a bear-resistant 

manner (mitigation measures 11.c). In addition, feeding of any wildlife would be prohibited 

(11.a) and any negative encounters with bears would be required to be reported to the Forest 

Service (11.d). The potential for a bear getting into a backcountry camp and becoming food 

conditioned would be mitigated with the highly effective requirement for proper storage. 

Alternatives 2, 3 or 4 “may effect, but would not likely adversely affect” the grizzly bear.

Cumulative Effects

The spatial boundaries for the cumulative effects analysis are the Bear Management Units that 

overlap the analysis area. The temporal boundary is from the early 1900s through 2023, when 

the 10 year permits would expire and effects of the permits would cease.

Past Actions

Past actions that may have affected grizzly bears in the analysis area include shooting, trapping, 

or poisoning individual bears, excessive livestock grazing activities, road and trail construction, 

and displacement from habitat due to human use of roads or trails.

Present Actions

Present actions that may affect grizzly bears include human disturbance to a den or foraging 

site, accidental or intentional shooting/trapping, timber sale activities, livestock grazing 

activities, accessing improperly stored food or garbage at camp sites and becoming habituated 

to human presence and food, and displacement from habitat due to human use of roads or 

trails. Habitat displacement is measured by calculating the amount of core area in bear 

management units (BMU). 

Core area is any habitat that is more than 500 meters from a road, motorized trail, or high use, 

nonmotorized trail. High use for nonmotorized trails is defined as greater than 20 parties per 

week (IGBC 1987). Examples of high use, nonmotorized trails in the study area include but are 

not limited to the Pacific Crest Trail, Middle Fork Pasayten River, Hidden Lakes, Andrews Creek, 

and Chewuch River trails. Figure 3.8-3 indicates the amount of core area and the number of 

outfiitter-guide camps in each of the BMUs in the analysis area.

A BMU with more than 70% core area is considered to have a low level of human influence, 55 

to 70% is considered to have a moderate level, and less than 55% is a high level (Gaines et. al. 

2003). Seventy-four percent of the camps are in BMUs with an otherwise low level of human 

influence.
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Figure 3.8-3. Number of Camps in Grizzly Bear Core Area, by BMU.

Bear Management 

Unit

Acres % Core Area # of Camps

Early 

Season

Mid/Late 

Season

Ashnola 177,945 99 97 35

Granite Creek 148,665 88 84 5

Libby Creek 147,910 49 47 4

Lower Chelan 206,308 84 77 20

Lower Chewuch 194,880 41 41 0

Middle Methow 142,635 18 18 1

Pasayten 183,106 99 98 15

Salmon 73,976 44 34 0

Stehekin 107,289 99 97 0

Upper Chelan 227,250 97 87 21

Upper Chewuch 149,281 93 88 13

Upper Methow 227,353 64 42 20

Upper Toats 111,325 69 66 0

Upper Twisp River 156,966 67 66 14

Reasonably Foreseeable Future Actions

Foreseeable future actions that may affect grizzly bears include human disturbance to a den or 

foraging site, accidental or intentional shooting/trapping, timber sale activities, livestock grazing 

activities, accessing improperly stored food or garbage at camp sites by the public, wildfire and 

wildfire suppression activities, and displacement from habitat due to human use of roads or 

trails.

Alternative 1

Alternative 1 would have no cumulative effects with past, present, and reasonably foreseeable 

future actions on grizzly bears because no pack and saddle outfitter-guide permits would have 

incremental effects.

Alternatives 2, 3, and 4

Alternatives 2, 3, and 4 and all past, present, and foreseeable future actions may affect, but 

would not likely adversely affect grizzly bears and their habitat. Outfitter-guide use would not 

change the amount of core area in any of the alternatives. Additional use that could occur 

under alternatives 2 and 4 would be on trails that are already mapped as high use. Although 

pack and saddle outfitter-guides may take clients to hunt black bears, shooting and trapping 

grizzly bears is illegal in Washington and mitigation measures requiring education and warning. 

Timber sale and grazing activities are regulated and planned to avoid or minimize and mitigate 

impacts to grizzly bears. There have been no reported incidents of grizzly bears getting into 

improperly stored food or garbage in the analysis area.

Consistency Findings

Each of the four alternatives considered would be consistent with Forest Service Manual 2670 

and the Endangered Species Act, as amended. A Biological Assessment has been completed, 

and consultation with the U.S. Fish & Wildlife Service is forthcoming. The proposed project 

would be consistent with the Grizzly Bear Recovery Plan because no core area is reduced, 
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effects to habitat were analyzed, and mitigation measures are included to prevent bear 

habituation.

Lynx

Regulatory Framework

Management guidance for lynx and their habitat is in Forest Service Manual 2670 (USDA Forest 

Sevice 2005b) and the Endangered Species Act, as amended. A BA must be prepared for all 

projects that are planned, funded, executed, or permitted by the USDA Forest Service (FSM 

2672.4). If the BA concludes that the project that may affect an endangered or threatened 

species, the Forest Service must consult with the U.S. Fish & Wildlife Service. Details on habitat 

use, ecology, and amount of habitat on the Forest for lynx are in Wildlife MIS Status Report 

(2011). The amount of habitat on the Forest for this species is also listed in Figure 3.8-1. The 

Lynx Conservation Assessment and Strategy (Ruediger et al. 2000) includes specific conservation 

measures for managing lynx and their habitat. Those that may apply to outfitter-guide pack and 

saddle use are:

1) Manage livestock grazing within riparian areas and willow carrs in lynx habitat to 

provide conditions for lynx and lynx prey (snowshoe hares).

2) Reduce lynx mortalities related to mistaken identification or illegal shooting. 

Affected Environment

Lynx are known to occur on the Methow Valley and Chelan Ranger Districts. Lynx inhabit mesic 

(moist), coniferous forests that have cold snowy winters and provide a prey base of snowshoe 

hares (Ruggiero et al. 2000). On the east side of the Cascade Range lynx primarily inhabit 

subalpine fir, Engelmann spruce, and lodgepole pine forests. They also occur in cool, moist 

Douglas-fir types where they are interspersed with primary vegetation types (Ruediger et al. 

2000). These forest types generally are found above 4,000 feet elevation. Lynx seem to prefer 

areas of low topographic relief (McKelvey et al. 2000, Apps 2000). Lynx distribution is linked to 

that of the snowshoe hare which require forests with low, dense, horizontal structure (Ruggiero 

et al. 2000).

Most of the current pack and saddle stock outfitter-guide activities occur partly in lynx habitats 

except the Alta Lake portion of the analysis area. 

Environmental Consequences

The potential effects of the proposed activities on lynx are the possibility of livestock grazing 

associated with outfitter-guide activities affecting habitat for lynx or snowshoe hares, and an 

outfitter-guide client accidentally or intentionally shooting a lynx. 

Outfitter-guide stock grazing effects to riparian and meadow habitats were discussed above. 

Riparian areas in lynx habitat are used by outfitter guide livestock, but impacts are limited 

primarily to small areas where trail intersect streams. This would be a minor effect to summer 

foraging habitat for snowshoe hares. However, summer foraging habitat is not a limiting factor 
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for snowshoe hares (Hodges 2000). Shrub and tree cover in these riparian areas, which is more 

important for winter snowshoe hare habitat, is altered minimally if at all. 

Hunter misidentification of a lynx as a bobcat occurred in October 1999 when a deer hunter shot 

and killed a lynx near Rainy Pass in the North Cascades Highway Corridor. Bobcat hunting is 

permitted by the Washington State Department of Wildlife. If accidental or intentional shooting 

of a lynx were to occur in association with one of the proposed outfitter permits it would most 

likely happen during big game hunting seasons in the fall. Several of the proposed outfitterguide permits include taking hunters into the backcountry during the fall hunting seasons. 

Effects of human disturbance to lynx have not been studied and are not known, but anecdotal 

observations recorded by some biologists indicate that lynx are tolerant of human disturbance 

(Mowat et al. 2000, Ruggiero et al. 2000).

Direct and Indirect Effects

Alternative 1

There would be no pack and saddle stock outfitter-guide activity in the analysis area so 

Alternative 1 would have “no effect” on lynx.

Alternatives 2, 3, and 4

Neither Alternative 2, 3, nor 4 would result in any structural habitat modifications or increases in 

motorized access. None of the alternatives would result in reductions to lynx prey species. The 

possibility of a hunter accidentally/intentionally shooting a lynx for a bobcat would be mitigated 

with educational efforts (11.b). These alternatives would be consistent with the Lynx 

Conservation Assessment and Strategy because livestock grazing associated with the 

alternatives would not alter habitat for lynx or snowshoe hares and the potential for accidental 

shooting has been mitigated. Alternatives 2, 3, and 4 “may effect, but would not likely 

adversely affect” lynx. They would not change the viability outcome listed for lynx in Figure 3.8-

1. They would not contribute to a negative trend in viability on the Okanogan-Wenatchee 

National Forest for lynx.

Cumulative Effects

The spatial boundaries for the cumulative effects analysis are the Lynx Management Units. The 

temporal boundary is from the early 1900s through 2023, when the 10 year permits would 

expire, and the effects from the permits would cease.

Past Actions

Past actions that may have affected lynx in the analysis area include shooting/trapping/ 

poisoning of individual lynx, excessive livestock grazing activities, timber sale activities, fire 

suppression, and the grooming of snowmobile/ski routes. Past livestock grazing may have 

negatively impacted snowshoe hares, the primary prey for lynx, by overgrazing of riparian areas 

(see Range section). Timber sale activities in lynx habitat have removed security cover for lynx 

and temporarily reduced snowshoe hare habitat. Recent wildfires have created good snowshoe 

hare habitat and therefore good lynx forage habitat. On the other hand, fire suppression in lynx 

habitat prevented the development of good lynx/hare habitat that often occurs after wildfires. 
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The grooming of snowmobile/ski routes has provided easy access into lynx habitat for other 

carnivores that may predate on or compete with lynx.

Present Actions

Present actions that may affect lynx include accidental shooting of individual lynx, timber sale 

activities, fire suppression, and the grooming of snowmobile/ski routes. Snowmobile use may 

impact lynx by providing a compacted snow surface that allows competing predators to access 

lynx habitat. There are 43 lynx analysis units (LAU) on the Methow Valley Ranger District 

portion of the analysis area and 40 of them have snowmobile route density of less than 1 

mi./sq.mi. This is considered a low level of human influence (Gaines et al. 2003). Present and 

future management activities are analyzed using the Lynx Conservation Assessment and 

Strategy (Ruediger et al. 2000).

Reasonably Foreseeable Future Actions

Future foreseeable actions that may affect lynx include accidental shooting of individual lynx, 

timber sale activities, fire suppression, and the grooming of snowmobile/ski routes with effects 

as described in past actions above. Present and future management activities are analyzed 

using the Lynx Conservation Assessment and Strategy (Ruediger et al. 2000).

Alternative 1

Alternative 1 would have no cumulative effects with past, present, and reasonably foreseeable 

future actions on lynx since no pack and saddle outfitter-guide permits would be issued.

Alternatives 2, 3, and 4

When considered in conjunction with other activities affecting lynx and their habitat, 

Alternatives 2, 3, and 4 may affect, but would not likely adversely affect lynx.

Consistency Findings

Each of the four alternatives considered in this project would be consistent with Forest Service 

Manual 2670 (USDA Forest Service 2005b) and the Endangered Species Act, as amended. A 

Biological Assessment has been completed, and consultation with the U.S. Fish & Wildlife 

Service is forthcoming. The proposed project would be consistent with the Lynx Conservation 

and Assessment Strategy because no habitat would be affected and the potential for accidental 

shooting would be mitigated.

Critical Habitat-Lynx

Some of the proposed outfitter-guide activities would occur in critical habitat for lynx. The 

activities proposed in the four alternatives would not alter any forested stands and thus would 

have no effect on proposed critical habitat for lynx.

Marbled Murrelet

Marbled murrelets have never been observed in the analysis area and there is no suitable 

habitat for them in the analysis area.
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Environmental Consequences

Direct/Indirect/Cumulative Effects

Alternatives 1, 2, 3, and 4

Each of the alternatives would have “no effect” on the marbled murrelet.

Designated Critical Habitat-Marbled Murrelet

There is no designated critical habitat for marbled murrelets in the analysis area. All four 

alternatives would have no effect on marbled murrelet critical habitat.

Northern Spotted Owl

Regulatory Framework

Management guidance for northern spotted owls and their habitat is in Forest Service Manual 

2670 (USDA Forest Service 2005b) and the requirements of the Endangered Species Act, as 

amended. A BA is prepared for all projects that are planned, funded, executed, or permitted by 

the USDA Forest Service (FSM 2672.4). If the BA contains a conclusion that the project that may 

affect an endangered or threatened species, the Forest Service consults with the U.S. Fish & 

Wildlife Service. The northern spotted owl recovery plan (USDI 2011) includes specific 

guidelines for managing northern spotted owls and their habitat. Although both the Okanogan 

and Wenatchee Forest Plans had management requirements and standards and guidelines for 

the northern spotted owl, these were replaced by the Northwest Forest Plan in 1994 (USDA, 

USDI 1994).

Affected Environment

Northern spotted owls are known to occur on the Methow Valley and Chelan Ranger Districts. 

Suitable owl habitat in the analysis area is mixed conifer forest below 5,000 feet in elevation 

with large diameter trees, snags, and downed logs, decadence, high canopy closure, and a large 

proportion of Douglas-fir. Their nesting period is considered to be March 1 to July 31. The 

northern spotted owls in this area typically begin nesting in late March and young owls leave the 

nest by mid June. Details on habitat use, ecology, and amount of habitat on the Forest for 

northern spotted owl are in Wildlife MIS Status Report (2011). The amount of habitat on the 

Forest for this species is also listed in Figure 3.8-1. 

Environmental Consequences

The Bear/Ramsey/Volstead portion of the analysis area is outside the range of the northern 

spotted owl. The Alta Lake portion contains no suitable habitat for the northern spotted owl. 

The only potential effect of the proposed activities on northern spotted owls would be from 

human disturbance to a nesting pair. None of the known northern spotted owl nest sites have 

maintained trails through them. In addition, the dense, decadent forested stands that typify 

spotted owl nesting habitat are not conducive to pack and saddle stock outfitting activities. 

Outfitter-guides would not be allowed to establish new camps or trails. Most of the outfitterguide camps are above 5,000 feet in elevation and therefore are not in suitable habitat.
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Direct and Indirect Effects

Alternative 1

This alternative would have “no effect” on northern spotted owls.

Alternatives 2, 3, and 4

These alternatives would not alter any vegetation and thus would have no effect on suitable owl 

habitat or on owl prey species. The proposed activities would occur on existing trails that are 

not near any known northern spotted owl nest sites. 

The alternatives include mitigation measures that limit outfitter-guides from establishing new 

camps (1.g) and from creating new travel routes (6.a) so the potential for disturbance to nest 

sites would be low. These three alternatives "may effect, but would not likely adversely affect" 

the northern spotted owl. They would not change the viability outcome listed for northern 

spotted owl in Figure 3.8-1. They would not contribute to a negative trend in viability on the 

Okanogan-Wenatchee National Forest for northern spotted owl.

Cumulative Effects

The spatial boundary for the cumulative effects analysis is the portion of the analysis area as 

described in Chapter 1 that is west of the Chewuch and Methow Rivers. The temporal boundary 

is from the early 1900s through 2023, when the 10 year permits would expire, and the impacts 

of these permits would cease.

Other activities in the analysis area that may affect northern spotted owls include disturbance to 

a nesting pair by recreationists or management activities, and habitat loss from timber 

management activities, wildfire, and wildfire suppression.

Alternative 1

This alternative would have no cumulative effect on northern spotted owls because no permits 

would incrementally add to effects from other projects.

Alternatives 2, 3, and 4

When considered in conjunction with other past, present, and foreseeable future actions, these 

alternatives may affect, but would not likely adversely affect spotted owls or their habitat. Most 

recreational activities, including pack and saddle outfitter-guide activities, do not occur in the 

forest stand types that spotted owls utilize for nesting. Timber and other management activities 

are planned and implemented to avoid or minimize and mitigate any impacts to northern 

spotted owls.

Consistency Findings

Each of the alternatives considered would be consistent with Forest Service Manual 2670 and 

the Endangered Species Act, as amended. A Biological Assessment has been completed, and 

consultation with the U.S. Fish & Wildlife Service is forthcoming. The proposed project would be 

consistent with the northern spotted owl recovery plan.
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Designated Critical Habitat-Northern Spotted Owl

There are three critical habitat units in the analysis area: WA1, WA2, and WA3. The activities 

proposed in the four alternatives would not alter any forested stands and thus would have no 

effect on northern spotted owl critical habitat.

Sensitive Species

Regulatory Framework

Management guidance for all sensitive species and their habitat is in Forest Service Manual 2670 

(USDA Forest Service 2005b). A BA must be prepared for all projects that are planned, funded, 

executed, or permitted by the USDA Forest Service (FSM 2672.4). A determination of the level 

of impact the project might have on each species listed as sensitive by the Regional Forester 

must be made. The Wenatchee Forest Plan require that actions not jeopardize the continued 

existence of sensitive species and the Okanogan Forest Plan requires the protection of sensitive 

species.

Affected Environment & Environmental Consequences

The proposed outfitter activities would not occur in or adjacent to habitat for California 

mountain kingsnake, sharp-tailed grouse, harlequin duck, northwestern pond turtle, and 

sandhill crane. Sandhill cranes may migrate through the area, but there are no large, wet 

meadow complexes that are known to be used by sandhill cranes. All four alternatives of the 

proposed project would have “no impact” on any of these sensitive species. Since there would 

be no direct or indirect effects, there would be no cumulative effects. The proposed outfitterguide activities could occur in areas inhabited by bald eagles, common loons, fisher, great gray 

owl, gray flycatcher, Lewis’ woodpecker, moose, mountain goat, pallid bat, peregrine falcons, 

sharptail snake, striped whipsnake, Townsend’s big-eared bat, western gray squirrel, whiteheaded woodpecker, and wolverines. 

Bald Eagle

Affected Environment

Bald eagles are known to occur in the Methow Valley and Lake Chelan areas. During winter they 

occur as individuals or in small groups along the Methow River from Winthrop down to the 

mouth and along the lower 6-7 miles of the Chewuch River. The eagles tend to congregate in 

areas with road-killed or winter-killed deer, near livestock calving operations, and along open 

waters that contain fish. There are communal winter roosting areas on non-Forest lands 

adjacent to the Columbia River near the mouth of the Methow River and along the lower 

Methow River. In the last few years, bald eagles have attempted to nest at 3 locations, at least, 

in the Methow Valley; all on private lands, one on the Methow River near the town of Methow, 

one on the Methow River near Winthrop, and one near Moccasin Lake, south of Winthrop. In 

the Lake Chelan area there is a nest on the Stehekin River and two others are suspected to occur 

south of Lake Chelan. All 3 of these are outside the analysis area. 
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There are no known or suspected bald eagle nesting or roosting sites on Forest Service lands in 

the analysis area. The only known bald eagle use on Forest Service lands is on low elevation 

deer winter ranges where they scavenge on winter- or predator-killed deer remains. None of 

the proposed outfitter/guide activities would occur in these areas during winter when eagles are 

present. 

Environmental Consequences

Direct, Indirect, and Cumulative Effects

The spatial boundary for the cumulative effects analysis is the analysis area as described in 

Chapter 1. The temporal boundary is from the early 1900s through 2023, when the 10 year 

permits would expire and the effects of the permits would cease.

Alternatives 1, 2, 3, and 4

The proposed activities would not occur near any known bald eagle use areas. They would have 

"no impact" on bald eagles.

Common Loon

Affected Environment

Common loons are known to occur in the analysis area. They inhabit freshwater lakes that are 

large enough to support fish, their primary food. To be suitable habitat for common loons, lakes 

also must be deep enough for loons to dive underwater to escape predators, and long enough 

for a loon to take flight (about 1⁄4 mi.) (DeGraaf, et al. 1991). Loons nest on the ground close to 

the water on shore, on islands, sometimes on floating vegetation or muskrat lodges. Common 

loons have been observed in the recent past on Black Lake and Hidden Lakes in the Pasayten 

Wilderness and on Lake Chelan. Successful nesting has not been confirmed at these lakes or 

anywhere else in the analysis area. Other lakes that may be suitable for loons are Surprise Lake 

in the Lake Chelan-Sawtooth Wilderness and Cub Lake in the Sawtooth Backcountry, but loons 

have not been observed at either.

Environmental Consequences

Direct, Indirect, and Cumulative Effects

The spatial boundary for the cumulative effects analysis is the analysis area as described in 

Chapter 1. The temporal boundary is from the early 1900s through 2023, when the 10 year 

permits would expire and the effects of the permits would cease.

Alternatives 1, 2, 3, and 4

All four of the alternatives would have “no impact” on the common loon. The outfitter-guide 

activities would not disturb any known nesting sites nor alter any suitable habitat.
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Okanogan-Wenatchee National Forest

Fisher

Affected Environment

Fishers are suspected to occur on the Okanogan-Wenatchee National Forest. There are two 

trapping records of fishers on the Methow Valley Ranger District from the early 1900s (Stinson 

and Lewis 1998). In addition, there have been unverified observations of individual fishers or 

tracks in the snow by Forest recreationists. Based on lack of recent confirmed sightings, the 

fisher was considered extirpated or reduced to scattered individuals in the state of Washington 

(USDI 2004). In 2008 fishers were translocated to Olympic National Park in western Washington 

and that population persists to date (Lofroth et al. 2010). 

Fishers historically occurred on both sides of the Cascades mountains in Washington in low to 

mid elevation forests (USDI 2004). They are opportunistic predators with a diverse diet that 

includes snowshoe hares, birds, rodents, reptiles, insects, carrion, and fruit. They need forests 

that provide abundant prey and low vulnerability to predators. They also have specific needs for 

natal denning and for resting spots (Powell and Zielinski 1994). The forest stand structures that 

provide these needs include large diameter trees with cavities and/or large platform-type 

branches, and large hollow logs. Late-successional forests provide the most suitable fisher 

habitat because they provide abundant potential den sites and preferred prey. 

Forest stands that would be suitable fisher habitat are present within the analysis area. 

Outfitter-guide activities do not alter forest stand structure except for the removal of snags and 

downed logs which are used for camp firewood when on overnight trips. Livestock grazing 

would not influence forest stand structure or the availability of denning and resting sites for 

fishers. Grazing could affect the abundance of some small rodent species that make up part of 

the fishers diet. However, grazing effects on rodents varies; some species respond with an 

increase while others decrease (Ivey 1996). Since fishers are considered generalized predators 

(Lofroth et al. 2010) and do not specialize on any certain prey species they would be able to shift 

to whatever species were available. 

Environmental Consequences

Direct and Indirect Effects

Alternatives 1, 2, 3, and 4

There would be no reduction of mature or old growth habitats under any of the four 

alternatives. Each of the four alternatives would have “no impact” on fishers. See the sections 

above on primary cavity excavators and LSRs for the discussion on effects to snags and downed 

logs.

Cumulative Effects

The spatial boundary for the cumulative effects analysis is the analysis area as described in 

Chapter 1. The temporal boundary is from the early 1900s through 2023, when the 10 year 

permits would expire and effects of the permits would cease.
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Past actions that may have affected fishers include shooting/trapping/poisoning of individual 

fisher and timber management that reduced habitat. Some forest management activities 

reduce habitat for fisher by reducing canopy closure or removing structure needed for denning 

and resting. Present and reasonably foreseeable future actions in the analysis area that may 

affect fisher include accidental shooting or trapping and wildfires that reduce suitable habitat.

Alternative 1

This alternative would have no cumulative effect on the fisher because no outfitter-guide 

permits would be issued.

Alternatives 2, 3, and 4

When considered in conjunction with other activities affecting fishers and their habitat, these 

alternatives would have no impact on the fisher. Shooting and trapping fisher in Washington is 

illegal. Body-gripping traps are not allowed for any species in Washington. 

Gray Flycatcher

Affected Environment

Gray flycatchers are known to occur in suitable habitats on the Okanogan-Wenatchee National 

Forest. They inhabit tall sagebrush plains and arid, open pine forests (DeGraaf et al. 1991) and 

build nests 2 to 5 feet above ground in shrubs or trees (O’Neil et al. 2001). Their diet includes 

beetles, butterflies, grasshoppers, and moths (O’Neil et al. 2001). Their range in Washington 

appears to be expanding (O’Neil et al. 2001). There is suitable gray flycatcher habitat within the 

Bear/Ramsey/Volstead and Alta Lake portions of the analysis area.

Environmental Consequences

Direct, Indirect, and Cumulative Effects

Outfitter-guide activities would not alter gray flycatcher nesting habitat or foraging habitat. 

None of the outfitter-guide camps are in gray flycatcher habitat.

The spatial boundary for the cumulative effects analysis is the analysis area as described in 

Chapter 1. The temporal boundary is from the early 1900s through 2023, when the 10 year 

permits would expire.

Alternatives 1, 2, 3, and 4

These four alternatives would have “no impact” on the gray flycatcher.

Great Gray Owl

Affected Environment

Great gray owls are known to occur on the Okanogan-Wenatchee National Forest. Great gray 

owls commonly nest in mature to old-growth forests that provide nesting structures such as 
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broken top snags, mistletoe brooms, or abandoned hawk or raven nests (Hayward and Verner 

1994). They forage in nearby meadows, bogs, clearcuts, or open forests for voles and pocket 

gophers (Hayward and Verner 1994). Prey abundance and the availability of existing nest sites 

appear to regulate great gray owl populations. Human disturbance has not been reported as an 

impact to great gray owls.

Forest stands and meadows that would be suitable great gray owl habitat occur in the analysis 

area, especially in the Spanish Camp area of the Pasayten Wilderness. Outfitter-guide activities 

have not altered forest stand structure other than the removal of some snags around camp sites 

for firewood (see Primary Cavity Excavators above). Livestock grazing associated with outfitterguides and their clients may impact habitat for rodents that great gray owls prey upon. Grazing 

effects on rodents varies with the species, habitat type, and season of grazing (Ivey 1996). Voles 

and pocket gophers, which are great gray owls preferred prey species, are dependent on good 

ground cover and can be negatively affected by grazing (Johnson 1981, Kauffman et. al. 1981, 

Oldemeyer and Allen-Johnson 1988). Excessive grazing removes their security cover and forage. 

Environmental Consequences

Direct and Indirect Effects

Alternative 1

This alternative would have “no impact” on the great gray owl because no outfitter-guide 

permits would be issued.

Alternatives 2, 3, and 4

Under mitigation measure 1.j, pack and saddle outfitter-guides would be prohibited from 

removing snags for firewood and therefore would have no impact on forest stand structure (see 

Primary Cavity Excavators above). It is possible that recreational livestock grazing activities 

conducted by outfitter-guides or their clients near camps could reduce habitat suitability for 

great gray owl prey species. Some rodents that great gray owls prey upon use the grass/forb 

layer of vegetation for food and for hiding cover. However, this occurs on such a small portion 

of the landscape that it is unlikely to be a substantial impact (see Ruffed Grouse and Beaver and 

Mountain Goat sections above). Due to this potential for minor impacts to rodents, alternatives 

2, 3, and 4 “may impact individual great gray owls, but are not likely to cause a trend toward 

Federal listing or a loss of population viability”.

Cumulative Effects

The spatial boundary for the cumulative effects analysis is the analysis area as described in 

Chapter 1. The temporal boundary is from the early 1900s through 2023, when the 10 year 

permits would expire, and the permits would cease to have effects.

Past Actions

Past actions in the analysis area that may have affected great gray owls include livestock grazing 

and timber management. Sheep grazing in the early 1900s in the analysis area may have 

temporarily impacted great gray owls by reducing habitat for the voles and pocket gophers they 

prey upon (see Mountain Goats analysis above for effects on high elevation meadows and 
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species). Some timber management actions can reduce nesting and foraging habitat for great 

gray owls.

Present and Reasonably Foreseeable Future Actions

Present and reasonably foreseeable future actions in the analysis area that may affect great gray 

owls include livestock grazing that may impact rodent species.

Alternative 1

This alternative would have no cumulative effect on the great gray owl because no pack and 

saddle outfitter-guide permits would be issued.

Alternatives 2, 3, and 4

When considered in conjunction with other past, present, and reasonably foreseeable future 

actions, these three alternatives may impact individual great gray owls, but are not likely to 

cause a trend toward Federal listing or a loss of population viability as a result of small potential 

for impacting habitat for prey species from recreational livestock grazing. Timber and other 

Forest Service permitted management activities are now planned and implemented to avoid or 

minimize and mitigate impacts to great gray owls.

Lewis’ Woodpecker

Affected Environment

The Lewis’ woodpecker utilizes dead and defective tree habitat in open Ponderosa pine stands 

and riparian cottonwood stands. This species and suitable snag habitat exists in the drier 

forested areas of the analysis area. 

Environmental Consequences

Direct, Indirect, and Cumulative Effects

Effects to snag habitat are specified above in the MIS section on primary cavity excavators. The 

spatial boundary for the cumulative effects analysis is the Methow Watershed. The temporal 

boundary is from the early 1900s through 2023, when the 10 year permits would expire and the 

any effects would cease.

Alternatives 1, 2, 3, and 4

These alternatives would have “no impact” on the Lewis’ woodpecker. The proposed outfitterguide activities would not alter any key features of Lewis’ woodpecker habitat. 

Moose

Affected Environment

Moose prefer forested habitat where lakes, marshes, and other wetlands provide them with 

aquatic vegetation and willows. But in less wet areas, like northeast Washington, they also eat 

the woody browse in early stages of regrowth following disturbances like fires, logging, and 

clearing. Moose are a pioneering type animal and adapt to a variety of available forage. 
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Moose are known to occur in the analysis area. Their numbers and distribution seems to be 

increasing following the large wildfires that have occurred in the area since the mid-1990s. They 

seem to be observed most often in the upper Chewuch River, Twisp River, and Pasayten River 

drainages. 

Direct/Indirect/Cumulative Effects

Effects to riparian habitat are specified above in the MIS section on ruffed grouse and beaver. 

The spatial boundary for the cumulative effects analysis is the analysis area as described in 

Chapter 1. The temporal boundary is from the early 1900s through 2023, when the 10 year 

permits would expire and the any effects would cease.

Alternatives 1, 2, 3, and 4

These alternatives would have “no impact” on moose. The proposed outfitter-guide activities 

would not alter any key features of moose habitat. Effects to riparian habitats are limited to 

trail crossings and other small areas near camps. Woody browse that moose prefer are not 

typically favored by domestic stock and are not limiting in the analysis area. 

Mountain Goat

Affected Environment

Mountain goats are associated with open country with steep rocky cliffs, talus slopes, and 

meadows for foraging (Wilson and Ruff 1999). In the southern portion of its range, they inhabit 

high alpine and subalpine zones in the mountains. They spend the majority of their time on or 

directly adjacent to cliffy escape terrain. In the winter, some groups of goats inhabit higherelevation wind-swept ridges, and others move to lower-elevation steep south-facing slopes. In 

some areas goats spend the majority of the year in steep shrubland, forests, and grasslands 

during the long winter (Rice 2010). 

Mountain goats are known to occur in the analysis area. Effects of the proposed activities on 

mountain goats were discussed above in the Management Indicator Species section. 

Direct/Indirect/Cumulative Effects

Alternatives 1, 2, 3, and 4. 

These alternatives would have no impact on mountain goats. 

Pallid Bat

Affected Environment

Pallid bats are known to occur in low elevations of the Methow Valley. Individuals have been 

documented on several occasions roosting under Highway 153 bridges over the Methow River 

between Carlton and Pateros. They have not yet been documented on the Methow Valley 

Ranger District. This species of bat is a large insectivorous, terrestrial forager that inhabits 

deserts, arid grass and shrublands and dry forests (Chapman et al 1994). They fly low over areas 

of sparse vegetation searching for large insects, then night roost on nearby Ponderosa pines. 

Day roosts are usually in fissures in cliff systems. 
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There is suitable habitat for pallid bats within or adjacent to the analysis area. Areas of sparse 

vegetation near Ponderosa pine forests exists in the lower elevations of the Alta and 

Bear/Ramsey areas of the analysis area. 

Direct/Indirect/Cumulative Effects

The proposed outfitter-guide pack and saddle stock activities would not impact night roosting 

habitat or day roosting habitat for pallid bats. 

Alternatives 1, 2, 3, and 4

These alternatives would have no impact on the pallid bat. 

The proposed project would not alter any bat roosting habitat or affect their prey base. 

Peregrine Falcon

Peregrine falcons experienced a dramatic decline in population nationwide, due to the effects of 

DDT on eggshell thickness. They were Federally listed as an endangered species in 1970, 

underwent recovery, and were removed from the list in 1999. 

Affected Environment

Peregrine falcons are known to occur in the analysis area. There are two known peregrine 

falcon nesting sites (eyries) on the Methow Valley Ranger District but neither are within the 

analysis area. 

Peregrine falcons are considered a generalist predator, and they prey mainly on other birds, 

particularly waterfowl and shorebirds (Hayes and Buchanan 2002). Prominent cliffs are the 

most common characteristic in peregrine territories. They nest on cliff ledges that provide 

protection from the weather and mammalian predators, and are in close proximity to bodies of 

water. Their breeding period is March 1 to July 30. 

Environmental Consequences

Direct, Indirect, and Cumulative Effects

There are no known peregrine falcon nesting sites in the analysis area. Outfitter-guide pack and 

saddle stock activities are unlikely to disturb nesting falcons since their nests are on sheer cliffs. 

The proposed activities would not substantially alter habitat for falcon prey species. 

The spatial boundary for the cumulative effects analysis is the analysis area as described in 

Chapter 1. The temporal boundary is from the early 1900s through 2023, when the 10 year 

permits would expire and any effects would cease.

Alternatives 1, 2, 3, and 4

All four alternatives would have “no impact” on the peregrine falcon. Pack and saddle stock 

outfitter-guide activity would not alter peregrine falcon habitat.
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Sharptail Snake

Affected Environment

The sharptail snake is suspected to occur on portions of the Chelan Ranger District. They are a 

small, secretive snake that feed almost exclusively on slugs (Storm and Leonard 1995). They 

seem to prefer moist habitats and are found at elevations below 2,000 feet. There is only a 

small area of suitable sharptail snake habitat in the very southern portion of the analysis area. 

Environmental Consequences

Direct, Indirect, and Cumulative Effects

The spatial boundary for the cumulative effects analysis is the Lake Chelan Watershed. The 

temporal boundary is from the early 1900s through 2023, when the 10 year permits would 

expire and any effects would cease.

Alternatives 1, 2, 3, and 4

These alternatives would have “no impact” on the sharptail snake. The proposed alternatives 

would not alter any sharptail snake habitat. There are no outfitter-guide camps or other 

activities proposed to occur in sharptail snake habitat.

Striped Whipsnake

Affected Environment

The striped whipsnake is suspected to occur on portions of the Chelan Ranger District. They are 

long, slender, and fast-moving snakes that are most abundant in areas with a diversity of lizards, 

their favorite prey (Storm and Leonard 1995). They occur in arid habitats below 2000 feet 

elevation. There is only a small area of suitable striped whipsnake habitat in the very southern 

portion of the analysis area. 

Environmental Consequences

Direct/Indirect/Cumulative Effects

The spatial boundary for the cumulative effects analysis is the Lake Chelan Watershed. The 

temporal boundary is from the early 1900s through 2023, when the 10 year permits would 

expire.

Alternatives 1, 2, 3, and 4

These alternatives would have “no impact” on the striped whipsnake. The proposed 

alternatives would not alter any striped whipsnake habitat. There are no outfitter-guide camps 

or other activities proposed to occur in striped whipsnake habitat.
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Townsend’s Big-eared Bat

Affected Environment

Townsend’s big-eared bats are known to occur on the Methow Valley Ranger District. A nursery 

colony was discovered in a warehouse at the Early Winters Forest Service administrative 

compound in 1997. About 70 Townsend’s big-eared bats were using this building. The colony 

has been closely monitored and protected from disturbance since then. There are several other 

known sites being used by Townsend’s big-eared bats on private lands in the Methow Valley. 

This species of bat is known to roost in old buildings, caves, and mines, and underneath bridges 

(Christy and West 1993). They are not known to roost in foliage, beneath loose bark, in snags, 

or in rock crevices (Christy and West 1993). They seem to require enough space to be able to 

hang upside down. They feed primarily on moths, and foraging habitat is open dry forests, 

meadows, and grasslands. There are no known roost sites in the analysis area. There is suitable 

foraging habitat within the analysis area and there are potential roosting sites in the form of a 

few old buildings and mine shafts.

Environmental Consequences

Direct/Indirect/Cumulative Effects

The spatial boundary for the cumulative effects analysis is the Methow Watershed. The 

temporal boundary is from the early 1900s through 2023, when the 10 year permits would 

expire.

Alternatives 1, 2, 3, and 4

Alternative 1 would have no impact on the Townsend’s big-eared bat; there would be no change 

from the existing condition. Alternatives 2, 3, and 4 would have “no impact” on the Townsend’s 

big-eared bat since the project would not alter any bat roosting habitat or affect the prey base.

Western Gray Squirrel

Affected Environment

Western gray squirrels are known to occur on the Methow Valley and Chelan Ranger Districts. 

There are no known records in the Methow portion of the analysis area however they may occur 

in the very southern portion of the analysis area on the Chelan District. Western gray squirrels 

inhabit ponderosa pine forests and oak woodlands and forage on pine nuts, fir seeds, berries, 

bark, and hypogeous fungi (O’Neil et al. 2001). In the Chelan Basin they are present in areas the 

have walnut trees or bigleaf maple trees. They are largely arboreal.

Environmental Consequences

Direct, Indirect, and Cumulative Effects

The spatial boundary for the cumulative effects analysis is the Methow Watershed. The 

temporal boundary is from the early 1900s through 2023, when the 10 year permits would 

expire and the any effects would cease.
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Alternatives 1, 2, 3, and 4

These alternatives would have “no impact” on the western gray squirrel. The proposed 

outfitter-guide activities would not alter any key features of western gray squirrel habitat.

White-headed Woodpecker

Affected Environment

The white-headed woodpecker utilizes dead and defective tree habitat in open Ponderosa pine 

stands. This species and suitable snag habitat exist in lower elevations of the project area.

Environmental Consequences

Direct, Indirect, and Cumulative Effects

Effects to snag habitat are specified above in the MIS section on primary cavity excavators. The 

spatial boundary for the cumulative effects analysis is the Methow Watershed. The temporal 

boundary is from the early 1900s through 2023, when the 10 year permits would expire and the 

any effects would cease.

Alternatives 1, 2, 3, and 4

These alternatives would have “no impact” on the white-headed woodpecker. The proposed 

outfitter-guide activities would not alter any key features of white-headed woodpecker habitat. 

Wolverine

Affected Environment

Wolverines are known to occur on the Okanogan-Wenatchee National Forest. The northern 

Cascade Range in Washington represents the southernmost extent of the current range of 

wolverines along the Pacific coast of North America (Aubry et al. 2007). Wolverines are 

uncommon inhabitants of subalpine habitats in western mountain ranges in the lower 48 United 

States (Aubry et al. 2007). Recent research on wolverines in the Rocky Mountains of British 

Columbia (Krebs et al. 2007) and the United States (Copeland 1996, Copeland et al. 2007, 

Squires et al. 2007) indicates that wolverines are wide-ranging, inhabit remote areas near 

timberline, and are sensitive to human disturbance at natal and maternal den sites. They subsist 

on ungulate carrion and by predating on small to medium sized animals. Wildlife biologists have 

recently radio-collared 10 wolverines in the analysis area. They have been found to use the 

Pasayten, North Cascades, Lake Chelan-Sawtooth Wilderness, and Middle Methow areas. In 

addition, there have been highly reliable sightings from Forest visitors recently reported at 

several other locations on both the Methow and Chelan portions of the analysis area. In an 

analysis of wolverine habitat use in central Idaho, Copeland et al. (2007) found no relationship 

between wolverine presence and maintained trail systems. However, Copeland (1996) found 

wolverines to be intolerant of human disturbance at maternal den sites. Wolverines give birth 

in natal dens from late February to March (Magoun and Copeland 1998). Magoun and Copeland 
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(1998) noted the critical feature of wolverine denning habitat to be the dependability of deep 

snow throughout the denning period. Copeland (1996) observed two wolverine natal dens in 

Idaho; both were in subalpine talus habitat on north-facing, steep slopes of cirque basins. The 

talus consisted of large rocks and boulders that were at least two meters in diameter, and the 

talus was less than 100 meters across and surrounded by trees. The den was in the interstitial 

spaces of the large-rock talus. Recent research in southeastern British Columbia has 

documented wolverine maternal den sites in Englemann spruce/subalpine fir forest types in 

large woody debris accumulations at the bottom of avalanche chutes (Krebs 1999). 

Most of the proposed outfitter activities would occur in areas that may be inhabited by 

wolverine. Wolverine denning habitat as described by Magoun and Copeland (1998) and Krebs 

(1999) exists within the analysis area.

Environmental Consequences

The potential effects of the proposed outfitter-guide activities on wolverines are the possibility 

of human disturbance to a mother with kits. Reproductive den habitats, as described by 

Magoun and Copeland (1998) are not typically sought out by pack and saddle stock outfitterguides. In addition, the wolverine reproductive denning season is considered to be February 

through April (Magoun and Copeland 1998). The proposed outfitter-guide activities would not 

occur until after this so disturbance is unlikely. 

Direct, Indirect and Cumulative Effects

Alternatives 1, 2, 3, and 4

These alternatives would have “no impact” on wolverine. Pack and saddle stock outfitter-guide 

activities would occur after the reproductive den season so disturbance would be unlikely. 

Consistency Findings for Sensitive Species

Each of the four alternatives considered in this project would be consistent with Forest Service 

Manual 2670 because biological evaluations have been prepared in accordance with Manual 

policy. None of the alternatives would cause a trend toward Federal listing or a loss of 

population viability for sensitive species.

Sensitive Invertebrate Species

Affected Environment

The following table lists the sensitive invertebrate species suspected or known to occur on the 

Okanogan-Wenatchee National Forest along with their preferred habitat and information on 

nearest documented sightings in relation to the analysis area:
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Figure 3.8-4. Sensitive Invertebrate Species on Okanogan-Wenatchee National Forest

Species Habitat Nearest documented 

Astarte fritillary Alpine rock slides and windswept 

ridges

Slate Peak, in analysis area

Meadow fritillary Open boggy wet meadows Loup Loup Pass, south of analysis 

area

Freija fritillary Alpine, willow bogs, forest 

meadows

East of analysis area

Labrador sulphur Alpine scree and tundra Pasayten wilderness, in analysis 

area

Lustrous copper Alpine rock slides and windswept 

ridges

Slate Peak, in analysis area

Melissa arctic Alpine rock slides and windswept 

ridges

Slate Peak, in analysis area

Great Basin fritillary Montane meadows, forest 

clearings

East of Okanogan River, east of 

analysis area

Tawny-edged skipper Moist to dry grassy areas Loomis, east of analysis area

Peck’s skipper Mountain meadows, grassy wet 

meadows

Loomis, east of analysis area

Zigzag darner Wet sedge meadows, fens, bogs, 

and very shallow peaty ponds

East of analysis area

Subarctic darner fens, wet meadows, and bogs 

with abundant sphagnum and 

other mosses

Fish Lake, south of analysis area

Subarctic bluet boreal fens and bogs Davis Lake, east of analysis area

Environmental Consequences

The only sensitive vertebrate species known to occur within the analysis area are those with 

alpine rocky areas for habitat. There is potentially suitable habitat for the meadow fritillary, 

Great Basin fritillary, tawny-edged skipper, and Peck’s skipper. Overgrazing by livestock would 

be an impact to butterflies trying to inhabit these areas. 

Direct, Indirect and Cumulative Effects

Alternatives 1, 2, 3, and 4

These alternatives would have “no impact” on sensitive invertebrate species. Pack and saddle 

stock would not impact alpine rocky habitats. The proposed alternatives would not result in 

the overgrazing of any suitable habitats. 
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3.9 INVASIVE PLANTS

The section below is a summary of the Invasive Plant Management Analysis Report which is 

available in the project analysis file (McFetridge 2012b).

REGULATORY FRAMEWORK

This analysis is required to conform to the requirements of Pacific Northwest Invasive Plant 

Program Final Environmental Impact Statement, Record of Decision (USDA Forest Service 

2005a), hereafter referred to as the 2005 PNW ROD, and the Okanogan (1989) and Wenatchee 

(1990) Forest Plans, each of which require a prevention emphasis, and in the case of the 

Okanogan, especially in unroaded areas and wilderness, both of which make up the majority of 

this project’s analysis area. The 2005 PNW ROD standards that apply to this project require an 

emphasis on prevention (ROD-10) and the use only pelletized or certified weed free feed in 

wilderness and at wilderness trailheads (ROD-12). No treatment of invasive species is included 

in any of the alternatives. Actual treatment will authorized be under other NEPA documents.

The Okanogan Forest Plan requires that noxious weeds be controlled to the extent practical, 

new infestations be the first priority for eradication (page 4-45). The Wenatchee Forest Plan 

requires cooperation with other agencies in identifying, locating and preventing the spread of 

noxious weeds, inventory and monitoring of noxious weeds, conduct of a risk assessment on 

weed introduction for ground disturbing activities, and containment, control or eradication of 

existing populations as budget allows, by priority specific classes and locations of weeds (page 

IV-89 to IV-92). Each standard and guideline is listed and addressed under the Consistency 

findings at the end of this section.

Both Service-wide and Pacific Northwest Region Noxious Weed Strategies use the term “noxious 

weeds” to broadly encompass all invasive, aggressive, or harmful non-indigenous species. The 

more recent term is “invasive plants”, which are defined as non-native plants likely to cause 

economic harm, environmental harm, or harm to human health (Executive Order 13112, 1999). 

The terms “invasive plant species”, “noxious weeds”, and “weeds” are used interchangeably in 

this document.

Policy Guidance – This analysis is guided by the National Strategy and Implementation Plan for 

Invasive Species Management (USDA Forest Service 2004c). The National Strategy has four 

elements: Each of these elements is addressed in detail in the Prevention and Management 

Strategy document in the analysis file (Items 1 - 4 below).

1. Prevention – Stop invasive plants before they arrive.

2. Early detection and rapid response – Find new infestations and eliminate them before 

they become established.

3. Control and management – Contain and reduce existing infestations.

4. Rehabilitation and restoration – Reclaim native habitats and ecosystems. 
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ANALYSIS METHODS

Introduction and spread of invasive plants is generally proportional to the area disturbed. For 

this project, disturbance is mostly associated with trailhead and outfitter-guide camps, although 

outfitters, their stock, and their clients can spread weeds along trails. The type and size of 

disturbance is relatively similar between all trailheads and camps. There would be no new 

disturbance as a result of the proposed action or its alternatives. The spatial boundary used for 

this resource is the entire analysis area, including all weed sites along roads and off-road areas. 

Most of the invasive plant populations in this analysis area are on roads within the analysis area 

and are not directly affected by the outfitter-guide activities at trailheads, on trails, and at 

camps. The temporal boundary is the time during project activity (a ten-year permit). For the 

purposes of this analysis, the potential for invasive plant introduction and spread is discussed. 

The following specific indicators are used to describe the direct, indirect, and cumulative effects 

of the proposed action and its alternatives:

Qualitative discussion of existing vegetation within the analysis area relative to the habitat 

requirements for new invader and potential invader noxious weeds including the number of 

outfitter-guide camps within each habitat type.

Number of trail heads with established populations of New Invader noxious weeds and 

qualitative discussion on potential to spread into the analysis area.

Acres of current known infestations within the analysis area and discussion of potential to 

spread into project activity areas.

Quantitative estimate of number of visitor days as a vector of introduction and spread.

Analyses of potential invaders occur on lands adjacent to the project area but not within the 

project area.

This analysis describes the ecological and social conditions within the analysis area, and the 

potential effects of the proposed outfitter-guide use on resources and people. The best

available science was used for this analysis, including the methodology and data sources 

described above. 

AFFECTED ENVIRONMENT

Past Activities

Past commercial livestock grazing introduced and spread invasive plants in the analysis area in 

the past from private land well outside the project area. Numerous commercial sheep and 

cattle driveways were constructed to enable livestock to access key use grazing areas. This 

opened the wilderness and back country area to the potential for weed introduction through 

dispersal of weed seed on these commercial livestock, and through use by recreationists, and 

outfitters. Ground disturbance at the sheep camps, and along trails and stock driveways created 

areas of disturbed soil suitable for weed introduction and establishment.

Logging activity started in the 1950s outside of wilderness areas. Secondary roads were 

completed in the 1960s and 1970s in conjunction with timber sales through the 1990s. An 

increase in recreation and permitted commercial cattle grazing followed. Road construction 

increased motor vehicle and livestock access to the edge of wilderness. Even after the roads 
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were built, commercial grazing continued to occur in the Pasayten and Lake Chelan Sawtooth 

wilderness but limited to those areas that were being grazed at the time the wilderness was 

established. 

Past wildfires, including but not limited to the Quartz Mountain Fire in 2000, Thirtymile Fire in 

2001, Farewell Fire in 2003, and Tripod and Tatoosh Fires in 2006, and the more recent Slick 

Creek Fire increased the potential for weed establishment and spread in the analysis area by 

creating disturbed soils conducive to weed establishment. Burned Area Emergency Response 

(BAER) plans were completed and implemented for many on these fires. Post fire surveys for 

invasive plants are always considered under BAER. Invasive plant treatments were conducted 

for 3 years in Bear/Ramsey/Volstead area as part of the Tripod BAER treatment plan. 

The 1997, 1999 and 2001 Noxious Weed Management decisions (USDA Forest Service 1997e, 

USDA 1999a, and USDA Forest Service 2000d) on the Okanogan portion of the analysis area 

combined with the Crupina Control EIS on the Chelan portion allowed for 4066 acres of the 

analysis area to be treated using integrated weed management strategies, including manual, 

mechanical, biological and chemical methods. These treatments have reduced the spread of 

noxious weeds, and decreased population sizes. 

In 2003, the Forest approved the Crupina Control Analysis file of Decision, which also approved 

use of the above management strategies in the Lake Chelan Sawtooth Wilderness and the area 

below the wilderness boundary and above the lakeshore. Treatment began under the decision 

in 2003 and 600 gross acres have been treated as of 2012 and have been successful in 

preventing spread outside the known infested area, and reducing the size and density of the 

infestation. 

Surveys for common crupina occur yearly. Common crupina continues to be the highest priority 

for treatment. The management strategy is to contain and reduce the existing population. 

Herbicide and manual treatments have been successful and are currently meeting this objective. 

The Lake Chelan population is the only known crupina infestation in Washington State. The 

primary habitat is on hot, dry southern slopes in shrub steppe grassland and open ponderosa 

pine and Douglas fir forest. Associated species include arrowleaf balsamroot, bluebunch 

wheatgrass, and cheatgrass. Crupina grows from the lake level to approximately 2800 feet in 

elevation. Because crupina grows in open, dry, hot habitats it is unlikely to invade the cool, 

shaded subalpine forests, and unlikely to spread into the higher elevation outfitter-guide camp 

activity areas above 3500 feet. 

In 2008, the Forest approved the Blue Buck Hawkweed Decision Notice (USDA 2008b), which 

approved the use of 3 herbicides to reduce and eliminate the orange hawkweed populations in 

Blue Buck Creek. As of 2012, 11 acres of these populations have been treated 4 to 5 times each 

year since treatment began in 2008. These treatments have been very successful in reducing 

spread but less successful in reducing and eliminating these populations. Population densities 

are much less than in 2008 and on a steady decline but treatments have not been as effective as 

expected. 

The Washington Department of Transportation (DOT) administers the roadside of Highway 20

through the North Cascades sub-project area under their easement. Herbicide treatments are 

conducted along within the easement on most years in that project area. Recent treatments in 
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2012 have been very effective in eliminating many of the invasive plants established along the 

highway.

Current Condition of Invasive Plants

Noxious weed information and analysis for the project area has been conducted through recent 

Okanogan and Wenatchee National Forests Noxious Weed Environmental Assessments (USDA 

Forest Service1997, 1999, and 2000) and through more recent inventories. Informal noxious 

weed surveys are routinely done within the project area by range management personnel and 

by the livestock grazing permittees. The weed acres in Figure 3.4-5. are from the 2008 

inventory. Gross acres describe the general area of land or perimeter in which all the invasive 

plants are found. Gross acres thus often encompass land that does not actually contain the 

invasive species. Infested acres on the other hand narrow the perimeter down to the actual 

area containing the plant, as defined by the invasive species canopy cover. 

Status and Classification of Weeds

Invasive plant populations are present in the project area and fall into three primary categories. 

These categories are used to prioritize invasive species for inventory and treatment. Figure 3.9-1 

below displays the established, new and potential invaders found within or adjacent to the 

analysis area.

1. Established Invaders are those species whose population levels and distribution are such 

that seed production cannot be prevented. State listed Class C or no state listing.

2. New Invaders are invasive plant species that occur sporadically on the Forest and that may 

be controlled by preventing seed production and early treatment. State listed Class A or 

State listed Class B and C that are locally limited in distribution on National Forest within 

the project area.

3. Potential Invaders are invasive plants that occur on lands adjacent to the project area but 

have not been documented on lands administrated by the Forest; however, the potential 

for infestation is imminent. State listed Class A and/or B that are locally limited in 

distribution.
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Figure 3.9-1. Established, New, and Potential Invaders in or adjacent to analysis area.

Established Invaders: New Invaders: Potential Invaders:

bull thistle common crupina *orange hawkweed

Canada thistle common tansy *sulfur cinquefoil

common mullein dalmatian toadflax Japanese knotweed

dandelion diffuse knapweed yellow hawkweed

cheatgrass houndstongue

lambsquarters oxeye daisy

tansymustard Russian knapweed

dwarf mallow Scotch broom

common plantain spotted knapweed

white clover St. Johnswort

field bindweed whitetop

common mullein

yellow salsify

crane’s bill

prickly lettuce

bulbous bluegrass

*New Invader in Bear/Ramsey/Volstead subunit only

Figure 3.9-2 below displays the characteristics of new invaders, and one potential invader to the 

analysis area.
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Figure 3.9-2. Existing New Invader and Potential Invader Noxious Weed Characteristics.

COMMON NAME OF SPECIES 

(scientific name)

CHARACTERISTICS

common crupina 

Crupina vulgaris

A Washington State Class A Noxious weed; A fall germinating annual, 

primary habitat is southern slopes in steep canyon grasslands and open 

forest; reproduces by seed but seeds not persistent in soil; adapted to a 

wide range of soil and climate conditions; can form solid stands decreasing 

forage productivity, livestock carrying capacity and replacing native plants.

common tansy

Tanacetum vulgare

Spreads mainly by seeds, and less commonly from creeping rhizomes, to 

form dense clumps of stems. An invader of disturbed sites commonly 

found on roadsides, fence rows, pastures, stream banks and waste areas.

dalmatian toadflax

Linaria dalmatica

A perennial reproducing by seed and rhizomes; it is aggressive on 

roadsides and rangeland; difficult to control.

diffuse knapweed Centaurea 

diffusa

An annual or short-lived perennial; highly competitive.

Houndstongue

Cynoglossum officinale

A biennial; seeds are 4 prickly nutlets (seeds) that attach to people, 

livestock, vehicles, for easy dispersal; a very strong competitor with 

desirable forage; generally non-palatable but toxic properties capable of 

poisoning livestock, shade tolerant and thrives in wetter grasslands.

Japanese knotweed 

Polygonum cuspidatum

(Potential Invader)

An escaped ornamental becoming increasingly common along stream 

corridors and rights-of-way in Washington; a perennial with spreading 

rhizomes, can reach 8 feet in height and is often shrubby, very aggressive, 

capable of crowding out all other vegetation, rarely established from seed, 

primary spread is through mechanical movement of plant parts; several 

sites in Methow Valley bottom, one on Twisp River.

oxeye daisy 

Chrysanthemum leucanthemum

Aggressive perennial invader of open forest, meadows, and roadsides; 

strong sprouting from roots with branched rhizomes; reproduces 

vegetatively along rhizomes and by seed.

orange and yellow (meadow) 

hawkweed

Hieracium aurantiacum, 

Hieracium pratense

A perennial with creeping stolons; forms dense patches and rapidly 

invades new areas; mostly vegetative reproduction; dispersed by wind, 

animals, and people, seeds not carried far by the wind - presumably 

dispersed > 1 km, minute barbs on the seeds stick to fur, clothing and 

vehicles; suitable habitat well above 5000 ft. in mountain meadows.

Russian knapweed 

Acroptilon repens

A creeping perennial, reproduces from seed and vegetative root buds, 

toxic to horses, very competitive in heavier soils of bottomlands, invades 

degraded areas dominating the plant community.

Scotch broom 

Cystis scoparius

An aggressive, deciduous, perennial shrub, Common pest in western WA 

and OR, very limited infestations east of the Cascades, a prodigious seed 

producer with seed coats enabling them to survive for up to 80 years.

Spotted knapweed

Centaurea maculosa

A short-lived perennial; tolerates shade; spread by vehicles, wind, animals; 

highly competitive.

sulfur cinquefoil

Potentilla recta 

A competitive long-lived perennial; unpalatable to grazing animals 

reducing forage for livestock and wildlife; adapted to a wide range of 

environmental conditions; reproduces by seed and uses early emergence 

to establish.

St. Johnswort

Hypericum perforatum

A perennial reproducing by seed or short rhizomes; easily established on 

roadsides; very slow in spreading off of roadside; difficult to control; 

biological control available.

whitetop

Carderia draba

A deep rooted perennial reproducing from root segments and seeds; 

highly competitive with other species once it becomes established; will set 

seed by early summer.

(Sheley and Petroff, 1999) (Whitson et. al., 1992)
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The analysis area contains a moderate potential for spread of potential and new invaders from 

adjacent private and state lands. 

Information currently in the NRIS (Natural Resource Information System) inventory database 

shows 11 species occurring singly or in combination at 162 sites in the analysis area, for a total 

of about 4,066 acres. All invasive plant sites in the analysis area were inventoried in the last five 

years.

Many of the invasive plant sites in the analysis area that occur on the Methow Valley and Chelan 

Ranger Districts have been approved for herbicide use under the 1997, 1999 and 2001 

Integrated Weed Management EA Decision Notices, the 2008 Blue Buck Hawkweed Decision 

Notice and the 2003 Crupina Integrated Weed Management EIS Record of Decision. Of the total 

4066 gross acres of weeds within the project are, 743 acres of herbicide treatment and 263 

acres of manual treatment have been constantly accomplished each year over the past 6 years. 

Overall, treatments have been effective in reducing populations. The larger dalmatian toadflax 

and diffuse knapweed populations have warranted using bio-control agents.

Figure 3.9-3 Acres of treatment accomplished annually in the analysis area

Weed acres within Project 

Area

Herbicide Acres

Treated

Manual Acres

Treated

Pasayten Wilderness 1 1

Bear/Ramsey/Volstead 925 479

Middle Methow 661 122 201

Upper Methow 484 141 61

North Cascades Highway 600 1 0.1

Alta Lake 439 

Lake Chelan-Sawtooth and Sawtooth 

Backcountry

956 50 200 

Total 4066 743 263

Existing Vegetation and Habitat Type

The analysis area covers dry ponderosa pine habitat, interspersed with shrub steppe habitat, 

from 1,100-foot elevation along the north shore of Lake Chelan, to alpine parkland habitats 

above 6,000-foot elevation in the Pasayten.

There are four general vegetation types identified in the analysis area (summarized from Botany 

report in the analysis file). Vegetation type and the number of existing outfitter-guide camps 

that fall within each typed are listed below:

Hot/dry ponderosa pine/shrub steppe to warm/dry Douglas fir communities, 10 camps

Cool/moist subalpine fir communities, 60 camps

Cold/moist alpine parkland communities, 43 camps

Cool/moist Pacific silver fir and mountain hemlock communities, 3 camps
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Invasive plants are competitive in a variety of habitats and prefer disturbed sites such as 

trailheads, roadsides, trails, wildlife bedding grounds, overgrazed areas, and campgrounds. Of 

the new invader and potential invader weed species associated with this project, most are 

native of the Mediterranean climate and are competitive in the dry lower elevation areas that 

are open or sparsely forested. Some of these are competitive on sunny south slopes and in welldrained soils. These species are typically the most competitive in disturbed soil areas within the 

shrub steppe and open forest communities. Conversely there are a few weed species that are 

native of the northern regions of Eurasia that are more adapted to cool, moist, higher elevation 

habitats and can be competitive in moist meadow environments (Sheley and Petroff 1999).

The analysis area contains a range of habitat types but most of the impacts of recently 

permitted outfitter-guide activities are at outfitter-guide camps within the cool/moist higher 

elevation habitat types, and at trailheads which are typically in the transition zone between the

warm/dry Douglas fir and the cool/moist subalpine fir plant communities. Of the total number 

of outfitter-guide camps in the analysis area, 88% are in the cool/moist subalpine fir and alpine 

cold/moist parkland habitat which is limited as suitable habitat for many of the new invader 

weeds.

Current Infestations

Current infestation of Established, New, and Potential Invaders are described. Invasive species 

were likely introduced from private lands mostly by vehicles, but also by recreational livestock 

and hikers. In the case of common crupina, the likely vector was by boat transported livestock.

New Invaders

These weeds are minimal; there is currently one outfitter-guide camp (1st Hidden Lake) with a 

new invader noxious weed population (whitetop). There are 17 trailheads in the analysis area 

with populations of new invader noxious weeds, and there are 5 known new invader sites 

established along trails into wilderness (see Figure 3.9-4 below). The new invader weeds with 

the highest risk of establishment into the project area are whitetop, oxeye daisy, and orange 

and yellow hawkweed as all three can invade mountain meadows, and higher elevation forest 

openings. The areas with the highest potential for new introduction and spread are the lower 

elevation trails associated with trailheads with established weed populations, as discussed 

below.

Trailheads

Trailheads are areas of concentrated public use and have a high risk of new invader weed 

introduction. Diffuse knapweed is present at most all trailheads leading into the analysis 

area, but population densities are low with the exception of West Fork Methow, Williams 

Lake, and War Creek trailheads. Whitetop and oxeye daisy are species that are established 

at many trailheads with some spread up the trail systems. The trailheads of greatest 

concern are Billygoat and Thirtymile in the Pasayten and the Prince and Fish Creek 

trailheads in the Lake Chelan-Sawtooth. A large population of oxeye daisy is established at 

the Billygoat trailhead. The main infestation is along the road between the trailhead and 

the horse corral (a recently permitted assigned site) but there is a large patch near the 

corral and plants are scattered through the trailhead area. The 2001 Thirtymile trailhead 

has become weedy since the Thirtymile Fire with many established invaders, but there are 

also two small new invader sites of oxeye daisy and Russian knapweed. Common crupina is 
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near the Fish Creek Base Camp and the Prince and Fish Creek trailheads in the Lake ChelanSawtooth Wilderness. Weed surveys and treatment continue to be a priority at trailheads. 

New invader populations are currently low at trailheads with the exception of the above 

mentioned areas. Houndstongue has been found at trailheads but only a few individual 

plants.

Figure 3.9-4. New Invader weeds established at trailheads.

Sub-Area Trailhead Weed Species

Pasayten Andrews Creek oxeye daisy, spotted knapweed

Pasayten Thirtymile russian knapweed, oxeye daisy

Pasayten Lake Creek whitetop

Pasayten Billygoat oxeye daisy

Middle Methow Slate Creek whitetop, st. johnswort

Middle Methow War Creek whitetop, diffuse knapweed

Middle Methow Wolf Creek whitetop

Middle Methow West Fork Buttermilk whitetop

Middle Methow Williams Lake diffuse knapweed

Middle Methow Crater Creek whitetop

Middle Methow Gilbert oxeye daisy

Upper Methow Harts Pass dalmatian toadflax, common tansy

Upper Methow West Fork Methow diffuse knapweed

North Cascades Hwy Rainy Pass common tansy

North Cascades Hwy Canyon Creek common tansy

Lake Chelan-Sawtooth Prince Creek common crupina

Lake Chelan-Sawtooth Fish Creek common crupina

In addition to the list of weeds at trailheads associated with the analysis area that have new 

invader weed infestations (Figure 3.9-4), noxious weed information and analysis for the 

following sites has been conducted through the 1997, 1999 and 2000 Weed EAs, the 2003 

Crupina EIS, as part of the Blue Buck Hawkweed EA, and through recent inventories for this 

project. Figure 3.9-5 lists the actual weed species and number of sites found in each of the 

discrete portions of the analysis area.
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Figure 3.9-5. Weed Sites in Analysis Area.

Subunit Weed Species Number of Sites Gross 

Acres

Pasayten Wilderness whitetop 1 1

Bear/Ramsey/Volstead whitetop 3 4

musk thistle 1 2

orange hawkweed 4 11

dalmatian toadflax 15 189

sulfur cinquefoil 2 27

Total New Invader 25 233

*diffuse knapweed 12 692

Total All 37 925

Middle Methow whitetop 6 13

oxeye daisy 7 45

St. Johnswort 2 4

dalmatian toadflax 1 2

houndstongue 1 1

common Tansy 1 1

Total New Invader 18 66

*diffuse knapweed 17 595

Total All 35 661

Upper Methow whitetop 7 19

spotted knapweed 1 3

Russian knapweed 1 8

oxeye daisy 8 42

dalmatian toadflax 3 30

sulfur cinquefoil 2 2

tansy ragwort 1 77

common tansy 10 21

Total New Invader 33 202

*diffuse knapweed 10 282

Total All 43 484

North Cascades Highway many species Numerous 

roadside

600+

Alta Lake Russian knapweed 2 3

dalmatian toadflax 4 436

Total New Invader 6 439

Lake Chelan-Sawtooth and 

Sawtooth Backcountry

common crupina Mostly 

continuous with 

1⁄2 of total acres 

on private land

600

Scotch broom

spotted knapweed

diffuse knapweed

oxeye daisy

Scattered 

populations

356

Total 956

*Diffuse knapweed populations are extensive along roads and not included in the new invader total 

for each subunit.
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Bear/Ramsey/Volstead

There are 15 known sites of dalmatian toadflax for a total of 189 acres within the open 

bunchgrass habitat on the south facing slopes of Ramsey, Pearrygin, Bear, and Cougar 

Creeks. Most roads have populations of diffuse knapweed with 690 acres total. There are 2 

small roadside sulfur cinquefoil sites and there are 4 closely associated small populations of 

orange hawkweed in old timber harvest units on the south slopes and in the bottom of 

upper Blue Buck Creek. These sites have not been affected by recently permitted outfitterguide activities (see below under Potential Invaders) because there is no overlap of actual 

areas used. The higher elevation areas with few roads and north facing slopes within this 

area are less suitable for weed establishment due to the dense conifer overstory and/or the 

understory dominated by pinegrass, a competitive native. The orange hawkweed and 

Dalmatian toadflax has been a priority for herbicide treatment with consistent and effective 

control. An average of 20 person days have been needed to control the 11 acres of orange 

hawkweed since treatment began in 2008. All 189 acres of dalmatian toadflax has been 

greatly reduced in population densities are currently very low.

Pasayten Wilderness

Currently the only known new invader weed populations in the Pasayten are whitetop sites 

at Black Lake and Hidden Lakes. The Black Lake site was buried by the debris of a mud slide 

after the Farewell fire of 2003; it is not likely to re-establish. The Hidden Lake site continues 

to be pulled by FS wilderness personnel. There are three known new invader sites on trail 

systems between the trailheads and the wilderness. The highest risk of spread is the 

relatively large oxeye daisy population at the Billygoat trailhead (see discussion under

Trailheads above). Otherwise, the Farewell Fire of 2003 increased the potential for weed 

establishment and spread within burned areas, however recent monitoring of trails has not 

detected any new establishment.

Lake Chelan-Sawtooth Wilderness and Sawtooth Backcountry

The only population of common crupina (Crupina vulgaris) in Washington occurs along the 

north shore of Lake Chelan, near the Fish Creek Base Camp and the Prince and Fish Creek 

trailheads. Common crupina is a Washington State Class A noxious weed. The infestation is 

on both public and private land, between Prince Creek and the uplake side of Hunts Bluff, 

from the lake level to around 3,500 feet elevation, and was likely introduced by early 

livestock grazing . No plants have been found over 3,500 feet elevation. The Lakeshore Trail 

cuts though some of the densest populations. Since the 2001 Rex Creek fire, and to some 

extent since 1988, crupina infestations along the trail were treated to prevent accidental 

spread by trail users. Treatment objectives have been a containment strategy and include 

hand-pulling where populations are sparse and herbicide spraying in the dense patches. 

The treatments have been mostly along the Lake Shore trail from Prince Creek to Hunts Bluff 

and have been effective in containing the spread. In 2003, the Forest Service issued the 

Crupina Control Record of Decision, and began treatments under this decision, however the 

state of Washington did a lot of treatment prior to this after it was first discovered. 

Between 2003 and 2011, 600 acres of crupina have been treated with herbicides, and 

treatments have been effective.

The following Class B noxious weeds are present at trailheads or along trails: Scotch broom 

(Cystis scoparius), spotted knapweed (Centaurea biebersteinii), and diffuse knapweed 
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(Centaurea diffusa). Oxeye daisy was found and pulled at one outfitter camp in the Fish 

Creek drainage. Knapweeds are pulled or sprayed at the Moore Point and Prince Creek 

trailheads as administrative sites, and along the Fish Creek and Lakeshore trails. There are 

944 gross acres of new invader weeds within this subunit and all are below 3,500’ elevation 

in relatively close proximity to the lake. 

There are 12 acres of new invader weeds in the Sawtooth Backcountry.

Middle Methow

The Twisp River road system has established populations of new invader noxious weeds 

including one population of a potential invader (Japanese knotweed) on private land. 

Diffuse knapweed has been a problem in the Twisp River area with dense populations along 

roads and in trailheads and campgrounds established in the 1990s. There is a total of 595 

acres of diffuse knapweed within the Middle Methow. Recent treatments under the 2001 

Okanogan Forestwide EA have greatly reduced weed densities. Small infestations of oxeye 

daisy, whitetop, and St. Johnswort are also present along roads. The area of greatest 

concern is the 3.5 acre whitetop site at the Slate Creek trailhead and associated outfitterguide base camp with a well-established population of whitetop inside the corral. 

Treatments have been effective in reducing the corral site population to a few scattered 

plants, but the trailhead still has low to moderate densities. In addition to diffuse 

knapweed, there are 18 sites and 66 gross acres of new invader weeds within this area.

North Cascades 

The Washington Department of Transportation administers the roadside of Highway 20 

under their easement; the area has well-established populations of noxious weeds. 

Common tansy, oxeye daisy, St. Johnswort , spotted knapweed, and dalmatian toadflax are 

common and can be present at most junctions with trailhead access roads. Rainy Pass and 

Canyon Creek are the two trailheads with known weeds on Forest Service administered land 

and have received some treatment as administration sites. St. Johnswort is common along 

the highway east of Rainy Pass and is scattered in patches. Common tansy is scattered 

evenly along the highway west of Rainy Pass to the Forest boundary. The weed populations 

are scattered extensively along the highway with the area of infestation exceeding 600 

acres.

Alta Lake

Dalmatian toadflax is found throughout this area with some widely scattered and a few 

dense patches. There are two populations of Russian knapweed in the bottom of Alta 

Coulee. One patch is along the horse trail near between Alta Ponds. The Russian knapweed 

sites have been effectively treated with herbicide under the 1998 Wenatchee Forestwide 

EA. The dalmatian toadflax is currently being treated under the Wenatchee Forestwide EA 

through a containment strategy in the Alta Pond area, but is too widespread and is under 

biological control elsewhere in the Coulee. There is a relatively large disturbed soil area in 

the Alta Coulee bottom near Alta Pond where public saddle stock continue to maintain the 

bare soil; weed densities are high along the perimeter of the impacted area. There is a high 

density of diffuse knapweed, in addition to Russian knapweed. There are three acres of 

Russian knapweed and 436 acres of dalmatian toadflax.
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Established Invaders

Lower-priority established invaders occur throughout the analysis area. These weeds are found 

Forest-wide and generally not site-specifically inventoried because they are so prevalent; 

however they are inventoried in wilderness.

Pasayten Wilderness

The following established invaders were detected in an around disturbed camp sites in the 

Sheep Mountain and Spanish Camp areas above 6,000’ elevation: lambsquarters 

(Chenopodium album), orchardgrass (Dactylis glomerata), tansymustard (Descurainia 

species), dwarf mallow ( Malva neglecta), black medic (Medicago lupulina), common 

plantain (Plantago major), knotweed (Polygonum species); red sandspurry (Spergularia 

rubra), northern starwort (Stellaria calycantha), longstalk starwort (Stellaria longipes), and 

white clover (Trifolium repens). These species are currently restricted to the most hardened 

and disturbed sites, but their potential for persistence and spread is not understood in these 

high elevation environments.

Lake Chelan-Sawtooth Wilderness and Alta Lake

Established Invaders include Canada thistle (Cirsium arvense) field bindweed (Convolvulus 

arvensis), and common mullein (Verbascum thapsus). Many non-native, undesirable species 

can be found along trails generally associated with the more open dry sites: dandelion 

(Taraxacum officinalis), yellow salsify (Tragopogon dubius), crane’s bill (Erodium cicutarium), 

orchard grass (Dactylis glomerata), bull thistle (Cirsium vulgare), horse-tail fern (Equisetum 

arvense), and prickly lettuce (Lactuca serriola). Non-native annual grasses including 

cheatgrass (Bromus tectorum), bulbous bluegrass (Bromus bulbosa), and slender fescue 

(Festuca vulpia) are also present.

Potential Invaders

Several sites outside the analysis area have potential to spread. In the 

Bear/Ramsey/Volstead area, there are four closely associated sites of orange hawkweed in 

timber harvest units on the south slopes and in the bottom of upper Blue Buck Creek. These 

are not affected by recently permitted outfitter-guide activities. As these small sites are 

isolated from most of the analysis area, they are classified as potential invaders. These sites 

have been surveyed and mapped. Yellow hawkweed is common along the highway west of 

the Forest boundary just inside the North Cascades National Park; it has potential to spread 

to trails along the North Cascades Highway. Several population of Japanese knotweed are in 

the Methow Valley Bottom, including the Chuwuch river valley bottom, and the Twisp River 

valley bottom. Sulfur cinquefoil is well established in the Cub Creek and lower Eightmile 

Creek areas with the potential to spread into the project area. 

Current Practices

Prevention and Management Strategy

The current strategy for invasive species management has four elements (USDA 2004b):

Prevention – Stop invasive plants before arrival.

Early detection and rapid response – Find new infestations and eliminate them before they 

become established.
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Control and management – Contain and reduce existing infestations.

Rehabilitation and restoration – Reclaim native habitats and ecosystems.

Each of these prevention and management strategy elements is addressed in detail in the 

analysis file, and the effects of this strategy are discussed in the cumulative effects analysis 

below.

ENVIRONMENTAL CONSEQUENCES

Direct and Indirect Effects

Alternative 1

This alternative would result in no issuance of pack and saddle outfitter guide permits. As a 

result, there would be 2% less pack and saddle stock traffic in the analysis area with this 

alternative compared to the current condition. Outfitters would not be permitted to use corrals 

or assigned sites. Introduction and spread of noxious weeds by pack and saddle outfitter-guide 

and associated vehicles would not occur. The trailheads, corrals, trails, and camp sites would 

still be used by the general public and non-pack and saddle outfitter guides, but by less vehicle 

traffic, stock and people than in the past. There would be a lower rate of weed spread and 

introduction expected, however less outfitter-guide presence and less recreation administrative 

activities would reduce the degree of new weed recognition and reporting. This would result in 

longer time frames for weeds to establish before being discovered, resulting in larger infestation 

sizes prior to initial treatment 

With fewer stock and people using an area, some vegetation recovery is expected. However, the 

general public and non-pack and saddle outfitter guides would continue to use these areas, so 

disturbance at these sites would continue. Elimination of pack and saddle outfitter guide 

services in these areas may result in more inexperienced stock and stock handlers from the 

general public entering the analysis area. Inexperienced stock or stock handlers could result in 

greater resource damage by disturbing more ground and creating more seed bed in the analysis 

area than would occur with a more experienced outfitter-guide. The risk of invasive 

introductions would continue with the general public and non-pack and saddle outfitter-guide 

use, but to a lesser degree because of fewer overall stock and people using the trails and 

campsites; this would likely result in a lower rate of spread and introduction.

Alternatives 2, 3, and 4

Introduction and movement of invasive species transported by animals would continue. Stock 

have the potential to further spread weed species into wilderness and elsewhere where suitable 

habitat exists. The mitigation measures specific to invasive species would mitigate potential 

effects by minimizing the potential establishment and spread of noxious weeds in the analysis

area and are analyzed below.

13a. Outfitter-guides and clients would be required to prevent the introduction and spread 

of noxious weeds on National Forest System land by removing any plant material attached 

to vehicles, shoes, clothing, or the bodies of pack and saddle stock. Compliance to this 

mitigation would be effective in the reduction of spread of plant material that is readily 

visible. As invasive plant seeds are often small and difficult to see, many seeds may attach 
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to vehicles, shoes, clothing, or pack and saddle stock without being detected. The 

effectiveness of this mitigation is proportional to the visibility of the plant material and the 

compliance of the outfitter-guides and their clients. 

13b. Outfitter-guides would be required to use only certified weed-free feed, commercially 

processed feed, or weed-free certified processed hay cubes on all National Forest System 

Land. This would be very effective in reducing the potential for establishment and spread 

as forage and mulch products sometimes contain seed or reproductive parts from nonnative, invasive and noxious weeds. National Forest lands are among the areas most 

vulnerable to impacts from weeds and are also, in general, where prevention of infestation 

is most likely to succeed. 

13c. Outfitters typically use processed hay when feeding stock in the backcountry or 

alternately, they turn animals out to loose graze native vegetation, reducing the risk of 

exotic species introduction. However, when stock graze on weedy areas at the home base, 

there is a risk that viable weed seed would pass through the animal while in the wilderness 

or backcountry and establish new weed populations unless it is fed certified weed free feed 

for several days before entering the backcountry. Although the mitigation measures ask 

pack and saddle outfitter-guides to consider feeding stock certified weed free feed several 

days prior to their trips, this mitigation has low effectiveness potential because they are not 

required to do so. It is expected that the potential for new weed introduction and spread 

through pack and saddle stock manure would be slightly higher in Alternatives 2 and 4 than 

in the recent past because of the larger number of pack and saddle stock permitted use in 

the analysis area. Alternative 3 would likely result in a slightly lower risk because of 

reduced permitted use. 

13d & e. As mitigation, a noxious weed Identification and mapping program would be 

designed specifically for pack and saddle stock outfitter-guides. This program would be 

designed in coordination with the District invasive plant specialist. It is expected that the 

implementation of this program would increase the number and distribution of people able 

to recognize potential new invaders, because pack and saddle outfitter-guides would be 

required to map and report invasive species. Pack and saddle outfitter guides spend a 

great deal of time in these backcountry and wilderness areas so early detection of newly 

found weed populations are far more likely than under the existing condition. Actual 

treatment would be implemented under other NEPA documents. Under the mitigation 

measures, outfitters would be required to assist in those future treatments. 

The Forest Plan amendments included in Alternatives 2, 3, and 4 would also help control the 

potential spread of invasive plants by limiting the barren core areas that could be used by pack 

and saddle outfitter-guides at wilderness campsites. Recovery of unused barren core would 

have no risk of weed establishment by pack and saddle outfitter-guides. Under the action 

alternatives, this potential for recovery is highest in Alternative 3, followed by Alternatives 2 and 

4.

Most of the invasive species and noxious weeds are not expected to establish and spread in the 

colder subalpine and alpine environments where most outfitter-guide campsites occur. All 

destination campsites are above 4,000 feet in elevation, which limits the establishment and 

persistence of most invasive species due to the colder environment. However, nearly all the 
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entry points into these destination camps start at lower elevations and in habitats suitable for 

most invasive and noxious weed species. Fish Creek, Andrews Creek, and Slate Creek base 

camps are below 4,000 feet, and most vulnerable for weed establishment. The primary habitat 

for common crupina is on hot, dry southern slopes in shrub steppe grassland and open 

ponderosa pine and Douglas fir forest below 2800 feet in elevation. There are 10 outfitter-guide 

camps (9%) in this habitat that are susceptible to invasion of this highly invasive plant. Crater 

Creek and Billygoat Creek base camps are above 4,000 feet but below 4,500 feet, leaving them 

slightly less vulnerable to most invasive species establishment, but still a concern. In addition, 

whitetop, oxeye daisy, orange hawkweed, and houndstounge have been found within the 

project area to do well at elevations above 4,000 feet in colder climates where most outfitterguide activities occur.

The current outfitter-guides are permitted 4,460 days of use. This number would be increased 

in Alternative 2 to 4,620, reduced to 2,660 in Alternative 3 (40% reduction from recently 

permitted level), or increased to 6,700 in Alternative 4 (50% increase). The potential for 

introduction and spread would range from similar (Alt. 2) to slightly less than (Alt. 3) to slightly 

more than (Alt. 4) under the recently permitted use, since these changes represent a 1% 

increase in the number of visitor days in Alternative, 1% decrease in Alternative 3, or a 3% 

increase in Alternative 4. These changes are too small to affect the overall potential for invasive 

plant introduction and spread. In Alternatives 2 and 4, outfitter-guides would use existing trails 

and camps; no new camps or trails would be developed. Alternative 3 would also require pack 

and saddle outfitter-guides to use existing trails and camps, but additionally would prohibit 

them from using established camps with 200 feet of wetlands, lakes, and steams. The camps 

that would be eliminated currently do not have any new invader weeds within them so this 

prohibition would not likely affect them. 

Cumulative Effects

This cumulative effects analysis considers effects of past, present, and reasonably foreseeable 

future actions within the analysis area. The geographic boundary for the cumulative effects 

analysis is the entire analysis area and areas where there is a potential for spread from adjacent 

lands, and the temporal boundary is the period of time from the early 1900s to well into the 

future. There is a potential for effects of weeds introduced under alternatives 2, 3, and 4 to 

continue long after permits issued under this document expire.

Reasonably Foreseeable Future Actions

The Forest is currently working on an EIS to permit invasive species treatment forest-wide which 

would allow treatments with all strategies in areas outside wilderness, and within wilderness 

treatment areas. This document is expected to be completed and implemented in 2013. The 

document analyzes new management strategies for controlling weeds, including those in 

riparian areas. The treatments under this EIS are expected to help control the establishment 

and spread of noxious weeds in the analysis area.

All new invader sites are authorized for treatment under current NEPA documents for an 

aggressive treatment strategy to contain, reduce, or eradicate the populations. Herbicides will 

continue to be used in areas approved under the 1997, 1999 and 2001 Integrated Weed 

Management EA (USDA Forest Service 1997e, USDA 1999a, and USDA Forest Service 2000d) 

Decision Notices, the 2003 Crupina Integrated Weed Management FEIS (USDA Forest Service 
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2003b) Record of Decision, and the 2008 Blue Buck Hawkweed EA and Decision Notice. 

Trailheads will continue to be a priority for weed surveys and treatment. Integrated weed 

management will reduce the risk of spread from currently infested areas on access roads, 

trailheads, and trails into the outfitter-guide activities areas.

All the known new invader noxious weed sites in and adjacent to the analysis area are being 

prioritized for integrated weed management. Integrated weed management would continue in 

the new invader weed infestations on recreation access roads, trail heads, trails, corrals, camps 

and off roads in areas where weeds may spread to impact recreation facilities and activities. 

Integrated weed management would be accomplished by implementing a combination of all the 

control methods available with emphasis on early detection of new infestations, rapid 

treatment response, and prompt revegetation. The combination of herbicide, manual, and 

cultural treatment together would provide effective control of small populations. District weed 

treatments with herbicides are authorized under the1997 and 2000 Weed EA Decision Notices 

and the 2003 Crupina EIS Record of Decision.

All types of recreation will continue to be vectors for disturbance and weed spread in the 

analysis area, including, but not limited to outfitter-guide packing, hiking, camping, mountain 

biking, and trail maintenance/rehabilitation.

Commercial livestock grazing can continue to transport weed seeds across the landscape with 

dispersal into disturbed areas, although only outside wilderness since commercial grazing no 

longer occurs in wilderess. Given the existing low noxious weed densities in the analysis area, 

and that there are virtually no areas where outfitter-guide activities occur in commercial 

livestock (cattle) grazing areas, so the likelihood of outfitter-guide stock to spread weeds 

introduced by cattle is low.

Alternative 1

The cumulative effects of Alternative 1 and all past, present, and reasonably foreseeable future 

actions would continue to provide vectors for weed spread although not in conjunction with 

outfitter-guide activities under this decision. Current disturbances would continue to provide 

sites suitable for weed establishment. Control of existing weeds would continue to occur under 

the existing Integrated Weed management decisions which would result in reductions in weed 

populations. A Forest-wide EIS is planned for completion in 2012; the decision would likely help 

to control the spread and establishment of invasive plants in the analysis area because 

additional areas and more effective and less impactful herbicide treatments could be used. The 

combination of herbicide, manual, and cultural treatments together would provide effective 

control of small populations. Treatments would be conducted by the District Weed program 

with herbicide treatments authorized under the 1997, 1999 and 2001 Noxious Weed EA 

Decision Notices, the 2003 Crupina EIS Record of Decision, and the 2003 Blue Buck Hawkweed 

Decision.

No cumulative effect would occur because outfitter-guides would not be adding any incremental 

effects, although short-term increases in amounts of established invaders and slight increases in 

the amount of new invaders may occur from use by the general public and non-pack and saddle 

outfitter-guides. Recovery of unused barren core would have no risk of weed establishment by 
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pack and saddle outfitter-guides, however there is a potential for the public to spread weeds 

into these areas. 

In the long-term, with implementation of weed prevention awareness by recreationists, 

including on-going weed management, weed populations would be reduced.

Alternatives 2, 3, and 4

The risk of invasive plant introduction and spread would be reduced through an Integrated 

Weed Management approach, implementation of mitigation measures in this analysis and weed 

control treatments. A Forest-wide EIS is planned for completion in 2013; the decision would 

likely help to control the spread and establishment of invasive plants present in the analysis area 

with more effective, less impactful treatments. The combination of herbicide, manual, 

biological and cultural treatments together would provide effective control of small populations. 

Treatments would continue to be conducted by the District Weed program with herbicide 

treatments authorized under the 1997, 1999 and 2001 Weed EA Decision Notices, the 2003 

Crupina EIS Record of Decision, and the 2008 Blue Buck Hawkweed Decision Notice. With 

implementation of mitigation measures included in Alternatives 2, 3, and 4, and on-going weed 

management, weed populations would be reduced. The combination of these actions would 

lessen the threat of invasive plants to native plant communities in the analysis area as a result of 

outfitter-guide activities, even with increased numbers because of the increase in mapping, 

reporting and awareness by outfitter guides.

The continued effective control of Crupina would greatly reduce the potential of spread by 

outfitter-guide activity to other area within its primary habitat. With only 9% of the outfitterguide camps within habitat that is susceptible to invasion, the likelihood of establishment of

seed dispersal by outfitter-guide activities is relative to the limited suitable habitat within the 

project area. 

Implementation of the Prevention and Management Strategy located in the analysis file with 

emphasis on early detection and rapid response to any new found populations would reduce 

the likelihood of the establishment of large new invader infestations.

Although the mitigation measures recommend pack and saddle outfitter-guides to consider 

feeding stock certified weed free feed several days prior to their trips, this mitigation has low 

effectiveness potential because they are not required to do so.

Summary Statement

The cumulative effects of all past, present, and reasonably foreseeable future actions would be 

short-term increases in amounts of established invaders and slight increases in the amount of 

new invaders. In the long-term, with implementation of mitigation measures and an increase in 

weed prevention awareness by outfitter-guide and recreationists including on-going weed 

management, weed populations would be reduced.
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CONSISTENCY FINDINGS

All alternatives are consistent with the both the Okanogan and Wenatchee Forest Plan, and 

2005 PNW Rod standards and guidelines. 

Okanogan National Forest Plan Standards and Guidelines

12-1: Control noxious weeds to the extent practical. 

Mitigation measures 14 a-e would control noxious weeds potentially spread or 

introduced by pack and saddle stock outfitter-guide activities to the extent practical. 

12-2: New infestations of noxious weeds should be the first priority for eradication.

This standard and guideline does not apply to pack and saddle stock outfitter-guide 

operations. 

12-3: Emphasis on noxious weed control shall be on the prevention of infestations, 

especially into unroaded areas and wilderness.

Mitigation measures 14 a-e would prevent noxious weed infestations, to the extent 

practical, by pack and saddle stock outfitter-guides. Nearly all their activity is in 

unroaded areas and wilderness, so the prevention measures would reduce the risk of 

introducing weeds into these areas. 

Wenatchee National Forest Plan Standards and Guidelines

Cooperate with the Washington State Noxious Weed Control Board and other state, 

county and local agencies and organization in the identification, location, prevention 

and spread of noxious farm weeds.

This guideline regarding noxious farm weeds does not apply to this project. 

Develop an Action Plan for inventory and monitor populations of noxious weed 

populations on the Wenatchee National Forest.

Mitigation measures 14 d and e would require the pack and saddle stock outfitterguides to monitor for weeds within campsites, and follow a weed identification and 

mapping program under the direction of the Forest Service. These inventory and 

monitoring measures would comply with this standard and guideline.

Conduct a noxious weed assessment for all significant ground disturbing project 

activities to determine the risk of introducing noxious weeds and develop a plan to 

prevent introduction on moderate and high risk sites.

The pack and saddle stock outfitter-guide activities would not cause significant ground 

disturbance so this standard and guideline does not apply. None-the-less, mitigation 

measures 14 a-e would reduce the risk of pack and saddle stock outfitter-guide 

activities introducing noxious weeds. 

Contain, control or eradicate existing populations as budget allows.

This standard and guideline does not apply to the pack and saddle stock outfitterguide permits, since treating existing populations is not part of the purpose and need. 
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2005 PNW Rod Standards and Guidelines

The applicable 2005 PNW ROD (USDA Forest Service 2005a) standards are included in 

mitigation measures 14a-e and the analysis provided above. These measures would apply 

to all alternatives, ensuring compliance with these standards and guidelines. 

3.10 RANGE RESOURCES

The section below is a summary of the Range Report which is available in the project analysis file

(McFetridge 2012a).

REGULATORY FRAMEWORK

The Okanogan National Forest Land and Resource Management Plan (Forest Plan, USDA Forest 

Service 1989b) established management goals. The objective of range management is to 

protect resources and continue the management of the affected commercial5grazing allotments 

(designated areas to graze) while providing for recreation opportunities. All active allotments 

within the project area are managed according to standards and guidelines in the Okanogan 

Forest Plan. 

The following forest-wide standards and guidelines apply to commercial grazing and 

recreational livestock grazing associated with pack and saddle stock outfitter-guide activities.

11-4 and 11-5: Forage utilization standards outside and inside riparian areas. Refer to tables on 

pages 4-43 and 4-44 in the Okanogan National Forest Plan.

11-6: Range structural and non-structural improvements and maintenance shall conform with 

the resource emphasis of the Management Area and shall be specified in the AMP.

11-7: Range improvements and practices shall not be designed to increase livestock use in 

riparian ecosystems, but should enhance riparian ecosystems.

Some management-area specific standards and guidelines also pertain to the pack and saddle 

stock outfitter-guides. These are listed by sub-unit below. These Management Areas are shown 

on the sub-area maps in the Map Section. 

 

5

Because this analysis discusses two types of grazing, recreational stock grazing by outfitter-guides, and 

grazing permitted through the allotment management process, the latter is referred to as “commercial” 

livestock grazing for clarity.
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Pasayten Wilderness

The Pasayten Wilderness is divided into Management Area 15A and 15B. Pack and saddle stock 

outfitter-guides are not permitted to operate or graze recreational livestock in 15A, so none of 

the standards and guidelines there apply to the outfitters. 

Management Area 15B: 15B-11B: The forage resource shall be utilized in conformance with all 

wilderness resource values. 

Lake Chelan-Sawtooth Wilderness

The Lake Chelan-Sawtooth Wilderness is divided into Management Areas 15A and 15B in the 

portion on the Methow Valley Ranger District (Okanogan Forest Plan) and WI-1 in the portion on 

the Chelan Ranger District (Wenatchee Forest Plan). Pack and saddle stock outfitter-guides are 

not permitted to operate or graze recreational livestock in 15A, so none of the standards and 

guidelines there apply to the outfitters. There are no standards and guidelines for WI-1 that 

pertain to pack and saddle stock recreational livestock grazing. 

Management Area 15B: 15B-11B: The forage resource shall be utilized in conformance with all 

wilderness resource values. 

North Cascades

This area includes Management Areas 4, 5, 7, 10, 17, and 25, in addition to Late Successional 

Reserves, Administratively Withdrawn, and Riparian Reserves, from the Okanogan Forest Plan, 

as amended by the Northwest Forest Plan. 

There are no standards and guidelines that pertain to recreational stock grazing by pack and 

saddle stock outfitter-guides in management areas 4, 5, and 25. 

Management Area 7: MA7-11A Domestic livestock grazing shall not be permitted. Recreation 

livestock grazing shall be permitted except for the meadows at Rainy Lake turnoff and Whistler 

Basin. Users should be encouraged to use weed-free hay.

Management Area 10: MA10-11A Livestock use should not be increased over existing permitted 

numbers. The goal for Management Area 4 is to: [p]rovide semi-primitive non-motorized 

recreation opportunities during summer and fall seasons (4-61).

Sawtooth Backcountry

The Sawtooth Backcountry includes Management Area 4M on the Methow Valley District 

(Okanogan Forest Plan), and Management Area RE2a on the Chelan District (Wenatchee Forest 

Plan), as amended by the Northwest Forest Plan.

There are no standards and guidelines for Management Area 4M that apply to recreational 

livestock grazing by pack and saddle stock outfitter-guides. The standards and guidelines for 
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Management Area RE2a that apply to the outfitter-guides are listed below. The remaining 

standards and guidelines for that management area do not apply.

Management Area RE2a (page IV-66, Wenatchee Forest Plan)

Grazing of suitable range by livestock shall emphasize range management practices that 

favor unroaded, motorized, dispersed recreation.

Management of the range resource under this prescription will seek full utilization of 

forage allocated to livestock.

Control noxious weeds as practical.

Bear/Ramsey/Volstead

This area includes Okanogan Forest Plan Management Areas 14, 25, and 26, as amended by 

PACFISH (see Aquatics section for PACFISH regulatory framework). There are no standards and 

guidelines in these management areas that pertain to pack and saddle stock recreational 

livestock grazing. 

Middle Methow

This subsection is divided between Management Areas 5, 10, and 25, in the Okanogan Forest 

Plan, as amended by the Northwest Forest Plan. 

There are no standards and guidelines that pertain to recreational stock grazing by pack and 

saddle stock outfitter-guides in management areas 5 and 25. 

Management Area 10: MA10-11A Livestock use should not be increased over existing permitted 

numbers. he goal for Management Area 4 is to: [p]rovide semi-primitive non-motorized 

recreation opportunities during summer and fall seasons (4-61).

Alta Lake

This subsection is divided between Management Areas 5 and 14 in the Okanogan Forest Plan, as 

amended by the Northwest Forest Plan. There are no standards and guidelines that pertain to 

pack and saddle stock outfitter-guide recreational livestock grazing for these management 

areas.

ANALYSIS METHOD

The geographic boundary for range is the analysis area plus the area of all pastures within 

commercial grazing allotments that overlap outfitter-guide activities (active trailheads, trails, 

camps). The temporal boundary is the period of time from the 1900s through 2024 because the 

permits that would be issued under this analysis would expire at that point and impacts from 

them would cease. Any impacts to vegetation from pack and saddle stock outfitter-guide 

recreational grazing would recover within a year after grazing ceases.
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This analysis assesses the effect of the proposed alternatives on six livestock grazing allotments 

and the effect of current and historic grazing using the best available science. The following 

specific indicators are used to describe the direct, indirect and cumulative effects.

Qualitative and quantitative discussion about the impacts of historic sheep and cattle 

grazing activities in the project area compared to the level of current impacts.

The cumulative effects of outfitter-guide pack and saddle stock and commercial livestock 

(cattle and sheep) grazing, and compliance with Forest Plan standards and guidelines.

Number of Animal Unit Months (AUM) of forage utilized by outfitter-guide pack and saddle 

stock compared to the number of historic AUMs of forage utilized in grazing allotments.

Qualitative discussion of outfitter-guide stock grazing.

AFFECTED ENVIRONMENT

There is currently no permitted commercial livestock (cattle or sheep) grazing in the Pasayten 

Wilderness, Lake Chelan-Sawtooth Wilderness, or the Sawtooth Backcountry areas. All prior 

allotments are vacant or closed. Vacant allotments are schedule for NEPA analysis to update the 

allotment management plan or to close the allotment.

The Bear/Ramsey/Volstead, North Cascades, Middle Methow, and Alta Lake areas have some 

level of commercial livestock grazing, however there are virtually no areas where outfitter-guide 

activities, especially pack and saddle stock grazing, occurs in the livestock (cattle or sheep) 

grazing areas. There are no deluxe or progressive camps or the associated trails or trailheads in 

permitted livestock grazing areas. The recreation activities that occur within the livestock 

allotments are typically day use with hiking or saddle horse riding. The only outfitter-guide 

activity within livestock allotments is taking clients to drop camps with no overnight pack and 

saddle stock use or passing through the allotment to camps outside the allotment. The day use 

activities utilize a negligible amount of forage with no measurable impacts on the rangeland 

resource. The primary foraging areas within commercial livestock grazing allotment are 

associated with road systems and with the livestock utilizing the transitory range within historic 

timber harvest units adjacent to roads. The current pack and saddle stock outfitter-guide 

activities in general are almost exclusively within the areas with no roads. Because of this there 

is virtually no overlap of livestock grazing and these outfitter-guides activities. There are no 

areas with range resource impacts of both outfitter-guide stock and livestock (cattle or sheep) in 

the same area.

Grazing History

The analysis area has a long history of grazing. In the recent past (1960s), there were 6,464 

AUMs grazed by livestock. In the early to mid-1900s, there were 15,000 AUMs grazed annually. 

According to Forest Service records, sheep grazing was first introduced in about 1908, but 

possibly earlier. During the World War I years, the number of sheep grazing in the area 

increased dramatically, and then gradually decreased until after Work War II, when most of the 

sheep allotments were changed to cattle allotments. At their peak, there were many thousands 

of sheep grazing in the Pasayten and the Lake Chelan-Sawtooth areas. Typically the Forest 

Service regulated and documented sheep band size based upon the number of mature ewes. 

The number of lambs were unregulated which would indicate that the total number of sheep 

documented in the Forest Service records was likely much higher.
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To support early livestock operations, numerous mountain trails were built. Many of these trails 

still exist today as Forest Service system trails. Some trails were constructed to provide access 

to sheepherder camps and grazing lookout sites. Many of these camps continue to be used 

today by recreationists and outfitters. Numerous sheep and cattle driveways were constructed 

to enable livestock to access key use grazing areas but no longer used for commercial grazing.

Allotment records indicate that during 1920 and 1930 many grazing allotments could no longer 

support the large sheep numbers. Available forage had declined tremendously. Domestic 

sheep numbers steadily declined through the 1940s, 1950s, until present. The last sheep permit 

in the Pasayten was converted to cattle in 1949; cattle grazed the area until 1994 then waived 

back to the Forest Service in 1999.

Compared with sheep, cattle operations are more recent and more closely monitored by the 

Forest Service. Grazing is closely monitored for forage utilization. Other than localized areas of 

high use, no detrimental grazing practices have been documented on the currently active 

allotments.

Sheep camps and trails were established by the sheep grazing operations. Current system trails 

used by Outfitter-guides are often on the same footprint as the old sheep trails.

The overuse and unsatisfactory management in the early years is still evident. Grazed areas are 

slowly returning to pre-grazing conditions, however many of the sheep driveways and sheep 

camps can still be identified by the sparse vegetation and differences in plant species 

composition compared to areas not grazed. With the closing of the wilderness livestock 

permits, even with outfitter-guide grazing, the forage use and resource impacts are far below 

the use and impacts under the old commercial grazing allotment stocking rates. 

Pasayten Wilderness

Sheep grazing in the Pasayten peaked in the early 1900s when as many thousands of sheep 

traveled from Horseshoe Basin to the crest of the Cascades. The high number of sheep began to 

fall by the mid-1900s until allotments were vacated in the late 1990s. The grazed areas are 

slowly returning to pre-grazing condition, however many of the sheep driveways and sheep 

camps can still be identified by the sparse vegetation and differences in plant species 

composition compared to areas not grazed.

Sheep grazed the Cathedral Allotment from 1909 to 1948 reaching a peak of 5 bands (5000 ewes 

with lambs) around 1912. By 1921 numbers had been reduced to one band on Beaver Creek, 

Bob Creek, and Bald Mountain from July 15 to September 15. In 1949 the allotment was 

converted to cattle with 350 head of yearlings on the Bald Mountain, Beaver Creek, Bob Creek, 

and Remmel Lake area. From 1949 to 1967 actual use ranged from 340 to 520 head. In 1968 

the permit was changed to a 300 cow/calf permit. In 1981 the Cathedral Allotment was 

converted to the Remmel Mountain Allotment with two units, the Bob Creek unit in the Bald 

Mountain area and the Coleman Ridge unit in the Remmel Lake area. The Remmel permit was 

160 cow/calf pairs from July 15 to September 30 and was waived back to the government in 

1999 with the last year of grazing in 1994. There were 528 AUMs in this area.
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The Horseshoe Basin Allotment was first used by sheep from 1910 to 1964 with 4 years of nonuse between 1948 and 1951. Boundaries of the allotment have changed slightly from time to 

time but in general the total area has remained the same. The Remmel Lake fire of 1929 and 

the Toats Coulee fire of 1930 created transitory forage, opening up considerable land to grazing 

through 1947. During the period when the burns produced lush feed, two bands totaling 2000 

sheep were allowed to graze. In 1948, it was thought the allotment was being overused and 4 

years of non-use were implemented and numbers were decreased to 1,200 head through 1964. 

Between 1961 and 1966 economics made it desirable to transition from sheep and convert the 

entire allotment to cattle. In 1972 the cattle permit was relinquished and by 1976 the allotment 

was converted back to sheep. Sheep grazing continued on the allotment until 1997 with 1,100-

1,200 ewe/lambs from early July to mid-September. The permittee waived the allotment back 

to the Forest Service in 2000. There were 480 AUMs in this area.

Lake Chelan-Sawtooth Wilderness, Sawtooth Backcountry, and Middle Methow

The grazing history dates back to 1912 with 5400 sheep grazing the Foggy Dew Creek-Merchants 

Basin portion. Use in the Horsethief Basin area by sheep dates back to 1921. During 1913-1916, 

records indicate that 5,000 sheep were permitted in the Chelan Summit area, from Sunrise Lake 

to Surprise Lake. In 1929 several allotments were combined into two major allotments. Crater 

Creek and Foggy Dew Creek were the Foggy Dew Allotment. East Fork Buttermilk, Fish Creek, 

and Meadow Creek were the Buttermilk Allotment. From 1929 to 1943 the combined permitted 

use for the two allotments was 1,200-2,400. In 1944, the two allotments were combined as the 

Buttermilk Allotment with one band of 1,200 to 2003 – the last year it was grazed. The season 

of use was May 15 to October 15 then shortened to September 30 in 1946, and in 1951, the 

most recent season of use was established from June 1 to September 30. There were 975 AUMs 

in this area.

The Horsethief Allotment (Horsethief Basin area) was grazed by 60 to 70 cow/calf pair until the 

permit was waived back to the Forest Service in the 1990s. The Lake Chelan side in the Hunter 

McFarland Allotment from the ridge top to the lake including Safety Harbor Creek east to 

Mitchell Creek was converted a couple times from sheep to cattle to sheep pending economic, 

or more recently, resource concerns. The permitted use was 1,200 ewes/lambs or 250 cow/calf 

pairs. The sheep portion of the permit was waived back to the Forest Service to aid in the 

introduction of California big horn sheep in 1999. The only active portion of the permit remains 

on the Methow Valley District side which is all outside the project area. Virtually all of the 

Sawtooth Backcountry was included under the Sawtooth Recreational Allotment and there was 

also a permit to graze 30-40 head of horses in the Prince Creek area in the 1980s. There were 

1,300 AUMs in this area.

The Wolf Creek area was used by sheep from 1900 to 1930 and heavily used for 20 to 25 years. 

Records show that the area west of the North Fork of Wolf Creek constituted the area for sheep 

and the area east of the North Fork to the Forest Boundary was used by cattle. The best range 

was within the sheep area and it was determined to be overgrazed. In 1930 the entire Wolf 

Creek drainage was included in the Wolf Creek Cattle Allotment and grazed until the wilderness 

portion was waived back to the Forest Service in 2000. The numbers fluctuated between 130 

and 236 cow/calf pair with the season of use starting at June 1 to October 31 and gradually 

shortened to June 1 to September 30 by 1960. The permit was reduced to 60 cow/calf pair in 

2000 when the wilderness portion of the allotment was waived back to the Forest Service. 

There were 1,070 AUMs in this area before the permit was reduced in 2000.
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Okanogan-Wenatchee National Forest

Bear/Ramsey/Volstead

The Ramsey Creek Allotment has been used by cattle since about 1900; it includes the Ramsey, 

Pearrygin, Bear drainages. The area was heavily grazed from 1906 to 1920. This allotment 

extends along the Forest boundary for 10.5 miles and with large number of homesteaders 

adjacent to the allotment; trespass was common and early and late grazing was the practice. At 

peak stocking between 1910 and 1920, 265 head were permitted. At that time there was no 

boundary fence and the more gentle slopes and natural feed areas extended on into the Forest 

and there was a high percentage of trespass by unauthorized stock. The greatest damage to the 

lower portion of the range came from the trespass cattle and horses of the homesteaders. One 

hundred head of cattle and 300 head of horses roamed the area as late as 1925. This use 

peaked between 1910 and 1918. Cattle numbers were reduced through shifting permittees to 

other allotments and because the homesteads were abandoned. The last of the homesteads in 

this area were purchased in 1943 and 1944, by Washington State. In 1948 a boundary and drift 

fence was built by the State from Boulder Creek to Beaver Creek. The season of use on the 

range was changed in 1947 from April 1 to October 30, to June 1 to October 15. The last 

stocking adjustment was made in 1950 to June 1 to September 30. There are currently 322 

AUMs in this area under a new AMP completed in 2007.

The Beaver allotment (Volstead Unit) has been used since 1916. The first year recorded cattle 

permit was for 53 cow/calf pairs from April 15 to October 15. The highest number of permitted 

cattle was in 1920 for 319 cow/calf pairs from April 15 to October 15. The allotment was 

officially converted from sheep to cattle in 1942, however, during the 1950’s, there were at least 

2 bands of sheep permitted to route through the allotment in addition to the cattle permits. 

Sheep were typically grazed at the higher elevations until it was later converted to all cattle. In 

1964 an allotment management plan (AMP) was written that allowed 128 cow/calf pairs to 

graze from June 1 to September 30. This included 50 pair on the Beaver Meadows unit from 

July 1 to September 30 and 78 pair on the rest on the allotment. In 1972 the Cougar Creek area 

was added to the Beaver allotment and to increase the cattle numbers from 78 to 140 cow/calf 

pairs. The plan for the Beaver Meadows unit remained at 50 pair from July 1 to September 30. 

In the late 1980s resource damage became evident in the Beaver Meadows unit and the unit 

was rested for resource protection in 1992 and was closed to grazing in 2004. Currently 110 

cow/calf pairs graze the Volstead unit from late June to early August with a total of 186 AUMs. 

North Cascades

The Harts Pass Sheep Allotment and the Goat Cattle Allotment are in the North Cascades area. 

The last allotment management plan for the Harts Pass was 1985 with 1,200 ewe/lambs grazed 

in conjunction with the Buttermilk sheep allotment. The Harts Pass allotment was grazed until it 

was waived back to the Forest Service in 2000. There were 560 AUMs in this area.

The Goat Allotment has been grazed by cattle since 1910. In 1950, the land between Goat Creek 

and Lost River was designated as the Goat Allotment. Cattle numbers stabilized to 170 cow/calf 

pair with the season of use June 1 to September 30 from 1965 to the present. There are 

currently 756 AUMs in this area under the new allotment management plan. Although the 

Forest Service issued a revised Goat AMP decision on September 25, 2007, it was later 

withdrawn as a result of NEPA deficiencies and management reverted to the old AMP until the 

most recent NEPA was completed in 2012 to update the AMP.
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The Boulder Allotment was grazed exclusively by sheep from 1923 to 1938 with 500 to 1,900 

ewe/lambs. The use by sheep included south slopes and bottom range areas in the first few 

miles of Early Winters Creek above the confluence with Cedar Creek. The allotment was 

converted to cattle in 1938 with100 cow/calf pair for 5 months, and then shortened to 4 months 

in 1949. By 1983 the numbers were reduced to 62 cow/calf pairs from June 15 to September 30 

with pastures north of Early Winters Creek and west of Cedar Creek dropped from the 

allotment. Currently the permitted use is 40 cow/calf pair from June 1 to September 30 every 

other year. There are 291 AUMs in this area.

Alta Lake

The Alta Coulee Allotment has been grazed by 25 cow/calf pair of cattle for many years. In 

recent years only the bottom of the coulee has been grazed in conjunction with private land on 

Antoine Creek; the Alta Pond area has been rested.

Permitted Livestock Grazing within the Project Area

The following are brief descriptions of the livestock grazing allotments that may have the 

potential to be impacted by outfitter guide activities. Grazing within each of these allotments is 

currently meeting Forest Plan allowable forage use standards and Streambank Alteration 

standards (Cowley et al. 2006).

Bear/Ramsey/Volstead

Beaver Allotment is 43,947 acres with four separate pastures (grazing areas) operating under 

the 2007 Allotment Management Plan (AMP). The grazing system is a deferred-rest rotation. 

Currently the permit allows 140 cow/calf pairs to graze annually from May 10 to September 30, 

which equals 887 animal unit months (AUM, the amount of dry forage required by a 1000 pound 

dry cow for one month – 1 cow/calf pair is 1.32 AUMs see glossary). This system utilizes two 

early season grazing pastures (Burns Canyon and Cougar) grazed and rested on alternating 

years, one mid-season unit (Volstead) and one mid-late season unit (Middle Fork). The Loup 

Loup and Wolf units in the Frazer allotment are grazed in conjunction with the Beaver allotment 

as needed to allow flexibility in grazing strategies and/or providing for more rest for units in 

both allotments. The pastures are mainly divided by natural barriers. There is one outfitterguide drop camp in the Beaver allotment. Both the outfitter-guide stock and commercial 

livestock use portions of the same access trail to the drop camp with a negligible amount of 

forage use by outfitter-guide stock occurring.

Ramsey Allotment is 12,312 acres with three pastures. Currently the permit, under the 2008 

AMP, allows 63 cow/calf pairs annually from June 1 to September 30, which equals 338 AUMs. 

Although permitted use dates are June through September, the pastures are used in an early 

season grazing system to limit use in the hot dry late season which has less water and palatable 

forage. Typically 76 cow/calf pairs and 14 yearlings graze from June 1 to August 31. The 

prescribed grazing system is rest-rotation using each pasture (the Ramsey, Pearrygin, and Bear 

units). Each unit receives a period of early summer grazing, followed by a year of rest, followed 

by a year of deferment where the unit is grazed in late summer in the third year. Each pasture is 

grazed for about 45 days. The pastures are mainly divided by natural barriers. There are no 

pack and saddle stock outfitter-guide camps in this allotment.
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North Cascades

Goat Allotment consists of 18,125 acres and is located in Goat (5,208 acres), Upper Methow 

River (9,626 acres) and the Lost River (3,291 acres) watersheds. There are two grazing 

permittees on the allotment. 

An Environmental Assessment (EA) was completed in 2012 that will allow grazing in the Goat 

Allotment with a revised allotment management plan (AMP). Recent permits allowed 170 

cow/calf pairs to graze from June 1 to September 30 each year, which equaled 900 AUMs. One 

permittee had a permit for 126 cow/calf pair and the other had a permit for 44 pair. The second 

permit (44 pair) was vacant for 7 years. Under the revised AMP, the Goat allotment will be 

grazed with 170 cow/calf pairs but with a reduced season of use. Specifically, 44 cow/calf pairs 

will graze in the Goat allotment for 47 days and 126 cow/calf pairs will graze for 122 days. The 

total permitted animal unit months for the allotment will change from 900 AUMs to 756 AUMs. 

The reduction in the season of use is based on current estimates of forage production.

The present rest rotation grazing system utilizes four units, two early summer units, Spokane 

Gulch and Yellow Jacket, and two late summer units, Black Pine and Whiteface. The early 

summer units are used on alternate years, and the late summer units are utilized each year with 

deferment. There are two drop camps in the Yellow Jacket Unit. Both the outfitter-guide stock 

and commercial livestock use portions of the same access trails to the drop camp with a 

negligible amount of forage use by outfitter-guide stock occurring.

Boulder/Wolf Allotments are grazed together under one grazing rotation with one permittee. 

The Boulder allotment consists of 7,801 acres and is located in the Little Boulder Creek, Looney 

Creek watersheds and portions of the Huckleberry Creek, and Cedar Creek watersheds. The

Wolf allotment grazing area is 10,502 acres with three pastures, Rader, Little Wolf, and Falls 

Creek only the Little Falls Creek pasture in the project area, in the Little Falls Creek watershed. 

The existing AMPs for both Boulder and Wolf allotments are currently out of date and scheduled 

to be revised in 2012.

Currently the permit allows 60 cow/calf pairs to graze from June 1 to September 30 every year, 

which equals 244 cow months or 322 animal unit months (AUM). The grazing strategy is to 

graze the Boulder allotment and the Falls Creek pasture on even years with 40 cow/calf pairs in 

Boulder and 20 cow/calf pairs in Little Falls Creek with complete rest on even years where the 

other pastures of the Wolf allotment are grazed. There are four outfitter drop camps within the 

Boulder allotment and a drop camp in the Falls Creek pasture. Both the outfitter-guide stock and 

commercial livestock use portions of the same access trails to the drop camp with a negligible 

amount of forage use by outfitter-guide stock occurring.

Middle Methow, Sawtooth Backcountry, and Lake Chelan-Sawtooth Wilderness

Buttermilk Sheep Allotment is in the Middle Methow, Sawtooth Backcountry (Methow), and 

Lake Chelan-Sawtooth Wilderness areas. The 52,974 acre allotment was in non-use between 

2000 and 2005, except in 2003, when partial use occurred and has been vacant since 2006 when 

the last grazing permit expired. The sheep were routed through the allotment with a herder 

with restrictions on bedding and trailing to reduce resource impacts. This allotment was grazed 

in conjunction with the Harts Pass allotment that was waived back in 2000. Currently the permit 

allows 1,200 ewe/lambs from May 1 to July 10. The season can be modified to provide for a 

later season of use to adjust for loss of the Harts Pass allotment which was grazed in the late 
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summer. The Crater Creek outfitter-guide base camp (corral) and trail system is in the 

Buttermilk allotment. Only a negligible amount of forage use is occurring by the outfitter-guide 

stock occurring.

Alta Lake

The Alta Coulee allotment is 3,249 acres with two pastures. Currently the permit allows 25 

cow/calf pairs annually from June 1 to September 30, which equals 102 AUMs. Although 

permitted use dates are June through September, the pastures are typically used for less time 

than the permitted season as the permittee keeps the permitted cattle on his private land 

pasture during the early part of the permitted period of use. The allotment boundary includes 

several sections of land but only the bottom of the coulee is grazed by the 25 cow/calf pair, in 

conjunction with the aforementioned private land to the south. There is a fence that divides the 

Alta Pond area from the south part of the coulee. The pond area is grazed early for two weeks 

then the cattle are excluded for the remainder of the season. The pond area has been rested 

voluntarily by the permittee for the past five years as approved by the Forest Service with the 

benefit of reducing impacts to the pond riparian area. There is a day use recreation trail system 

within the rested Alta Pond area. It is not likely that the pond area will be grazed in the future 

but it will remain in the permit if needed. The trail used for day-rides passes through this 

allotment.

Pack and Saddle Stock Grazing within the Project Area

The pack and saddle stock outfitter-guides have recently been permitted 270 Animal Unit 

Months (AUM) in the analysis area. This is noticeably lower than the 6,464 AUMs grazed by 

commercial livestock in the recent past (1960s), and substantially lower than the 15,000 AUMs 

allotted to the area in the early to mid-1900s.

Outfitter guide stock forage utilization is well within allowable use standards with the exception 

of localized areas of high use that can be associated with the camps. Forest Service monitoring 

guidelines specify that monitoring sites should be located outside livestock concentration areas 

and should be free of compounding use, such as the use directly around outfitter camps (Burton 

et al. 2011). Monitoring representative areas outside the camp allow cause-and-effect 

relationships to be established. Outfitter guide stock forage utilization monitored in 

representative locations as dictated by Forest Service monitoring guidelines is well within 

allowable use standards. With the closing of the wilderness livestock permits, even with 

outfitter guide grazing, the forage use and resource impacts are still far below the use and 

impacts under the old commercial grazing allotment stocking rates. Where and whenever it 

becomes necessary to restrict or limit the use of native forage by pack and saddle stock for 

resource protection, the outfitter may be required to pack in and supply all necessary feed. This 

would further reduce the potential for potential negative impacts for dual use by cattle and 

outfitterguide stock.

Loose Grazing and Stock Containment

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

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

to trees for short durations, tying to hitch rails or highlines (a line used to hitch stock to avoid 

tying directly to trees by tying a rope between two trees, then tying the stock to the rope), 

picketing stock, or holding them in a corral. Loose grazing is a technique where the stock are let 
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loose to graze. Drift fences made of natural materials, usually poles and logs, are used in some 

cases to keep loose stock from incidentally traveling down trails. There are ten drift fences in

the Pasayten and Lake Chelan-Sawtooth wilderness areas, including at Andrews Pass and on the 

Whistler Cutoff trail north of Slate Peak. Loose grazing generally causes the least impact on 

resources. More confinement can generally be equated to more impact because it concentrates 

impact and contributes to restless behavior (Leave No Trace, 2001). Loose grazing does not 

work everywhere, however, so containment methods are also important and appropriate.

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

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

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

constructed with wooden posts and rails. Highlines are used at most camps. Some outfitters 

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

after feeding. 

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

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

is not available near the campsite.

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

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

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

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

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

the stock to help the outfitter locate them if they don’t return to camp on their own. Some 

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

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

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

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

morning if needed. 

Horses and mules are herd animals, so as they graze, they stay in the same general area but 

are widely dispersed within that area and the forage use is well distributed. As with all 

grazing animals, they are constantly moving across the land, eating grasses as they go. Feral 

free-ranging horses typically spend over half their time feeding, and around 25-35% of their time 

resting, day and night (Ransom and Cade 2009). Studies with pack stock grazing show horses 

and mules behave similar to feral free-ranging horses. After daily exercise, they feed for an 

initial 3-4 hour bout and then continue to graze every hour with a constant rate of movement 

(Olson-Rutz et al. 1996). When not grazing, pack stock rested more than traveling, similar to 

wild horses (Olson-Rutz et al. 1996, Ransom and Cade 2009). 

The constant movement is a characteristic defensive pattern of grazers against predators. The 

stock form a loose herd, always nearby each other, but not tightly congregated. When water is 

readily available as it is in most places in the wilderness, horses do not gather at specific sites to 

drink as in desert environments (Salter and Hudson 1979). Outfitter-guide stock exhibit similar 

grazing behavior to that of free-ranging horses. Typically free-ranging horses move rapidly to 

and from water sources with very little feeding or loafing activities near drinking areas 

(Ganskopp and Vavra 1986). They prefer open areas and elevated terrain away from water and 
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thick brush to get away from insects (Keiper and Berger 1982) and to be able to assess potential 

threats from predators (Ganskopp and Vavra 1986). They avoid muddy areas because they 

instinctually do not want to be mired in mud, and simply because they prefer to keep their feet 

dry. During the night, they sleep by dozing off, and upon waking, graze while moving to a 

different spot. 

Feral free-ranging horses typically select for grasses (58-84% of the diet), and secondarily prefer 

sedges (2-34% of the diet) (Salter and Hudson 1980, Hansen et al. 1977). Research of pack stock 

yielded similar results, with horses selecting grasses over forbs or browse (Olson-Rutz eat al. 

1996). In a subalpine meadow in the Payette National Forest of Central Idaho, grasses 

composed 78% of pack stock diets, while sedges (Carex spp.) and rushes (Juncus spp.) composed 

20% of the diet. Forbs were a minor component (Krumpe and Schantz 1997). Most outfitter 

camps in the Pasayten and Sawtooth Wilderness are located near open meadows and 

bunchgrass hillsides where horses are placed to graze. Key forage species include green fescue 

(Festuca viridula), timber oatgrass (Danthonia intermedia) and sedges (Carex spp.).

Pasayten and Lake Chelan-Sawtooth Wilderness Areas

There are no permitted cattle in the wilderness areas. A portion of the vacant Buttermilk Sheep 

allotment is in the Lake Chelan-Sawtooth Wilderness (see the Buttermilk allotment description 

under Permitted Livestock Grazing within the Project Area). There are approximately 637 

established campsites scattered across the Pasayten Wilderness and 338 in the Lake ChelanSawtooth Wilderness. Approximately 12% of the Pasayten campsites are used by pack and 

saddle stock outfitter-guides, and 23% of those in the Lake Chelan-Sawtooth (refer to section 3.2 

Wilderness).

All of the affected area is directly associated with these camps used by people with pack and 

saddle stock. The outfitter-guide stock is dispersed around the camps to the point that the 

grazing is having little effect on natural plant succession on grass dominated meadow systems 

with an overall trend toward improvement in the current ecological condition (see Natural Plant 

Succession section in botany report). The level of forage use by outfitter-guide stock is highest 

at the camps and decreases the farther one moves away to the point of no use. Outfitters 

typically move stock at least 1⁄4 mile from camps to loose graze. Forage use in stock grazing areas 

is below the forest utilization standards due to light intensity and short duration grazing.

Upland Forage associated with established outfitter campsites is meeting Forest Plan utilization 

standards on all wilderness range with the exception of a few spots where localized high use is 

exceeding 60%. These spots are relatively very small and are not a representative sample of a 

large stratum or scale, such as the general foraging area associated with the outfitter camp. 

Forest Plan allowable use monitoring is based on the Key Area concept and the Key Area reflects 

what is happening on a larger area as a result of on-the-ground management actions. These 

relatively small hot spots are near campsites where the combined effect of trail and camp 

location, forage and water access, and topography results in virtually unavoidable 

concentrations of forage utilization. 

The Forest Service monitors outfitter-guide stock utilization and impacts to wetlands around 

campsites and in loose grazing areas away from camps. Two methods are used to monitor 

outfitter-guide stock grazing. First, ocular estimates are made by wilderness rangers when 

walking through camp areas and loose grazing areas away from camps. If grazing utilization 
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appears to be approaching standards, or if wetlands appear impacted, wilderness rangers report 

the conditions and formal monitoring is scheduled for the area. Formal monitoring is conducted 

by a modified stubble height utilization method to measure the level of use on key forage 

species. 

Utilization is estimated by a modified residue and height-weight method (Coulloudon et al. 

1999), in which stubble height is measured and a simplified clip and balance technique to 

develop height-weight curves is used. From height-weight curves, utilization can be estimated 

from the average stubble height measured at each location. Formal monitoring has also been 

conducted on sites not approaching standards for use as baseline data and to train wilderness 

rangers. Areas formally monitored for this purpose include Beaver Creek outfitter camp, and 

Bald Mountain outfitter camp. Forest utilization standards for range allotments allow for 45% 

use in upland forested areas, 55% use in upland grasslands, and 45% use in riparian meadows. 

Forage Utilization Monitoring Results

Utilization data has also been collected at public camp sites and administrative sites as well to 

provide baseline data for resource conditions.

Current wilderness forage use by outfitter guide stock is well below recent historic use levels 

permitted within commercial wilderness livestock grazing allotments (see Past Actions), and is 

well below Forest utilization standards. Results showed utilization of key forage species near 

outfitter camps was between 0% and 17.5% (Figure 3.10-1). Ocular estimates provided by the 

Forest Service Range Specialist in 2001 and Range Technician in 2010-2012 are provided in 

Figure 3-10.2. 

Figure 3.10-1. Forage utilization monitoring results in the Pasayten Wilderness.

DMA Name

Outfitter or 

Public Key Species Utilization (%)

2001 2010 2011 2012

Bald Mtn (Ryan Surface) Outfitter Sedge 5 0

Remmel Lake Horse Camp Public Sedge 39 7.3

Beaver Creek Camp 

(Darwood) Outfitter Green Fescue 17.5 16 <15 *

Border Ridge Public Green Fescue <5* < 5*

Spanish Camp FS Cabin Green Fescue <15* <10*

Border Patrol Camp Border Patrol Timber Oatgrass <15* <10*

Sheep Mtn. (Ryan Surface) Outfitter Green Fescue <30* <10*

*Ocular estimate of use

Streambank Disturbance Monitoring Results

Wilderness riparian areas are currently meeting Forest Plan allowable use standards including 

standards for streambank alteration (Cowley et al. 2006). Human or recreational stock 

disturbances to streambanks and riparian areas are localized near trail crossing areas and 

campsites in the Pasayten and Sawtooth Wilderness Areas. Areas above and below these 

disturbance areas are in pristine condition, with no sign of human or stock use, intact 

streambanks, and established vegetation. These disturbed areas are watering locations near 

campsites and/or at trail crossings where unavoidable trampling occurs. Trampling exposes 
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bare soil and causes alteration to the streambank. Some browsing on riparian shrubs and 

grazing of riparian herbaceous species is also occurring but is well within Forest Plan standards. 

Streambank disturbance data was collected near several camps in the Pasayten in 2010 , 2011, 

and 2012. Streambank disturbance around campsites is measured in linear feet of streambank 

that is showing disturbance due to camping or stock activities. Characteristics of disturbed 

banks include compacted soil, bare ground, vegetation loss, trampling, hoof action and a general 

appearance of human use. Streambank disturbance was used instead of streambank alteration 

because it requires little training for data collection, does not require any extra equipment for 

backpacker rangers to carry, and gives an idea of how much riparian area near campsites is 

being impacted by human activities.

In 2012 Forest Service personnel visited over 50 camps during the High Hunt patrol in 

September including Crow Lake, Bunker Hill, Sheep Mountain, Remmel Lake, Beaver Creek, 

Upper and Lower Cathedral Lakes, Glory Lake, Freds Mountain Lake, Spanish Camp, and the 

areas in-between. The highest streambank disturbance observed in any camp in this area was at 

the public horse camp at Remmel Lake, with approximately 12 feet of streambank disturbance. 

The streambank disturbance estimates are displayed in the following table. 

Figure 3.10-2. Streambank disturbance monitoring results in the Pasayten Wilderness.

DMA Name

Outfitter or 

Public

Stream Streambank Disturbance 

Estimate (feet)

2001 2011 2012

Bald Mtn (Ryan Surface) Outfitter 6 ft 6 ft

Remmel Lake Horse Camp Public 10 ft 12 ft

Beaver Creek Camp (Darwood) Outfitter Spring <5 ft 2-3 ft 2ft

Spanish Camp FS Cabin Spanish 

Creek 6 ft 6ft

Border Patrol Camp Border Patrol 3 ft 3ft

Sheep Mtn. (Ryan Surface) Outfitter 8ft

Detailed field notes regarding general resource conditions pertaining to grazing in the 

wilderness were collected by the Forest Service Range Specialist or Range Technician in the 

Sheep Mountain and greater Spanish camp area in 2001, and again in 2010-2012. Specific 

monitoring results and ocular estimates from these inspections are displayed in Figure 3.10-1

and Figure 3.10-2. Field notes are summarized below:

Sheep Mountain outfitter camp- In 2001, light grazing use (<20-30%) was observed in the 

area around the Sheep Mountain outfitter camp. Little to no grazing use was observed in 

the benches above the outfitter camp on Sheep Mountain. In 2012, less than 10% 

utilization was observed in the greater Sheep Mountain area. Use was estimated on two 

transects, one above the outfitter camp but below the Boundary trail #533, and the other 

approximately 1⁄4- 1⁄2 mile southwest of the camp above Barker Brown Cabin. From 2001 to 

2012, grazing use appears to have declined in this area, with the majority of the area 

receiving very light to no grazing. 

Bald Mountain outfitter camp- In 2011 and 2012, field observations indicated light grazing 

use. There are two main meadow areas on Bald Mountain. One meadow is located on a 
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bench approximately 1/8 of a mile above the camp. This is a small wet meadow, and no 

grazing was observed in this meadow in 2011 or 2012. The main area the outfitter loose 

grazes horses is about 1⁄2 mile above the camp on the shoulder of Bald Mountain. Very light 

grazing to no grazing was observed in this area. This is a large open, relatively flat bench 

with plenty of space for pack stock to disperse and graze, resulting in very light grazing and 

virtually no resource impacts.

Beaver Creek outfitter camp- In 2001, light grazing was observed in the ridge above the 

outfitter camp. An old utilization cage was inspected, and no differences were observed 

between plants inside the cage (excluded from grazing) and outside the cage. Grazing was 

minimal, with a slight trail to the watering hole in the camp. The watering area was 

characterized by low growing willow and sedges, with a small site of hoof shear less than 

five feet across. Observations from 2010-2012 show virtually no change in grazing resource 

conditions from 2001 in the greater area around the camp. Utilization on the ridges and 

open areas approximately 1⁄4 mile away from the camp was light, with 15-17.5% utilization. 

The area of disturbed bank near the watering site was estimated to be 2-3 feet wide. 

Conditions from 2001-2012 appear to have stayed the same or improved with very light 

grazing use observed.

ENVIRONMENTAL CONSEQUENCES

Direct and Indirect Effects

Alternative 1

This alternative would have no pack and saddle stock outfitter-guide recreation livestock grazing 

use in the analysis area. No grazing or browsing of forage by outfitter-guide pack and saddle 

stock would occur in the analysis area with only forage utilization by wildlife, commercial 

grazing, and non-outfitted pack and saddle stock. Less grazing would occur resulting in fewer 

disturbances to vegetation and soil. Vegetation and soil disturbance would be more limited to 

natural mechanisms (wind, water, wildlife, wildfire), public and administrative activities, and 

ongoing projects. 

Most of the existing campsites would continue to be used by private pack and saddle stock 

users. Impacts to riparian shrub and herbaceous vegetation would still occur at nearby watering 

sites and crossing areas but to a lesser degree with an expected increase in density and cover 

and an increase in stream bank stabilization. Due to the dynamic nature of stream systems and 

natural hydrologic processes, however, this trend may not remain stable through time. 

Alternatives 2, 3, and 4

None of the action alternatives would result in exceeding Forest Plan utilization standards, 

changing natural plant species composition, or causing impacts to vegetation that will take more 

than one year to recover. Refer to the Botany section for more information.

Mitigation measures would reduce potential impacts of outfitted pack and saddle stock grazing 

on wetlands, sensitive plants, water quality, vegetation, and aquatic habitat by limiting grazing 
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where forage conditions warrant it, and to disperse grazing and reduce impacts to forage from 

concentrated use.

8a. Using loose grazing as the preferred method for outfitter stock would be effective in 

avoiding over-utilization of forage. Loose grazing stock disperse and their constant 

movement pattern results in no concentrated grazing areas. 

8c & g. Outfitters would be required to carry supplemental feed if forage utilization or 

resource monitoring shows that utilization standards are close to being exceeded. This 

would be effective in eliminating the possibility of outfitted stock over-grazing areas. 

8d. Prohibitting picketing of stock in subalpine meadows would be effective in avoiding 

over-utilization of forage since stock would be able to roam free in the constant movement 

pattern that avoids over-grazing.

8e. Limiting outfitter-guide stock grazing to suitable areas during time of high use would be 

effective in ensuring that the stock do not over-graze areas where there is a high number of 

non-outfitted stock, or in areas where forage conditions cannot support stock grazing.

Under Alternatives 2, 3, or 4, only areas where outfitter stock remain at campsites overnight 

would have grazing impacts to the range resource. There are no permitted cattle in the 

wilderness or backcountry areas of the analysis area, consequently loose grazing of outfitterguide stock associated outfitter guide camps would not affect the commercial livestock grazing. 

The amount of grazing would conform to all Wilderness resource values, as described in each 

resource section of Chapter 3. Refer to Wilderness, Soil, Hydrology, Aquatics, Wildlife, and 

Invasive Species sections.

Within the non-wilderness backcountry areas nearly every camp used is a drop camp where 

there would be no pack and saddle stock grazing impacts because stock would not remain onsite 

to graze. The 4,620 service days associated with pack and saddle stock outfitter-guides in 

Alternative 2 would increase the number of pack and saddle stock visitor days by 0.3% 

compared to the recently permitted levels. Alternative 3 would reduce the outfitter-guide 

visitor days to 2,660, leading to a 4% reduction in recently permitted level of stock use. 

Alternative 4 would include 6,700 service days, and would increase stock use by 5% compared to 

current permitted levels. Alternative 2 would allow 270 AUMs for the outfitter-guide use. 

Alternative 3 would include 150 AUMs, and Alternative 4 would allow 390 AUMs.

The amount of forage use and resource impacts would be less than or similar to the current 

condition, and Forest Service grazing utilization standards would continue to be met. In 

Alternatives 2 and 4, the outfitter-guides would be using all existing trails and camps, and no 

new camps or trails would be developed. In Alternative 3, outfitters would also be restricted to 

existing trails and camps but additionally would not be allowed to use campsites within 200 feet 

of wetlands, streams, lakes, or key interest areas. A negligible amount of the available forage 

within the livestock grazing allotments would be grazed by the outfitter-guide stock. 
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Cumulative Effects

This cumulative effects analysis considers effects of past, present, and reasonably foreseeable 

future actions within the project area. The geographic boundary for this cumulative effects 

analysis is the entire project area and the entire area of the historic grazing activities associated 

with the project, and the temporal boundary is the period of time when the activities associated 

with this project are occurring from the 1900s to 20 years post-project. All of the historic 

information provided in the following Past Actions section was taken from Forest Service 

records in the livestock grazing allotment and livestock permit files at the Methow Valley, 

Tonasket, and Chelan Ranger Districts. 

Present Actions

Commercial Grazing Allotments

There are 6 active commercial grazing allotments with the project area as described in detail in 

the Affected Environment section. Non-outfitted recreation use, other outfitters, general public 

pack and saddle stock use, trail maintenance, and permit administration use are additional 

activities that would have a cumulative effect on the proposed actions but would have less of an 

impact on commercial livestock grazing than pack and saddle stock activities. The impacts of 

these activities would have a negligible reduction in the forage availability or cumulative 

physical impacts to streambanks. 

Recreational Livestock Grazing

Observations were also made near several private camps. No major resource conditions were 

identified, with light to no grazing observed in most places. There is evidence of natural 

recovery from historic livestock grazing, with improved conditions. The Remmel Lake public 

horse camp had the highest grazing use, with 39% grazing use observed in 2011. However, 2012 

results indicated a decline in use, with only 7.3% utilization. This is likely a result of varied 

amount of public stock use from year to year. This area also had the largest amount of 

disturbed banks, with approximately 12 feet of bank shear near the trail crossing. Above and 

below the trail crossing banks were in pristine condition.

Reasonably Foreseeable Future Actions

Commercial Livestock Grazing

All vacant allotments within the Pasayten Wilderness Area, Lake Chelan-Sawtooth Wilderness 

Area, and the Sawtooth Backcountry project areas are scheduled to be analyzed to be closed or 

to be made active again. Permitted livestock grazing will continue outside of wilderness. The 

Wolf, Boulder, Buttermilk and Alta Coulee allotments are scheduled for Allotment Management 

Plan (AMP) revisions within the next 4 years. The no grazing alternative may be the preferred 

alternatives for Buttermilk and the Boulder allotments. The Wolf AMP revision will be 

completed in 2013. Commercial livestock numbers within the project area will remain relatively 

low and continue to constitute a small amount of the forage overlap with pack and saddle stock 

with virtually no combined effect of the dual use. Range management techniques such as 

numbers of commercial livestock turned out, salting, water developments and timing of use, 

would continue to be used to meet riparian goals, and to obtain uniform distribution of use on 
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the allotments. Riparian objectives include maintaining and/or increasing bank stability along 

riparian areas. These objectives would be reached through the continued use of deferred and 

rest rotation grazing and maintenance of water troughs and fences.

Recreational Livestock Grazing

It is reasonably that non-outfitted pack and saddle stock use will increase in the future 

approximately 3% over current levels. This increase will not lead to exceeding utilization 

standards, even when considered cumulatively with pack and saddle stock outfitter-guide 

recreational livestock grazing.

Cumulative Effects

Alternative 1

This would result in a 2% reduction in the number of pack and saddle stock users in the analysis 

area. No AUMs would be used by outfitter-guides.

There would be no pack and saddle stock recreation livestock grazing. Camp sites would 

continue to be used by the general public but likely with fewer stock than in the past. A 

relatively small portion of the available forage in the livestock grazing allotments would 

continue to be grazed by the general public pack and saddle stock; the amount of forage in 

allotments utilized by general public stock would be negligible and have a minor effect on forage 

availability for permitted livestock grazing.

Alternative 2, 3, and 4

The cumulative effect of any of the alternatives and the past, present, and reasonable 

foreseeable future actions would be an improving trend in range conditions across the analysis 

area. There would be no overlap between recreational and commercial livestock grazing, and 

forest plan utilization standards would be met. Vegetation recovery from past overgrazing 

would continue. Proper commercial grazing allotment management coupled with the low 

numbers of recreational livestock and the mitigation measure to reduce impacts from pack and 

saddle stock outfitter-guide recreational livestock would continue the upward trend. 

CONSISTENCY FINDINGS

All alternatives would be consistent with the amended Forest Plans .

11-4 and 11-5: Forage utilization standards outside and inside riparian areas. Refer to tables on 

pages 4-43 and 4-44 in the Okanogan National Forest Plan.

The pack and saddle stock outfitter-guide recreational pack stock grazing would not exceed 

forest utilization standards, neither directly, indirectly, nor cumulatively. 

11-7: Range improvements and practices shall not be designed to increase livestock use in 

riparian ecosystems, but should enhance riparian ecosystems.

The number of livestock would be controlled by the special use permit. The range 

improvements (2 trail bars) would be used to stop loose pack and saddle stock from 

incidentally traveling back to trail heads. The trail bars are not designed to increase use in 
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riparian area, however the presence of the fence may result in incidental short duration use in 

a riparian area by the loose stock.

15B-11B The forage resource shall be utilized in conformance with all wilderness 

resource values. 

Forage use by pack and saddle stock outfitter-guide recreational livestock in 

wilderness would conform to all wilderness resource values, as discussed in 

Wilderness, Soil, Hydrology, Aquatics, Wildlife, and Invasive Species sections.

MA7-11A Domestic livestock grazing shall not be permitted. Recreation livestock grazing shall 

be permitted except for the meadows at Rainy Lake turnoff and Whistler Basin. Users should be 

encouraged to use weed-free hay.

Mitigation measure 8h would prohibit pack and saddle stock outfitter-guides from grazing 

livestock in the meadows at Rainy Lake turnoff or Whistler Basin. Mitigation measure 14b 

would require that only certified weed-free hay be used on National Forest System Land.

MA10-11A Livestock use should not be increased over existing permitted numbers. 

There would be no pack and saddle stock outfitter-guide camps in MA10, therefore no pack 

and saddle stock outfitter-guide recreational livestock permitted. 

Management Area RE2a (page IV-66, Wenatchee Forest Plan)

Grazing of suitable range by livestock shall emphasize range management practices that 

favor unroaded, motorized, dispersed recreation.

The pack and saddle stock outfitter-guide recreational livestock grazing would be 

dispersed, non-motorized recreation in mostly unroaded settings.

Management of the range resource under this prescription will seek full utilization of 

forage allocated to livestock.

This standard and guideline pertains to commercial livestock grazing to assure that good 

distribution of grazing occurs throughout the areas permitted to graze. Outfitter-guide 

permits do no allocate forage the same as commercial livestock permits do. Relative to 

the large wilderness and backcountry forage resource, only a very small portion near 

camps would be grazed by pack and saddle stock and outfitter-guide recreational 

livestock grazing would meet all utilization standards.

Control noxious weeds as practical.

Refer to analysis in the Invasive Plant section of this chapter. Mitigation measures 14 

a-e would control noxious weed introduction and spread by pack and saddle stock 

outfitter-guides to the extent practical.
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3.11 ECONOMIC AND SOCIAL ANALYSIS

The section below is a summary of the Economic Analysis (Grinspoon, 2011) and the Social 

Impact Analysis (Zbyszewski, 2011), both available in the analysis file.

REGULATORY FRAMEWORK

The direction completing economic and social analyses of a proposed action and alternatives is 

found in the NEPA regulations, and in Forest Service Manual 1900. 

Section 1508.14 of the NEPA regulations gives direction in analyzing the effects of proposed 

actions and alternatives on the human environment. 

"Human environment" shall be interpreted comprehensively to include the natural 

and physical environment and the relationship of people with that environment. 

(See the definition of "effects" (Sec. 1508.8).) This means that economic or social 

effects are not intended by themselves to require preparation of an environmental 

impact statement. When an environmental impact statement is prepared and 

economic or social and natural or physical environmental effects are interrelated, 

then the environmental impact statement will discuss all of these effects on the 

human environment. (NEPA Regulations, Section 1508.14)

Forest Service Manual 1900, Chapter 1972 describes an economic impact analysis, and gives 

direction for completing the analysis. 

Economic impact analyses describe short-term effects that Forest Service activities 

may have on economic conditions in defined impact areas. Impact analyses help 

identify those who may be favorably or adversely affected by Forest Service decisions. 

Economic impact analysis is the basis for evaluating economic contributions by the 

Forest Service in the impact area. These analyses are used for comprehensive 

evaluations in forest planning and in other assessments. (FSM 1900, Chapter 1972)

The Manual also discusses when and how a social analysis should be completed. 

Social analysis is instrumental in National Forest planning and plan implementation. 

Social analysis is part of the overall evaluation requirement for decision making. Social 

impact assessments help identify desired conditions for social, economic, and 

ecological environments, and the effects of National Forest management activities on 

social systems within and/or adjacent to the National Forest or project area. (FSM 

1900, Chapter 1973)

This analysis follows the technical guidance and advice for economic and social evaluations 

found in Forest Service Handbook 1909.17 (USDA 2008). 

ANALYSIS METHOD

Except for the recreation areas that charge an entry fee, National Forest recreation is a nonmarket good. Economic ties between recreation on National Forest lands and local communities 
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can be estimated, however, by tracking how visitors spend their money in local businesses and 

by estimating how much those businesses spend on materials and wages in order to provide 

goods and services to the recreationists. The Forest Service conducts a visitor survey every five 

years called the National Visitor Use Monitoring Survey, or NVUM.6Every fourth interview asks 

visitors how much they spent in local communities and on what goods and services. The 

spending information is reported by visitor characteristics such as whether they were local 

residents or non-locals and whether they were just day users or if they spent the night. These 

categories have the highest effect on how recreationists spend their money and who in the local 

economy enjoys the economic benefit.7

For the purposes of this analysis, however, NVUM did not supply the information needed to 

estimate the economic contribution of the outfitter guide industry to local communities. 

Outfitter-guides are not one of the activities identified in the NVUM survey. There is no 

information in NVUM about number of visitors hiring outfitter-guides, nor is there expenditure 

information for that specific activity. To determine the economic ties between the activities of 

outfitter-guides and local communities, efforts were made to identify analogs to the NVUM 

data. Four possible analogs to outfitter guide activities were identified:

1) use the generic expenditure profile for high spending recreationists;

2) use the expenditure profile for horseback riding;

3) use the expenditure profile for downhill skiing since those are the highest spending 

recreationists; 

4) use data gathered by the Methow Valley staff to show how income earned by outfitter-guides 

contributes to the local economy.

The first option was rejected; it lacks specificity for the expenditures of outfitter-guides, which is 

a unique activity and business. If used, this option would not identify the types of businesses in 

the area that are impacted. The second option was not chosen because an examination of the 

data showed that the expenditures were extremely low compared to data independently 

gathered by the staff of the Methow Valley Ranger District, Okanogan Wenatchee National 

Forest. This option would fail to demonstrate the economic importance of the outfitter guide 

activities to local communities. The third option was also rejected. Even though the level of 

total expenditures was similar for downhill skiers and outfitter guide visitors, the goods and 

services purchased by skiers and ski area operators are different from those purchased by 

outfitter guide visitors and businesses.

Since the NVUM data didn’t have enough specificity to help with this particular analysis, a fourth 

method was considered and chosen for the economic analysis. In this method, data gathered by 

the staff of the Methow Valley Ranger District was used to show how income earned by 

outfitter-guides operating on Forest Service lands contributes the local economy. The data lack 

the richness of NVUM data, especially in terms of ‘local’ versus ‘nonlocal’ visitors, but there is 

enough information to show the principal economic effects of demand for outfitter services. It is 

probable, however, that this method slightly underestimates total effects on employment and 

income. The method lacks specificity about the characteristics of visitor spending while they are 

 

6 www.fs.fed.us/recreation/programs/nvum

7

Stynes, Dan and Eric White. Spending Profiles of National Forest Visitors, Round 2 Update. March, 2010
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in the area and only includes the fees paid to outfitter-guides, but this method is considered to 

be the best one available.

Economics

The economic contribution of the outfitter industry in the Methow Valley was measured by the 

jobs, labor income, and total sales supported in the local economy.8 Job, income and sales 

effects were modeled with “IMPLAN,” a software and database package produced by the 

Minnesota IMPLAN Group9. The Forest Service has an agency-wide site license for the IMPLAN 

package allowing the Forest Service to build models for almost any economy of interest. IMPLAN 

estimates the change in direct, indirect and induced effects10 (hereafter, “ripple” effects) 

resulting from a change in the final demand for goods and services provided by a given sector or 

sectors of an economy. These effects, as measured by “multipliers,” take into account the 

effects of money leakage from, and imports to, the study area. Leakage occurs when money is 

spent outside the analysis area in order to fulfill production needs. For example, if a local 

restaurant requires seafood for production of a dinner, the money spent to import the fish has 

left the study area and is no longer available for circulation within the local economy. Exports of 

goods and services, on the other hand, bring new money into the economy. Tourism is classified 

as an “export” because non-residents bring new money into a local economy, taking away a 

recreation experience in exchange. 

It is important to note that here is a time lag with the IMPLAN county economic data used for 

modeling. In this case, the most recent dataset available is for 2009, a two year time lag from 

the current situation. However, inspection of the IMPLAN data for Okanogan County shows that 

they are a reasonable representation of the existing economy.

For this analysis, the study area is Okanogan County. Although some of the outfitter guide trips 

travel though Chelan County, all of the trail heads, with the exception of the Fish Creek base 

camp, are in Okanogan County. All of the outfitter-guides, except one, also live in Okanogan 

County. Once the guides and clients enter the wilderness, they spend no money. Most of the 

spending associated with the outfitter guide trips takes place in Okanogan County. 

Social Analysis

The social analysis was conducted using demographic information about outfitter-guide clients, 

and how the alternatives would affect the opportunity for people to participate in pack and 

saddle stock activities.

 

8

Jobs are expressed as average annual jobs including full, part-time, seasonal and temporary jobs. Labor 

income is the sum of employee compensation (wages plus the value of benefits) and proprietor’s income 

(self employed).

9 www.implan.com

10 Direct impacts are the employment, labor income and sales resulting from the production of goods and 

services to meet demand. Indirect effects are produced when a sector must purchase supplies and 

services from other industries in order to produce output sufficient to meet demand. The employment 

and labor income generated in other industries as a result are referred to as indirect effects. Induced 

effects are the employment and labor income stimulated as a result of the expenditure of household 

disposable income generated by direct and indirect employment.
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Best Available Science

Throughout this analysis, the best available science was incorporated to describe the economic 

and social impacts of the existing pack and saddle stock outfitter-guide businesses, and the 

potential effects of the alternatives considered.

DATA SOURCES

Service Days

The current number of permitted outfitter guide service days is 4,460, which is the number of 

service days in the existing pack and saddle stock outfitter-guide permits plus the number of 

days in the priority use pool. Use data has been compiled using the most accurate data 

available. The number of service days actually used varies from year to year. Reliable records 

are available for the past 10 to 20 years. Some data gaps and margins of error exist due to data 

interpretations. The data is the best information available, and has a level of accuracy that is 

more than adequate for this analysis. More detailed use data, or data that goes back farther in 

time, is not essential and is not critical to the analysis. Current conditions and future uses are 

the most relevant factors to consider. 

Total Recreation Use Levels

The National Visitor Use Monitoring Results for the Okanogan National Forest (USDA, 2001d and 

2006a) generated information on the number and type of visitor days in the areas. Current 

outfitter-guide service days are included in the totals. The results have an 80% confidence level, 

which defines the degree of certainty that a range of values contains the true value will be 

within the range 80% of the time (USDA, 2006d). This is the best available information 

concerning use levels. 

Economic Contribution of Pack and Saddle Stock Outfitter-guides

The money charged for full service trips range from $190 - $200 per person per day. The 

analysis uses the average of $195. This information was gathered from the existing pack and 

saddle stock outfitter-guide.

Demographic Information

The information on demographics and age class distribution is from the Washington State Office 

of Fiscal Management, 2010. The number of visitor days expected in the future was calculated 

using projected changes included in the Washington State Comprehensive Outdoor Recreation 

Planning (SCORP) publication “Estimates of Future Participation in Outdoor Recreation in 

Washington State” (Interagency Committee for Outdoor Recreation 2003). These projected 

changes were for 10 and 20-year periods based on participation data from the 1999-2000 RCO 

survey (IAC 2003). These projections took into account NSRE data and projections for the Pacific 

Northwest Region, demographic trends in Washington State, the local supply of lands available 

for recreation activities, and other factors.

AFFECTED ENVIRONMENT

The total area of Okanogan County is approximately 3.4 million acres, of which about 1.5 million 

is federally owned. Over 95 percent of the federally owned land is within the jurisdiction of the 
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Okanogan-Wenatchee National Forest. The 2000 census recorded a population of 39,564 

people (Okanogan Country Comprehensive Plan Update, 2005, p. 23-24).

Economics

Agriculture and forestry have historically been and continue to be major economic generators 

for the County. According to IMPLAN data, approximately 5,280 people work in natural 

resource-based industries -- agriculture, forestry, fishing, hunting, and mining (IMPLAN, 2009). 

Government, retail trade, accommodation and food services, and manufacturing are a few of 

the major employers in the County. Figure 3.11-1 shows the size of various sectors in the local 

economy.

Figure 3.11-1: Basic economic data for Okanogan County (2009 Data)

Okanogan County Economy (2009 IMPLAN Data)

Industry Group

Employment 

(# Avg Annual 

Jobs)

Labor Income 

($2009)

Total Sales 

($2009)

Government & Misc. 5,705 $274,654,827 $420,328,029

Ag, Forestry, Fish & Hunting 5,280 $157,224,342 $222,567,555

Retail trade 3,208 $99,805,234 $193,288,389

Other services 1,377 $37,590,533 $73,424,721

Health & social services 1,347 $53,291,839 $97,983,172

Accommodation & food services 1,217 $24,611,691 $74,657,941

Construction 961 $35,607,160 $102,096,126

Finance & insurance 523 $22,166,279 $85,646,061

Professional- scientific & tech svcs 490 $17,511,830 $34,426,439

Real estate & rental 487 $3,894,190 $170,443,458

Wholesale Trade 409 $22,633,065 $61,541,367

Manufacturing 318 $10,288,961 $116,486,101

Administrative & waste services 302 $9,228,150 $24,982,611

Other amusement and recreation svcs 297 $6,215,524 $13,330,139

Transportation & Warehousing 194 $9,171,936 $27,368,507

Mining 151 $9,676,165 $66,896,994

Educational svcs 136 $1,477,726 $3,472,911

Information 119 $5,413,219 $21,455,504

Utilities 38 $2,647,656 $12,016,711

Management of companies 22 $805,809 $2,375,170

TOTAL 22,581 $803,916,135 $1,824,787,904

Copyright 2011 Minnesota IMPLAN Group, Inc.

Figure3.13- 1 shows that about 297 people are employed in the sector called “Other 

Amusement and Recreation Services” in Okanogan County. Outfitter-guides are included in this 

sector as well as an array of other recreation services companies including rafting companies, 

motorized coach tours, and other Forest Service permitees such as hiking/backpacking guides. 

The objective of this analysis is to estimate what portion of the economic activity supported by 
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the Amusement and Recreation sector is attributable to the pack and saddle stock outfitterguides using stock in the study area.

There are currently 4,460 service days for the pack and saddle stock outfitter-guides. Estimates 

of jobs and income generated economy-wide associated with this amount of service days gives a 

baseline against which to compare the other alternatives. Figure 3.11-2 shows the estimates for 

county-wide employment, income, and sales attributable to current pack and saddle stock 

outfitter-guides in Okanogan County. The figure shows that around 21 people are employed by 

pack and saddle stock outfitter-guides while outfitter guide activity supported an additional 4 

jobs throughout Okanogan County. The total is approximately 25 jobs economy-wide.11 Those 

jobs contribute almost $850,000 in labor income – which includes wages, benefits and 

proprietor’s income – to the Okanogan County economy. Current pack and saddle stock 

outfitter guide activity also supports more than $1.3 million dollars in sales economy-wide. 

Figure 3.11-2. Current Contribution of Pack and Saddle Stock Outfitter-Guides and Total Okanogan 

County Economy

Impact Type Employment

(# Jobs)

Labor Income

($2011)

Total Sales

($2011)

Direct Effect12 22.2 $757,844 $870,042

Indirect Effect13 1.1 $33,962 $114,016

Induced Effect14 3.3 $98,697 $309,881

Total Effect 26.6 $890,504 $1,293,940

Okanogan County 

Economy

22,581 $803,916,135 $1,824,787,904

Social Demographics

The demographics of the population of people hiring pack and saddle stock outfitter-guides 

helps identify potential social impacts to this segment of the recreating public. One statistic to 

consider is the age of the visitors. Assuming that as people age, they are less able to backpack 

long distances, an aging visitor population may have an increasing need for stock outfitterguides. Hiring outfitter-guides for stock help make backcountry trips more feasible for older age 

groups. 

The age class distribution of existing pack and saddle stock outfitter-guide clients shows that the 

majority of them are over the age of 50, based on actual client age information provided by the 

pack and saddle stock outfitter-guides.

The following figure shows the age ranges and percent of visits.

 

11 It is important to keep in mind that this is average annual employment so that it is not possible to 

distinguish whether these are 25 permanent, full time, year round jobs, or 50 temporary jobs for 6 

months, or some combination of the two.

12 Direct effects are those directed created by the businesses.

13 Indirect effects are those created in support of the businesses.

14 Induced effects are the impact of spending by the people employed by the businesses.
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Figure 3.11-3. Percent of Total Wilderness Visits and Outfitter-guide Clients by Age Class

Age Class Percent of Total Wilderness 

Visits (NVUM)

Percent of Stock 

OG Clients

Under 16 <1% 3%

16-19 6% 8%

20-29 33% 1%

30-39 <1% 2%

40-49 13% 12%

50-59 25% 24%

60-69 11% 41%

70+ 12% 8%

The Washington State Office of Fiscal Management tracks the population of the state, and how 

the composition of age classes is shifting over time. The following figure displays the current 

population distribution across the age classes, compared to the projected distribution in 2020. 

As is shown, the age class distribution is shifting into the older age classes. The number of 

people in the 60-69 age range will increase approximately 40%15, and those 70 years and older 

will increase 46%16 (Washington State Office Fiscal Management, 2010) by the year 2020. The 

Washington State Interagency Committee for Outdoor Recreation discusses projected changes 

in populations in the 2003 “Estimates of Future Participation in Outdoor Recreation in 

Washington State” (IAC, 2003). One of the key considerations in projecting changes in the 

number of people participating in various outdoor recreation activities is age. Physical demands 

of various activities, such as backpacking, will discourage people from participating as they age 

(IAC, 2003). 

Figure 3.11-4. Percent Change in Number of People in Age Classes in 2010 and 2020 

Age Class Number of People in 

2010

Projected Number in 2020 Percent Change

Under 15 1,311,555 1,517,032 16%

15-19 464,155 478,724 3%

20-29 966,978 1,014,958 5%

30-39 883,849 1,098,567 24%

40-49 959,344 935,360 -3%

50-59 947,648 967,301 2%

60-69 643,504 903,726 40%

70+ 556,217 809,712 46%

Total 6,733,250 7,725,380 15%

(Washington State Office Fiscal Management, 2010)

As shown in Figure 3.11-3, approximately 73% of stock outfitter-guide clients are 50 years old or 

older. This age class is more dependent on stock to travel into the wilderness or backcountry 

and more likely to use an outfitter-guide service due to a combination of physical limitations, 

more leisure time, and higher income levels. The relatively large predicted increase in the 

number of people over the age of 50 in Washington state (refer to Figure 3.13-4) indicates that 

there will likely be a corresponding increase in the number of people and the percentage of 

visitors who will require the service of stock outfitters guides for trips into the analysis area. The 

 

15 (903,726 people - 643,504 people)/643,504 people = 0.40, or 40%

16 (809,712 people - 556,217 people)/ 556,217 people = 0.456, or 46%
Pack and Saddle Stock Outfitter-Guide Permit FEIS 3-364 February 2013

Okanogan-Wenatchee National Forest

largest increases will be in people 60 years old and older. Therefore, the need for stock 

outfitter-guides will likely increase in the coming years at a faster rate than the general activity 

increases projected by the Washington State Interagency Committee on Outdoor Recreation, 

2003. Although only a small percentage of people over 50 years old actually take trips into the 

wilderness or backcountry, it is safe to assume that the number of people in that age class that 

do so could increase at a rate that matches the rates of increase in the general population –

approximately 25%17. 

ENVIRONMENTAL CONSEQUENCES

Direct/Indirect Effects

Figure 3.11-5 shows how the current number of service days and the number in each 

alternative. It also shows in comparative format the economy-wide contributions of each 

alternative. The service days represent different levels of income for pack and saddle stock 

outfitter-guides. A portion of the income is spent in the study area and ripples through the local 

economy. 

Figure 3.11-5: Summary of Permitted Days and Economy-Wide Contribution of Current Number of 

Service Days and By Alternative, Compared to Okanogan County Economy

Pack and Saddle Stock Outfitter-Guide Economy-wide 

Contribution

Current/Alternative Service 

Days

Employment

(# Jobs)

Labor Income

($2011)

Total Sales

($2011)

Current Condition 4,460 26.6 $890,504 $1,293,940

Alternative 1 0 0 0 0

Alternative 2 4,620 27.6 $922,451 $1,340,359

Alternative 3 2,660 15.9 $531,108 $771,722

Alternative 4 6,700 40.0 $1,337,753 $1,943,811

Okanogan County 

Economy

22,581 $803,916,135 $1,824,787,904

Alternative 1

Economic Impacts

There are no pack and saddle stock outfitter-guide permitted days under Alternative 1 and 

therefore no economic contribution from these businesses. This would result in approximately 

27 fewer jobs in Okanogan County annually, and a reduction of nearly $890,000 in labor income 

and $1.3 million in total sales, however these loses would only occur if there were no other 

opportunities for employment and income in the area to substitute for the loss of outfitter 

guide permits.

Social Impacts

The elimination of pack and saddle stock outfitter-guides under Alternative 1 would have the 

most impact on people over 50 years of age. This age class is more likely to need the services of 

 

17 (967,301 + 903,726 + 809,712)–(947,648 + 643,504 + 556,217)/(947,648 + 643,504 + 556,217) = 0.248 

or 25%
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a pack and saddle stock outfitter-guide to travel into the wilderness or backcountry and enjoy 

the type of recreation these settings offer. People unfamiliar with the analysis area, or lacking 

the skill and equipment to use pack and saddle stock would also lose the opportunity for this 

popular recreation activity.

Alternative 2

Economic Impacts

Figure 3.11-6 shows the economic contribution to Okanogan County from the 4,620 service days 

authorized in Alternative 2. 

Figure 3.11-6. Economic Contribution of Alternative 2 to Okanogan County Compared to Effect of 

Current Service Days

Impact Type Employment

(# Jobs)

Labor Income

($2011)

Total Sales

($2011)

Direct Effect 23.0 $785,032 $901,254

Indirect Effect 1.1 $35,181 $118,107

Induced Effect 3.4 $102,238 $320,998

Total Effect 27.6 $922,451 $1,340,359

Current Condition 26.6 $890,504 $1,293,940

Alternative 2 would create approximately 1 more job annually compared to the existing 

condition, and generate roughly $31,947 in additional labor income, and $46,400 in total sales. 

Social Impacts

Alternative 2 would slightly increase the number of service days authorized, so the pack and 

saddle stock outfitter-guides would be available for people who need them. Enough service 

days would be available to meet the current level of demand, but may fall short of demand in 

the future because of the projected increases in people over 50 who may need outfitter-guide 

services.

Alternative 3

Economic Impacts

Figure 3.11-7 shows the economic contribution to Okanogan County from the 2,660 service days 

authorized in Alternative 3. 

Figure 3.11-7. Economic Contribution of Alternative 3 to Okanogan County Compared to Effect of 

Current Service Days

Impact Type Employment

(# Jobs)

Labor Income

($2011)

Total Sales

($2011)

Direct Effect 13.2 $451,998 $518,904

Indirect Effect 0.6 $20,256 $68,001

Induced Effect 1.9 $58,864 $184,817

Total Effect 15.9 $531,108 $771,722

Current Condition 26.6 $890,504 $1,293,940
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Alternative 3 would potentially reduce the number of annual jobs in Okanogan County by 

roughly 11, labor income by approximately $360,000, and total sales by $522,000. As with 

Alternative 1, these losses would only occur if there were no other opportunities for 

employment and income in the area to substitute for the loss of outfitter guide permits.

Social Impacts

Alternative 3 would have a 40% reduction in the number of service days, compared to the 

permitted numbers under the current condition. This would have the greatest impact on those 

over 50 years old, since approximately 73% of the pack and saddle stock outfitter-guide clients 

fall in this age class. There would also be a reduced opportunity for people lacking experience 

or equipment to enjoy wilderness or backcountry recreation. It is likely that some people 

seeking this experience would not be able to find outfitter-guide services.

Alternative 4

Economic Impacts

Figure 3.11-8 shows the economic contribution to Okanogan County from the 6,700 service days 

authorized in Alternative 4. 

Figure 3.11-8. Economic Contribution of Alternative 4 to Okanogan County Compared to Effect of 

Current Service Days

Impact Type Employment

(# Jobs)

Labor Income

($2011)

Total Sales

($2011)

Direct Effect 33.4 $1,138,446 $1,307,014

Indirect Effect 1.6 $51,020 $171,280

Induced Effect 4.9 $148,268 $465,516

Total Effect 40.0 $1,337,753 $1,943,811

Current Condition 26.6 $890,504 $1,293,940

Alternative 4 would have the most positive benefits to the Okanogan economy of any 

alternative. It would increase the number of jobs generated by pack and saddle stock outfitterguides by approximately 13 compared to the existing condition. It would also increase labor 

income by approximately $450,000 and total sales by roughly $650,000. 

Social Impacts

Alternative 4 would increase the number of service days by approximately 50% over current 

levels. This would have a positive impact on people wanting pack and saddle stock recreation 

activities. As the age class distribution of the population shifts into the older segments, and the 

number of people traveling to the area increases, there would be enough service days available 

to meet potential increases in demand. 

Cumulative Effects

The geographic boundary for the cumulative effects is Okanogan County, with effects 

considered from the present to 2023, when the new permits would expire and any economic or 

social impacts would cease. Economic benefits to Okanogan County also benefit the economy 

of Washington State, but at that scale, the economic contribution of pack and saddle stock 

outfitter-guides is too small to measure.
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Past Actions

No past actions are currently contributing to the economy or having social impacts.

Present Actions

Outfitter-Guides

There are currently a number of other outfitter-guides and special use permit holders offering a 

variety of recreation opportunities. Refer to Figure 3.0-1 in the FEIS for a list. These companies 

are part of the “Other amusement and recreation services” sector of the economy shown in 

Figure 3.13-1. These companies offer a wide variety of services to all segments of the 

population and will likely continue to do so under their priority permits throughout the 

cumulative effects time boundary.

Total Recreation Use

There are approximately 400,000 visits to National Forest Land in Okanogan County each year 

according to the 2005 NVUM survey (US Forest Service, 2006a). This use contributes to nearly 

every segment of the Okanogan County economy shown in Figure 3.13-1. 

Reasonably Foreseeable Future Actions

Outfitter-Guides

It is reasonably foreseeable that all existing outfitter-guide and special use permit holders will 

continue to operate in the future.

Total Recreation Use

According to the Interagency Committee on Outdoor Recreation, the number of people 

recreating is on an upward trend that will likely continue for at least the next 20 years 

(Interagency Committee on Outdoor Recreation, 2003). This would increase the number of 

people recreating in Okanogan County, and increase the economic contribution over time. 

Demographics

There would be an approximate 25% increase in the number of people over 50 years old by the 

year 2020 compared to the current population distribution among the classes, according to the 

Washington State Office for Fiscal Management. The aging population will increase the demand 

for pack and saddle stock outfitter-guide services.

Alternatives 1, 2, 3, and 4

Economic Impacts

The cumulative effects of all other outfitter-guides and recreation that contributes annually to 

the “Other amusement and recreation services” category in Figure 13-1, and the alternatives is 

shown in Figure 3.11-9 below. This category would contribute between twelve and fourteen 

million dollars annually to the economy of Okanogan County, depending on the alternative.
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Figure 3.11-9. Cumulative Other Amusement and Recreation Services Economic Contribution by 

Alternative

Alternative/

Current

Employment

(# Jobs)

% Change 

from 

Current

Labor 

Income

($2011)

% Change 

from 

Current

Total Sales

($2011)

% Change 

from 

Current

Current 297 $6,215,524 $13,330,139

Alternative 1 270 -9% $5,325,020 -14% $12,036,199 -10%

Alternative 2 298 +0.3% $6,247,471 +5% $13,376,558 +0.3%

Alternative 3 286 -4% $5,856,128 -6% $12,807,921 -4%

Alternative 4 310 +4% $6,662,773 +7% $13,980,010 +5%

As shown in Figure 3.13-1, the total employment in Okanogan County is 22,581 jobs, total labor 

$803,916,135, and total sales $1,824,787,904. When considered cumulatively with the entire 

economy of Okanogan County, there is virtually no difference between the four alternatives.

Social Impacts

As stated above, the shift in the age distribution would increase the demand for pack and saddle 

stock outfitter-guide services in the future. The overall increasing trend in recreation use will 

also increase demand, albeit at a slower rate, for the other services currently being offered by 

the pack and saddle outfitter-guides and other recreation special use permit holders.

Alternative 1 would not meet the need for the aging population in terms of pack and saddle 

stock activities, but the other outfitter-guides would likely meet the demand for other types of 

recreation. Alternatives 2, 3, and 4 would all offer pack and saddle stock commercial services, 

so these alternatives added to the other outfitter-guides services being offered would provide 

access for nearly all segments of the population to more types of recreation experiences on 

National Forest System land than Alternative 1.

3.12 HERITAGE RESOURCES_________________________

The section below is a summary of the information included in the Heritage Program Appendix B 

Project Documentation Report from the analysis file (Dowie and Lenz 2011).

REGULATORY FRAMEWORK

Heritage resources on the Okanogan-Wenatchee National Forest are districts, sites, buildings, 

structures, and objects that contain evidence of past human activities. Traditional Cultural 

Properties (TCP), defined as resources of traditional cultural importance, are also included. 

Heritage resources are managed in accordance with the National Historic Preservation Act 

(NHPA) and its implementing regulation (36 CFR 800), the Archaeological Resources Protection 

Act (ARPA), the American Indian Religious Freedom Act (AIRFA), Native American Graves 

Protection and Repatriation Act (NAGPRA), and Executive Orders 11593, 13007, and 13175. 

Forest Plan Direction

The following forest-wide heritage resources standards and guidelines apply to the project area. 
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Okanogan Forest Plan Forest-wide Standards and Guidelines (USDA Forest Service 1989b, 

pages IV-36 to IV-38) 

7-2--Inventory all areas where ground-disturbing activities are planned in order to discover 

all reasonably locatable cultural resources, and in accordance with an Inventory Plan as 

specified in the Programmatic Memorandum of Agreement (PMOA) between Region 6 and 

the Washington State Historic Preservation Office.

7-3--Develop a schedule to evaluate cultural resources based on the criteria for eligibility to 

the National Register of Historic Places. First priority shall be for those cultural resources 

that may be affected by project activities. 

7-5--Protect eligible cultural resources from management activities by making reasonable 

efforts to avoid adverse impacts to the resource or develop a procedure to conserve the 

values through proper scientific methods of study. 

7-14--Coordinate with Native American Tribes regarding cultural resources of suspected 

prehistoric origin and to identify key native plant gathering areas and species. 

7-15--Information about planned project activities shall be presented to Native American 

Tribes for coordination about effects to traditional religious sites. 

7-16--Consultation with the Washington State Historic Preservation Officer shall follow the 

procedures in the PMOA between Region 6 and Washington State Office of Archaeology and 

Historic Preservation.

Wenatchee Forest Plan Forest-wide Standards and Guidelines (USDA Forest Service 1990) 

Conduct cultural resource inventories (survey and site recordation) according to strategies 

and consultation procedures established on the Forest. Emphasis will be given to all areas 

where ground disturbing activities are planned, to ensure discovery of all reasonably 

locatable cultural resources. These inventories should be supervised by a cultural resource 

professional (page IV-66).

Evaluate the significance of inventoried sites by applying the criteria for eligibility to the 

National Register of Historic Places (page IV-66).

Consider the effects of all Forest Service undertakings on significant cultural resources, and 

assure the development of measures to avoid or mitigate any adverse effects (IV-66).

Neither Forest Plan has management area specific direction that applies to cultural resources. 

All management direction is found in the forest-wide standards and guidelines above.

The Forest Service is responsible for the management of heritage resources that are listed or are 

eligible for listing on the National Register of Historic Places (NRHP). Listed or eligible heritage 

resources are known as historic properties and they are given consideration in planning for 

federally licensed, permitted, approved, or funded projects. Heritage resources that are 

documented but not yet evaluated for nomination or listing on the NRHP, are managed as 

eligible also. Sites that have been determined ineligible require no further management 

consideration, although the National Environmental Policy Act requires that the effects to 

ineligible resources be evaluated by alternative.

Tribal Consultation

Executive Order 13175 and the NHPA require consultation with tribal governments when federal 

projects have the potential to affect resources of interest to the tribes, tribal rights guaranteed 
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by treaty or executive order, and the agency’s trust responsibility to federally recognized tribal 

governments. For this project, formal government-to-government letters and maps were 

mailed to the Yakama Nation and to the Confederated Tribes of the Colville Reservation in June, 

2005. The letters described the project, defined the area of potential effect, and outlined how 

effects to heritage resources would be considered. Neither tribe identified concerns about the 

proposal.

ANALYSIS METHOD

Area of Analysis

The Area of Potential Effect (APE) for this analysis includes the complete project planning area 

(Map 1-1 in the Map Section). The area is extensive and covers portions of the Methow River 

and many of its subdrainages including the Chewuch River, Twisp River, West Fork Methow and 

Lost River. It also includes the following: the Ashnola and Pasayten River drainages, Canyon 

Creek in the western Pasayten Wilderness, which flows into Granite Creek, creeks in the far 

eastern area of the Pasayten Wilderness that drain into the Sinlahekin River and creeks on the 

south side of the Sawtooth Ridge that flow into Lake Chelan. 

Survey Design

Heritage resource site and report files at Forest Headquarters and at the Methow Valley, Chelan 

and Tonasket Ranger District offices were reviewed to determine where field inventory had 

already occurred and where heritage resources associated with those inventories had been 

documented. Potential effects to cultural resources were assessed by consulting the Forest 

Heritage GIS site layer and by reviewing pertinent literature, Section 106 project reports, site 

records and the National Register of Historic Places. Employees with a working knowledge of 

the landscape were also consulted. 

Cultural resource surveys were guided by the site survey model used on both the Okanogan and 

Wenatchee national forests. The model uses a variety of environmental variables – such as 

slope, distance to water, and landform type – along with oral and recorded history to predict the 

likelihood that an area will contain material evidence of past human activity. Sample strategy 

standards require that intensive, systematic pedestrian survey be applied to no less than 100% 

of high probability areas, 35% of moderate probability areas, and 5% of low probability areas. 

With the exception of one site, Hootowl, campsites are all within high probability areas due to 

location of perennial water and slope of less than 15%. Hootowl is in moderate as it is further 

than 150 meters to perennial water. Because of the acreage and large number of sites involved, 

field survey specific to this undertaking was limited to a sample of assigned or primary outfitter 

campsites located in readily accessible high site probability areas. The objective of the sample 

reconnaissance is to locate all extant archaeological resources that may reasonably be detected 

from an inspection of ground surfaces. 

AFFECTED ENVIRONMENT

The rich history of prehistoric and historic activities throughout the analysis have left cultural 

and historic sites scattered across the landscape. Many of the campsites used by outfitter-
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guides are associated with historical sheepherding, mining, hunting, trapping, recreation (trail 

shelters) or fire suppression (former lookout sites). Other than the can dump sites, no 

previously unknown historic or prehistoric resources were located in any of the camps surveyed 

for this project.

Completed Inventories

A summary of cultural resource investigations that have been conducted in outfitter-guide 

camps is described in Heritage Program Appendix B Project Documentation Report in the 

analysis file (Dowie and Lenz 2008). 

Many of the campsites used by outfitter-guides are associated with historical sheepherding, 

mining, hunting, trapping, recreation (trail shelters) or fire suppression (former lookout sites). 

Other than the can dumps, no previously unknown historic or prehistoric resources were 

located in any of the camps surveyed for this project on the Chelan or Methow Valley Ranger 

Districts. 

Past surveys have identified several historic sites within or near existing camps used by 

outfitters. These sites are usually associated with past trapping, mining, grazing and Forest 

Service administration activities. Many were cabins, lookouts and mines. None are listed on the 

National Register of Historic Places, with the exception of the Parson Smith tree, which removed 

from the analysis area and stored to preserve it. 

There are known sites located in the general vicinity of the camps that have been frequented by 

pack and saddle stock outfitter-guides, but not within the camps. Outfitters may have ridden by 

or stop and look at such sites but such activity would have no effect on the sites. Historic cabins 

at the Airport and Hidden Lakes are in close proximity to campsites that have been used by 

outfitters. These structures are currently maintained as administrative sites, and are pending 

SHPO concurrence on their eligibility to the National Register of Historic Places. There is also a 

picnic shelter at First Hidden Lake which is eligible to the National Register of Historic Places. 

Outfitter use in the vicinity of the Airport and Hidden Lake structures has been confined to 

adjacent camp areas, non-historic hitchrails, and the picnic shelter. . This is periodically used by 

outfitters, but the use is not damaging or altering the shelter. 

There are no known prehistoric sites in the areas the outfitters are operating.

ENVIRONMENTAL CONSEQUENCES

Direct/Indirect 

Alternative 1

Alternative 1 would have no direct or indirect effects on cultural resources from outfitter-guide 

activities. The potential of damage to cultural resources from non-outfitted recreationists 

would remain.
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Alternatives 2, 3, and 4

Pack and saddle stock outfitter-guide activities would have no effect on cultural resources with 

implementation of any of these alternatives. They would be required to camp in existing, 

authorized locations, and would be prohibited from increasing the amount of barren core in any 

campsite or constructing new trails. This would avoid new ground disturbance. The outfitters 

would be required to comply with all terms and conditions of their permits, including the 

following resource protection clause

The holder shall immediately notify the authorized officer of any antiquities or other objects 

of historic or scientific interest, including but not limited to historic or prehistoric ruins, fossils, 

or artifacts discovered as the result of operations under this permit. The holder shall leave 

such discoveries intact until authorized to proceed by the authorized officer. Protective and 

mitigative measures specified by the authorized officer shall be the responsibility of the 

holder.

Violations of any term or conditions of the permit could result in notices of non-compliance, or 

permit action. The permit action could be reducing service days, reducing the permit area, or 

permit cancellation.

Cumulative Effects

The area considered for heritage resources cumulative effects analysis consists of the Area of 

Potential Effect (analysis area). The time period considered for cumulative effects analysis 

includes up to 10 years into the future, the time-period of the proposed outfitter-guide special 

use permit issuance and any effects from the issuance of these permits would cease. From the 

list of past, present and reasonably foreseeable future actions at the beginning of this chapter, 

only ground-disturbing activities were considered in this cumulative effects analysis since these 

activities have the potential to affect heritage resources. 

Alternative 

There would be no cumulative effects from this alternative because there would be no pack and 

saddle stock outfitter guides operating in the analysis area. 

Alternatives 2, 3, and 4

There would also be no cumulative effect with Alternatives 2, 3, or 4 since the pack and saddle 

stock outfitter-guides would not affect or damage cultural resources. 

CONSISTENCY FINDINGS

In all action alternatives, the consideration of effects to heritage resources is consistent with 

Forest Plan standards and guidelines. 
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Okanogan Forest Plan Forest-Wide Standards and Guidelines

7-2--Inventory all areas where ground-disturbing activities are planned in order to discover 

all reasonably locatable cultural resources, and in accordance with an Inventory Plan as 

specified in the Programmatic Memorandum of Agreement (PMOA) between Region 6 and 

the Washington State Historic Preservation Office.

There would be no new ground disturbing activities associated with any alternative. The 

pack and saddle stock outfitter-guides would be required to use established campsites, 

and not increase the amount of barren core at any site (Alternatives 2 and 3 would limit 

the amount of barren core the outfitters could use at any site). The outfitters would not 

be allowed to create new campsites or construct new trail.

7-3--Develop a schedule to evaluate cultural resources based on the criteria for eligibility to 

the National Register of Historic Places. First priority shall be for those cultural resources 

that may be affected by project activities. 

This standard and guideline does not apply to the pack and saddle stock outfitter-guides. 

They would not be allowed to use any of the cabins, and would have no impact of 

resources eligible or potentially eligible to the National Register of Historic Places.

7-5--Protect eligible cultural resources from management activities by making reasonable 

efforts to avoid adverse impacts to the resource or develop a procedure to conserve the 

values through proper scientific methods of study. 

As stated in the discussion of 7-2 above, the pack and saddle stock outfitter guides would 

not be allowed to disturb new ground since construction of new camps or trails would be 

prohibited. Adverse impacts to resources would be avoided.

7-14--Coordinate with Native American Tribes regarding cultural resources of suspected 

prehistoric origin and to identify key native plant gathering areas and species. 

7-15--Information about planned project activities shall be presented to Native American 

Tribes for coordination about effects to traditional religious sites. 

Consultation with the Yakama Nation and the Confederated Tribes of the Colville Nation 

was completed. Information about the proposed action was provided, and the request 

made for information about cultural resources and native plant gathering areas. No 

responses were received. The government-to-government letters are in the analysis file.

7-16--Consultation with the Washington State Historic Preservation Officer shall follow the 

procedures in the PMOA between Region 6 and Washington State Office of Archaeology and 

Historic Preservation.

This project complies with Section 106 of the National Historic Preservation Act, under 

the terms of the 1997 Programmatic Agreement between ACHP (Advisory Council Historic 

Preservation), Washington State Heritage Protection Officer (SHPO), and Region 6 of the 

US Forest Service. The project meets the conditions listed in Appendix B of the 

Programmatic Agreement and under the programmatic agreement, is excluded from 

case-by-case review by SHPO. Refer to the Project Documentation report in the analysis 

file.
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Wenatchee Forest Plan Forest-wide Standards and Guidelines

Conduct cultural resource inventories (survey and site recordation) according to strategies 

and consultation procedures established on the Forest. Emphasis will be given to all areas 

where ground disturbing activities are planned, to ensure discovery of all reasonably 

locatable cultural resources. These inventories should be supervised by a cultural resource 

professional (page IV-66).

There would be no new ground disturbing activities associated with any alternative. The 

pack and saddle stock outfitter-guides would be required to use established campsites, 

and not increase the amount of barren core at any site (Alternatives 2 and 3 would limit 

the amount of barren core the outfitters could use at any site). The outfitters would not 

be allowed to create new campsites or construct new trail.

Evaluate the significance of inventoried sites by applying the criteria for eligibility to the 

National Register of Historic Places (page IV-66).

This standard and guideline does not apply to the pack and saddle stock outfitter-guides. 

They would not be allowed to use any of the cabins, and would have no impact of 

resources eligible or potentially eligible to the National Register of Historic Places.

Consider the effects of all Forest Service undertakings on significant cultural resources, and 

assure the development of measures to avoid or mitigate any adverse effects (IV-66).

There would be no new ground disturbing activities associated with any alternative. The 

pack and saddle stock outfitter-guides would be required to use established campsites, 

and not increase the amount of barren core at any site (Alternatives 2 and 3 would limit 

the amount of barren core the outfitters could use at any site). The outfitters would not 

be allowed to create new campsites or construct new trail.

3.13 SPECIFICALLY REQUIRED DISCLOSURES

This section describes how the action alternatives comply with other Forest Plan standards and 

guidelines, and applicable state and federal laws, regulations and policies.

The best available science was used for this analysis, including the methodology and data 

sources described below, to describe the ecological and social conditions within the analysis 

area, and the potential effects of the proposed outfitter-guide use on resources and people.

INVENTORIED AND UNINVENTORIED ROADLESS AREAS

The analysis area includes portions of, and entire Inventoried Roadless Areas and other 

unroaded areas. The Okanogan-Wenatchee National Forest has completed a draft Potential 

Wilderness Area evaluation as part of the Forest Plan revision. None of the alternatives would 

have any direct, indirect, or cumulative effect on roadless or undeveloped nature of these areas 

since they would not involve road or trail construction, or vegetation management. This project 

is consistent with the Roadless Area Conservation Rule (RACR) because, except for personal 

firewood use, no trees would be cut, sold or removed and no roads would be constructed or 

reconstructed in inventoried roadless areas. Personal firewood use is a permitted exception to 

the RACR prohibition on timber cutting, and has been re-delegated back to the local line officers 

by the Secretary of Agriculture.
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VISUAL QUALITY OBJECTIVES

There are a variety of Visual Quality Objectives throughout the analysis area. The most 

restrictive objective is preservation, which occurs in the wilderness areas, and along the North 

Cascades Scenic Highway where the objective is retention. All the alternatives would meet the 

Visual Quality Objectives for any given spot in the analysis area since there would be no 

vegetation management or permanent structures. Temporary structures would be constructed 

of materials and design that would meet preservation requirements. There would be no direct, 

indirect, or cumulative effect on the visual quality throughout the analysis area.

CONSISTENCY WITH NATIONAL ENVIRONMENTAL POLICY ACT, THE 

NATIONAL FOREST MANAGEMENT ACT, AND THE OKANOGAN AND 

WENATCHEE FOREST PLANS

This project and this analysis is consistent with the Okanogan and Wenatchee Forest Plans as 

amended and with the National Forest Management Act, which requires that resource plans and 

permits, contracts, and other instruments for the use and occupancy of National Forest System 

lands shall be consistent with the land management plans. The Forest Plans contain direction 

for each resource area. The discussion of how the alternatives analyzed in this FEIS meet that 

direction is included in the discussions above in Chapter 3. This analysis was prepared to meet 

the requirements of the National Environmental Policy Act of 1969 and its implementing 

regulations and Forest Service Regulations at 36 CFR 220, to inform the public of the proposed 

action and alternatives and to disclose the effects of implementation.

NATIONAL HISTORIC PRESERVATION ACT

This project complies with Section 106 of the National Historic Preservation Act, under the terms 

of the 1997 Programmatic Agreement between the Washington State Historic Preservation 

Officer (SHPO) and Region 6 of the U.S. Forest Service.. The project meets the conditions listed 

in Appendix B of the Programmatic Agreement and has been excluded from case-by-case review 

by SHPO as documented in an Appendix A supplement (see 3.12 Heritage section of Chapter 3). 

Formal government-to-government letters were mailed to the Yakama Nation and to the 

Confederated Tribes of the Colville Reservation in June, 2005. Neither tribe identified concerns 

about the proposal.

ENDANGERED SPECIES ACT AND REGIONAL FORESTER’S SENSITIVE 

SPECIES

The Endangered Species Act (ESA) rquires protection of all species listed as threatened or 

endangered by the U.S. Fish and Wildlife Service and the National Marine Fisheries Service. The 

Forest Service maintains a list of species that are proposed for classification and official listing as 

threatened or endangered under the ESA and maintains lists of Sensitive species that are 

recognized by the Regional Forester as needing special management to prevent placement on 

Federal or State threatened or endangered lists. In addition, the Forest Service coordinates with 

the State on management of species that appear on official State threatened, endangered or 

sensitive lists. Biological evaluations and assessments have been completed for all threatened, 

endangered and sensitive plants, aquatic species, and terrestrial wildlife. Determinations were 

made that the proposed action would not adversely affect threatened or endagered species nor

contribute to a trend toward federal listing, or cause a loss of viability to listed or sensitive plant, 
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fish, and animal populations or species. Details are found in the Aquatic Resources, Botany and 

Terrestrial Wildlife sections of this chapter and their respective specialist’s reports and biological 

assessments. Consultation with the regulatory agencies was not necessary for plants because 

no threatened or endangered plants would be affected by the project but has been completed 

for threatened and endangered fish and wildlife species and critical habitat. USFWS and NOAAFishies concurred with the effects determinations in concurrence letters dated January 28, 2013 

and November 13, 2012, respectively.

CLEAN AIR ACT

The Clean Air Act (Public Law 95-95, as amended in 1977 and 1990) is a legal mandate designed 

to protect public human health and welfare from air pollution. The act defines National 

Ambient Air Quality Standards (NAAQS) as levels of pollutant above which detrimental effects 

on human health and welfare could occur. Particulate Matter (PM), the major pollutant of 

concern from wildfires and prescribed fires, includes any airborne finely-divided solid or liquid 

material with an aerodynamic diameter smaller than 100 micrometers (mictrons).

The Clean Air Act and its amendments define responsibility for air quality. The Environmental 

Protection Agency (EPA) has the responsibility to develop the NAAQS, while individual states are 

responsible for developing a Smoke Implementation Plan (SIP), including a smoke management 

program, in order to meet or exceed these standards. Since 1997, the EPA has standards for 

levels of PM10 (coarse particles less than 10 microns in size), and PM2.5 (fine particles are less 

than 2.5 microns in size). The Clean Air Act established Class I air quality designations, where 

little air quality deterioration over baseline is allowed. Most of the Pasayten Wilderness (that 

portion designated in 1968) is the only Class I airshed in or near the analysis area.

Smoke from campfires in the Pasayten or Lake Chelan-Sawtooth Wilderness would not violate 

the Clean Air Act. People camping in the wilderness areas, including clients and employees of 

pack and saddle stock outfitter-guides are allowed to have campfires. These campfires tend to 

burn quickly and efficiently, with nearly total consumption of the fuel. They also occur at times, 

and in locations, where air movement keeps the smoke from settling into a localized area. The 

outfitter-guides are required by their permits to extinguish all campfires before leaving camp, 

which further reduces the possibility of a fire smoldering over a long period of time. In addition, 

the Okanogan-Wenatchee National Forest has a policy and process in place to prohibit 

campfires if conditions warrant the restriction. Campfires outside of the wildernesses would not 

reach or affect wilderness for the same reasons.

All alternatives would meet the Clean Air Act standards and would be consistent with the 

Washington State SIP. Refer to the Air Quality information in the project analysis file.

WILD AND SCENIC RIVER ACT

The Chewuch River section adjacent to Upper Methow area is allocated under the Okanogan 

National Forest Land and Resource Management Plan to maintain its potential Scenic River 

classification within one-quarter mile of the river (Forestwide standard and guideline 9-3). One 

assigned site near Andrews Creek Trailhead is within one-quarter mile of the river, but 

maintenance of the corral there would not affect future potential designation under the Wild 

and Scenic River system because the corral is not a permanent structure, and could be removed

if the Chewuch River is designated as Wild and Scenic.
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FLOODPLAINS AND WETLANDS

Executive Orders 11988 and 11990 direct Federal agencies to avoid, to the extent possible, both 

short-term and long-term adverse impacts associated with the modifications of floodplains and 

wetlands. Surveys and research carried out for this EIS indicated that there are designated 

wetlands within the project area. There are 35 camps within 500 feet of wetlands, and 

approximately 86 acres of wetlands would be potentially affected by this project. Under 

Alternatives 2 and 4, these existing campsites would continue to be used by pack and saddle 

stock outfitter-guides, in addition to private pack and saddle stock users. The current impacts to 

nearby wetlands would continue, including vegetation trampling, selective grazing, and soil 

damage in approximately 1% of the wetland habitat in the analysis area. The remaining 99% of 

the wetlands would be unaffected. Riparian reserves and riparian habitat conservation areas 

were designated in part to protect floodplain functions. The proposed outfitter-guide activities 

would meet the Aquatic Conservation Strategy and Riparian Management Objectives. Refer to 

the Botany section of Chapter 3 (beginning on page 3-235) for detailed information about the 

existing condition and environmental effects on wetlands. The Aquatic Resources section 

beginning on page 3-182 includes details concerning floodplains, the Aquatic Conservation

Strategy and the Riparian Management Objectives.

PRIME FARMLANDS, RANGELANDS, FORESTLANDS

The Secretary of Agriculture issued Memorandum 1827, which is intended to protect prime 

farmlands and rangelands. The policy for Prime Forestlands is in Forest Service Handbook 

1909.15, 65, 21 (USDA, 2008). The project area does not contain any prime farmlands. These 

designations generally do not apply to lands within the National Forest System. This project 

would not convert any prime rangelands or prime forestlands to other uses. National Forest 

system lands would be managed with consideration of the impacts on adjacent private lands. 

There would be no direct, indirect, or cumulative adverse effects to these resources.

RESEARCH NATURAL AREAS

No outfitter-guide activities would be allowed in Research Natural Areas, so there would be no 

direct, indirect, or cumulative effects to these areas.

CIVIL RIGHTS AND ENVIRONMENTAL JUSTICE

Civil Rights

Civil rights would not be affected by any of the alternatives. Under Executive Order 11246, 

companies with Federal contracts or subcontracts are prohibited from job discrimination on the 

basis of race, color, religion, sex or national origin. The U.S. Department of Agriculture (USDA) 

prohibits discrimination in all its programs and activities on the basis of race, color, national 

origin, age, disability, and where applicable, sex, marital status, familial status, parental status, 

religion, sexual orientation, genetic information, political beliefs, reprisal, or because all or a 

part of an individual's income is derived from any public assistance program. Special Use 

permits authorizing Outfitting-Guiding contain the following nondiscrimination language:

The holder and its employees shall not discriminate against any person on the 

basis of race, color, sex (in educational activities), national origin, age, or disability 

or by curtailing or refusing to furnish accommodations, facilities, services, or use 
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privileges offered to the public generally. In addition, the holder and its 

employees shall comply with the provisions of Title VI of the Civil Rights Act of 

1964 as amended, Section 504 of the Rehabilitation Act of 1973, as amended, Title 

IX of the Education Amendments of 1972, as amended, and the Age 

Discrimination Act of 1975, as amended.

The holder shall include and require compliance with the above nondiscrimination provisions in 

any third-party agreement made with respect to the operations authorized under this permit.

The Forest Service shall furnish signs setting forth this policy of nondiscrimination. These signs 

shall be conspicuously displayed at the public entrance to the premises and at other exterior or 

interior locations, as directed by the Forest Service.

The Forest Service shall have the right to enforce the foregoing nondiscrimination provisions by 

suit for specific performance or by any other available remedy under the laws of the United 

States or the State in which the violation occurs.

Environmental Justice

The following discussion is derived from the 2010 census information found at www.census.gov, 

using queries of the American Fact Finder. Although actual permitted Outfitter-Guide activities 

will take place on National Forest System lands, approximately 85% (see Economic and Social 

Section of this chapter) of clients travel from out-of-town to the Outfitter-Guide’s base camps, 

trailheads or other access points, primarily in the Methow Valley or along Lake Chelan. The only 

potential effects to environmental justice from this project would be increased traffic through 

high poverty or low income areas on roads travelled by out-of-town Outfitter-Guide clients to 

the base camps, trailheads or other Forest access points, and the economic viability of 

Alternative 3. Out-of-town clients are likely to travel through combinations of the following 

towns in Chelan and Okanogan County: Brewster, Cashmere, Chelan, Chelan Falls, Conconully, 

Entiat, Leavenworth, Methow, Okanogan, Omak, Oroville, Pateros, Riverside, Tonasket, Twisp, 

Wenatchee and Winthrop. 

Although Chelan County poverty rates are below both Washington State and national averages, 

Okanogan County exceeds both of those averages by about 52% and 33% respectively. Most of 

the towns in both counties have poverty levels above the national and state averages; the 

exceptions are Cashmere and Conconully (both above state average, below national average), 

and Chelan, Wenatchee and Winthrop (below both). Poverty is especially acute (more than 

twice the national and state averages) in the town of Oroville, and high (more than 50% above 

the national average) in Brewster. Measured at the state level, the towns of Brewster, Chelan 

Falls, Entiat, Okanogan, Omak, Tonasket and Twisp have acute poverty (approximately or more 

than 50% of the state average). 

The 2010 census information reports the percent of white, non-Hispanic populations. Because 

this language is awkward, the inverse number is used in this report to discuss minority 

populations (to which the Environmental Justice Executive Order applies). Although Chelan and 

Okanogan County minority populations are below the national averages for minorities, both 

exceed Washington State averages by about ten percent. The town of Brewster has a very high 

minority population (at 72.1%, more than double the national average, and over 2 1⁄2 times the 

Washington State average). The towns of Chelan Falls, Oroville, and Pateros also all exceed the 
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national averages; additionally the town of Cashmere and Omak, and City of Wenatchee both 

slightly exceed the Washington State minority population averages.

Although 85% of the clients come from outside the area, they would be spread across many 

different routes over the operating season, and they would travel almost exclusively on State 

Highways, except the last few miles to base camps, trailheads or other access points to the 

Forest. Clients would be even more dispersed on these local roads because most OutfitterGuides use different access points to the Forest. Because of this dispersion and the current level 

of traffic on primarily State Highways, it is extremely unlikely additional traffic from these 

clients, when added to other traffic already present on these roads, would be noticeable to 

residents along these routes. For a discussion of the economic benefits from clients passing 

through these towns and making purchases, see the Socio-Economic section of this Chapter.

In order for Outfitter-Guides to remain economically viable under the restricted party size of 

Alternative 3, it is likely they would have to raise their fees. Although all clients would be 

charged the same fee regardless of income level, if the fees are raised, it may disproportionally 

discourage lower income clients from using Outfitter-Guide services.

OTHER JURISDICTIONS

The Okanogan and Wenatchee Forest Plans guide management of National Forest System lands 

in the analysis area. Information relating to how the project meets Forest Plan standards and 

guidelines and effects relating to other federal and state laws are also analyzed throughout this 

chapter. To the extent that State and local laws are applicable to this project, this information is 

analyzed in the appropriate resource section of this chapter . Implementation of all alternatives 

would be consistent with State and local laws, land use, and environmental policies.

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). The Multiple Use - Sustained Yield Act of 1960 requires the Forest Service to manage 

National Forest System lands for multiple uses (including timber, recreation, fish, wildlife, range 

and watershed). All renewable resources are to be managed in such a way that they are 

available for future generations.

Soil and water are two key factors in ecosystem productivity, and these resources would be 

protected through design criteria and mitigation measures as described in Chapter 2. The 

quality of water from the project area may fluctuate as a result of short-term uses, but no longterm effects to water resources are expected to occur as a result of outfitter-guide activities 

(See Aquatics and Water Resources sections in this chapter).

All alternatives would provide the fish and wildlife habitat necessary to contribute to the 

maintenance of viable, well-distributed populations of existing native and non-native species. 

By managing the habitat of management indicator species, the other species associated with the 

same habitat would also benefit. The alternatives include amended standards and guidelines, 

design criteria and mitigation measures for maintaining long-term habitat and species 

productivity (see Terrestrial Wildlife, Aquatic Resources, Botany, and Water Resouces sections in 

this chapter).
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None of the alternatives would have an effect on the long-term productivity of timber 

resources.

IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES

Irreversible commitment of resources refers to a total loss of future options with non-renewable 

resources such as through mineral extraction or loss of heritage resources. Under the 

alternatives, various amounts of fossil fuels would be expended. Fossil fuel energy would be 

used for this project (vehicular transportation of clients and stock to and from trailheads) and 

would be an irreversible commitment of the fuel used. However, these energy sources are not 

currently in short supply, and the amount of fuel used annually would be very small when 

considered on a local, regional or national scale, and therefore their use would not have an 

effect upon continued availability of these resources. There would be no other irreversible 

commitment of resources with any alternative.

Irretrievable commitment of resources refers to losses that cannot be regained, but do not 

result in total loss of future options. Use of firewood and vegetation loss in campsites (barren 

core) would be irretrievable. The management of firewood use by the pack and saddle stock 

outfitter-guides would ensure that ample firewood exists in the present and future. Barren core 

areas would be perpetuated by pack and saddle stock outfitter-guide activities, so the loss of 

vegetation would be irretrievable as long as the activity continues. Limitations on the use and 

size of barren core would prevent expansion. 

UNAVOIDABLE IMPACTS

Each section of Chapter 3 documents the unavoidable impacts associated with the project. Figure 

3.13-1 summarizes these impacts:

Figure 3.13-1: Unavoidable Impacts

Resource Impact

Wildlife Disturbance and displacement impacts causing wildlife to relocate

Noise and human activity in and around campsites.

Impacts that constitute habitat losses for species.

Soil disturbance within campsites, at stock watering locations, and trail 

crossings (see Soils section of this chapter and report in the analysis file).

Vegetation loss within campsites (see Wilderness and Botany sections earlier 

in the chapter and reports in the analysis file).

Loss of grass and forb production from invasive species invasion and spread 

(see Invasive Species section earlier in this chapter and report in the analysis 

file).

Riparian habitat effects from stock watering and trail crossings (see Aquatics 

and Water Resources sections earlier in this chapter and reports in the 

analysis file). 

Water/Aquatic 

Resources

Sediment production and delivery to streams from pack and saddle stock 

activities could slightly reduce water quality in the vicinity of the disturbance 

sites. Fecal coliform would be introduced into waterways by outfitter-guide 

stock and clients (see Aquatics and Water Resources sections earlier in this 

chapter and reports in the analysis file).
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Soil Soil disturbance within campsites, at stock watering locations, and trail 

crossings (see Soils section earlier in the chapter and report in the analysis file). 

Human or recreational stock disturbances to streambanks and riparian areas are 

localized near trail crossing areas and campsites in the Pasayten and Sawtooth 

Wilderness Areas. Areas above and below these disturbance areas are in 

pristine condition, with no sign of human or stock use, intact streambanks, and 

established vegetation. These disturbed areas are watering locations near 

campsites and/or at trail crossings where unavoidable trampling occurs. 

Trampling exposes bare soil and causes alteration to the streambank. This 

erosion is not affecting water quality beyond the isolated, local areas due to 

relative small size and infrequent occurrence. 

Forest Vegetation Vegetation loss within campsites (see Wilderness and Botany sections earlier in 

this chapter and reports in the analysis file).

Plant Communities No long-term modifications of plant succession or communities would occur. 

Isolated short-term modifications that can recover in one growing season could 

occur (see Botany section earlier in this chapter and report in the analysis file).

Invasive Plants Soil disturbance would create sites for establishment of invasive plants (see 

Invasive Species section earlier in this chapter and report in the analysis file).

Recreation Outfitter-guide activities would add to the total number of non-outfitted 

recreationists in the area. Non-outfitted recreationists would encounter 

outfitter-guide clients and stock, potentially impacting the recreation 

experience by decreasing opportunities for solitude (see Wilderness and 

Recreation sections earlier in this chapter and report in the analysis file). 

Air Quality Smoke from isolated campfires could cause local, short-term changes in air 

quality. No violations of Clean Air Act (see Air Quality section earlier in this 

chapter and report in analysis file).

Sensitive Plants Possible impacts to some individuals, but would not cause a trend toward 

Federal listing or loss of population viability (see Botany section earlier in this 

chapter and report in the analysis file).

Wilderness 

Character

There will be localized impacts to the natural quality of Wilderness by impacts 

to water quality and vegetation, and to opportunities for solitude because of 

campsites and encounters on trails (see Wilderness section earlier in this 

chapter and report in the analysis file).

Wetlands Approximately 86 acres of wetlands could be impacted by outfitter-guide 

activities. Impacts could include trampling of plants and soil compaction and 

displacement. Impacted wetlands would be approximately 1% of all wetlands in 

the analysis area, so the majority of wetlands would not be affected (see Botany 

section earlier in this chapter and the report in the analysis file>

TRIBAL INTERESTS

Although the project area lies outside the areas ceded to the United States by the Colville 

Confederated Tribes and the Yakama Nation, the federal government still has a trust 

responsibility to manage resources of interest to the tribes in a manner consistent with the 

rights and privileges secured through treaty or executive order.

The “inherently sovereign” status of federally recognized tribes requires that land management 

agencies consult with tribes on a government-to-government basis about planned actions that 

may affect tribal interests. At the early stages of the planning process, the Forest Service 

initiated government-to-government consultation with the Confederated Colville Tribes and the 

Yakama Nation (copies of the letters are in the analysis file). Neither Tribe expressed any 

concerns regarding this project. 
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ENERGY REQUIREMENTS/NATURAL OR DEPLETABLE RESOURCES AND 

CONSERVATION

Under the alternatives, various amounts of fossil fuels would be expended to power the vehicles 

used for transporting clients and stock. Fossil fuel energy would be used for this project and is

an irreversible commitment of resources. These energy sources are not currently in short 

supply, and the amount of fuel used annually would be very small on a local, regional or national 

scale, therefore their use would not have an effect upon continued availability of these 

resources.

PUBLIC HEALTH AND SAFETY

Public health and safety would be protected by the mitigaton measures and terms and 

conditions of the special use permits. Outfitter-guides would be monitored and evaulated on 

public health and safety.

URBAN QUALITY, HISTORIC AND CULTURAL RESOURCES, AND THE BUILT 

ENVIRONMENT

No urban or built environment is present in the project area. Field surveys for historic and 

cultural resources were limited to a sample of outfitter-guide campsites because of the size of 

the analysis area. Other than the can dumps, no previously unknown historic or prehistoric 

resources were located in any of the camps surveyed. The outfitter-guide activities would have 

no effect on any cultural or historic sites.

Past surveys have identified several historic sites within or near existing camps used by 

outfitters. These sites are usually associated with past trapping, mining, grazing and Forest 

Service administration activities. Many were cabins, lookouts and mines. None are listed on the 

National Register of Historic Places, with the exception of the Parson Smith tree which is no 

longer within the area of potential effect (APE). The tree was cut down and moved to the Forest 

Service office to prevent decomposition.

Potential for damage to historic or cultural resources would be minimized in both action 

alternatives based on the surveys and probability analysis conducted and special use permit 

clause requiring outfitter-guides to protect cultural resources.