for the greatest good

United States Department of Agriculture

Sucker Creek Legacy 

Roads and Trails

Environmental Assessment

for the greatest good

November 2014
For More Information Contact: 

Chris Park

Forest Hydrologist

2164 NE Spaulding Avenue

Grants Pass, OR 97526

Phone: (541) 471-6761

Email: cpark@fs.fed.us

Fax: (541) 471-6514
Sucker Creek Legacy Roads and Trails Project

Contents

Chapter I. Purpose and Need for Action ........................................................................................ vi

Introduction................................................................................................................................. 1

Purpose and Need for the Proposal............................................................................................. 1

Location of the Proposed Project Area.................................................................................... 1

Background Information ......................................................................................................... 2

Current Condition.................................................................................................................... 4

Desired Future Condition ........................................................................................................ 4

Proposed Action.......................................................................................................................... 5

Decision Framework................................................................................................................... 5

Management Direction................................................................................................................ 6

Siskiyou Forest Plan................................................................................................................ 6

Port Orford Cedar FSEIS......................................................................................................... 8

GIS and Best Available Science.............................................................................................. 8

Public Involvement and Consultation ......................................................................................... 8

Issues........................................................................................................................................... 9

Key Issues................................................................................................................................ 9

Other Issues............................................................................................................................. 9

Out-of-Scope Issues............................................................................................................... 10

Chapter II. Alternatives, Including the Proposed Action .............................................................. 11

Introduction............................................................................................................................... 11

Alternatives Considered in Detail............................................................................................. 11

Alternative 1 – No Action ..................................................................................................... 11

Alternative 2 – Modified Proposed Action............................................................................ 12

Mitigation Measures and Project Design Criteria..................................................................... 37

Cultural Resources................................................................................................................. 38

Hydrology and Soils.............................................................................................................. 38

Aquatic Biota......................................................................................................................... 38

Sensitive Plants...................................................................................................................... 40

Invasive Plants....................................................................................................................... 42

Revegetation Requirements................................................................................................... 44

Port Orford Cedar.................................................................................................................. 45

Wildlife.................................................................................................................................. 46

Late-Successional Reserves................................................................................................... 48

Cultural Resources................................................................................................................. 48

Recreation.............................................................................................................................. 48

Alternatives Considered, but Eliminated from Detailed Study................................................. 48

Monitoring ................................................................................................................................ 49

Comparison of Alternatives...................................................................................................... 51

Chapter III. Affected Environment and Environmental Consequences ........................................ 53

Introduction............................................................................................................................... 53

Cumulative Effects.................................................................................................................... 53

Climate Change......................................................................................................................... 54

Introduction ........................................................................................................................... 54

Direct and Indirect Effects..................................................................................................... 55

Cumulative Effects................................................................................................................ 55

Recreation ................................................................................................................................. 55

Introduction ........................................................................................................................... 55

Affected Environment ........................................................................................................... 56

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Environmental Consequences ............................................................................................... 57

Visuals....................................................................................................................................... 57

Introduction ........................................................................................................................... 58

Affected Environment ........................................................................................................... 58

Environmental Consequences ............................................................................................... 58

Fire and Fuels............................................................................................................................ 59

Introduction ........................................................................................................................... 59

Affected Environment ........................................................................................................... 59

Environmental Consequences ............................................................................................... 60

Cultural Resources.................................................................................................................... 60

Introduction ........................................................................................................................... 60

Affected Environment ........................................................................................................... 61

Environmental Consequences ............................................................................................... 61

Alternative 1 – No Action ..................................................................................................... 61

Alternative 2 – Modified Proposed Action............................................................................ 61

Hydrology ................................................................................................................................. 62

Introduction ........................................................................................................................... 62

Affected Environment ........................................................................................................... 62

Past, Present and Future Actions........................................................................................... 65

Environmental Consequences ............................................................................................... 67

Alternative 1 – No Action ..................................................................................................... 68

Alternative 2 – Modified Proposed Action............................................................................ 70

Soil Resources........................................................................................................................... 73

Introduction ........................................................................................................................... 73

Affected Environment ........................................................................................................... 74

Past and Present Actions ....................................................................................................... 77

Environmental Consequences ............................................................................................... 78

Alternative 1 – No Action ..................................................................................................... 79

Alternative 2 – Modified Proposed Action............................................................................ 80

Sensitive Plants......................................................................................................................... 85

Introduction ........................................................................................................................... 85

Affected Environment ........................................................................................................... 85

Environmental Consequences ............................................................................................... 89

Alternative 1 – No Action ..................................................................................................... 90

Alternative 2 – Modified Proposed Action............................................................................ 90

Invasive Plants.......................................................................................................................... 93

Introduction ........................................................................................................................... 93

Affected Environment ........................................................................................................... 94

Environmental Consequences ............................................................................................... 97

Alternative 1 – No Action ..................................................................................................... 97

Alternative 2 – Modified Proposed Action............................................................................ 97

Vegetation ................................................................................................................................. 98

Introduction ........................................................................................................................... 98

Affected Environment ........................................................................................................... 98

Effects on Vegetation .......................................................................................................... 101

Environmental Consequences ............................................................................................. 107

Port Orford Cedar.................................................................................................................... 108

Introduction ......................................................................................................................... 108

Affected Environment ......................................................................................................... 108

Environmental Consequences ............................................................................................. 110

Wildlife ................................................................................................................................... 112

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Sucker Creek Legacy Roads and Trails Project

Introduction ......................................................................................................................... 112

Mitigation Measures and Project Design Criteria ............................................................... 113

ESA Consultation to Date ................................................................................................... 113

Scope of Analysis................................................................................................................ 113

Effects Common to Both Alternatives................................................................................. 115

Considerations for Cumulative Effects................................................................................ 116

Effects on Late-Successional Reserves (LSR) .................................................................... 116

Effects for Northern Spotted Owl (Federally Listed Species) and Habitat ......................... 118

Determination for Spotted Owls.......................................................................................... 122

Determination for Designated Critical Habitat.................................................................... 123

Effects on Region 6 Sensitive Species ................................................................................ 124

Effects on Management Indicator Species.......................................................................... 143

Effects for Neo-tropical Migratory Birds and Landbirds.................................................... 152

Effects to Northwest Forest Plan Species............................................................................ 155

Bat Roosts............................................................................................................................ 159

Cavity Nesting Birds........................................................................................................... 159

Aquatic Biota .......................................................................................................................... 160

Introduction ......................................................................................................................... 160

Affected Environment ......................................................................................................... 161

Environmental Consequences ............................................................................................. 165

Roads....................................................................................................................................... 172

Introduction ......................................................................................................................... 172

Affected Environment ......................................................................................................... 172

Environmental Consequences ............................................................................................. 176

Mining..................................................................................................................................... 177

Introduction ......................................................................................................................... 177

Affected Environment ......................................................................................................... 178

Effects for Mining Access................................................................................................... 178

Compliance with Other Laws, Regulations, and Executive Orders........................................ 179

Clean Air Act....................................................................................................................... 179

The Clean Water Act........................................................................................................... 179

Executive Orders................................................................................................................. 180

Energy Requirements and Conservation Potential .............................................................. 180

Environmental Justice and Civil Rights.............................................................................. 180

Short-term Uses and Long-term Productivity ..................................................................... 181

Unavoidable Adverse Effects.............................................................................................. 182

Irreversible and Irretrievable Effects................................................................................... 182

Chapter IV. Coordination ............................................................................................................ 183

Interdisciplinary Team Members............................................................................................ 183

Agencies and Persons Consulted ............................................................................................ 183

Federal, State, and Local Agencies ..................................................................................... 183

Tribes................................................................................................................................... 184

Others .................................................................................................................................. 184

References............................................................................................................................... 185

Glossary .................................................................................................................................. 200

Appendices.................................................................................................................................. 201

Appendix A – Compliance with Aquatic Conservation Strategy ........................................... 201

Appendix B – Applicable Best Management Practices .......................................................... 206

Appendix C – Revegation Plan............................................................................................... 208

Appendix D – Applicable Fish Passage Restoration Criteria ................................................. 212

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

List of Tables

Table 1. Summary of Siskiyou Forest Plan land allocations within the Sucker Creek Watershed . 7

Table 2. Potential sediment delivery (yd3

) from roads proposed for decommissioning in the 

Sucker Creek Project by alternative ...................................................................................... 25

Table 3. Potential sediment delivery (yd3

) from roads proposed for storage in the Sucker Creek 

Project by alternative............................................................................................................. 30

Table 4. Potential sediment delivery (yd3

) from roads proposed for stormproofing in the Sucker 

Creek Project by alternative .................................................................................................. 33

Table 5. Comparing the estimated key quantitative differences between alternatives.................. 51

Table 6. Current road impacts by watershed, including miles of road, road density, percent of 

road within 300 feet of streams and potential future sediment yield to stream channels...... 64

Table 7. Resulting miles of road, road density, percent of road within 300 feet of streams and 

potential future sediment yield to stream channels for alternative 2..................................... 70

Table 8. Summary of potential sediment delivery to the stream system from decommissioning and 

storage treatments.................................................................................................................. 72

Table 9. Summary of potential sediment delivery to the stream system from stormproofed roads

............................................................................................................................................... 72

Table 10. Acres of each major soil-parent material group in the Sucker Creek watershed........... 74

Table 11. Miles of road per proposed treatment on slopes at a higher risk of road-related failure.

............................................................................................................................................... 81

Table 12. Summary of some key measurement indicators for slope stability, soil productivity, and 

erosion hazard, by alternative................................................................................................ 84

Table 13. Forest Service sensitive and survey and manage plant species found within Sucker 

Creek watershed .................................................................................................................... 85

Table 14. Forest Service sensitive plant species, the road where it is located, and the proposed 

treatment for the road ............................................................................................................ 89

Table 15. Invasive plant species present in the project area.......................................................... 94

Table 16. Managed stands in the Sucker Creek Legacy Roads and Trails analysis area ............ 101

Table 17. Road segments, acres of managed stands and land allocation proposed for storage under 

alternative 2-modified proposed action ............................................................................... 102

Table 18. Road segments, acres of managed stands and land allocation proposed for 

stormproofing under alternative 2-modified proposed action ............................................. 103

Table 19. Road segments, acres of managed stands and land allocation proposed for 

decommissioning under alternative 2-modified proposed action........................................ 106

Table 20. Terrestrial wildlife special status species presence in the Sucker Creek watershed.... 114

Table 21. Acres of northern spotted owl habitat within the spotted owl analysis area and 

designated critical habitat.................................................................................................... 119

Table 22. Wildlife management indicator species and habitat in the analysis area..................... 144

Table 23. Habitat condition and attributes associated with Birds of Conservation Concern (2008) 

and Partners in Flight focal migrant species........................................................................ 153

Table 24. Survey and manage species ranging within the Sucker Creek Legacy Roads project area

............................................................................................................................................. 156

Table 25. Fish species and presence within Sucker Creek 5th field watershed .......................... 163

Table 26. Proximity of project elements to critical habitat within Sucker Creek 5th field 

watershed............................................................................................................................. 165

Table 27. Comparison of effects to aquatic biota for each alternative by activity type .............. 170

Table 28. Summary of Conclusion of Effects for TES................................................................ 172

Table 29. The “backbone” system roads in Sucker Creek watershed ......................................... 175

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Sucker Creek Legacy Roads and Trails Project

List of Figures

Figure 1. Sucker Creek watershed vicinity map.............................................................................. 2

Figure 2. Siskiyou Forest Plan land allocations within the Sucker Creek watershed...................... 7

Figure 3. Alternative 2-modified proposed action: Treatments proposed for Grayback Creek 

Subwatershed......................................................................................................................... 17

Figure 4. Alternative 2-modified proposed action: Treatments proposed for Lower Sucker Creek 

Subwatershed......................................................................................................................... 19

Figure 5. Alternative 2-modified proposed action: Treatments proposed for Middle Sucker Creek 

Subwatershed......................................................................................................................... 21

Figure 6. Alternative 2-modified proposed action: Treatments proposed for Upper Sucker Creek 

Subwatershed......................................................................................................................... 23

Figure 7. Soils by major parent material ....................................................................................... 75

Figure 8. Soil depths in the Sucker Creek watershed.................................................................... 76

Figure 9. Erosion hazard rating in the Sucker Creek watershed.................................................... 76

Figure 10. Location of Forest Service sensitive plants in the Sucker Creek Project area ............. 86

Figure 11. Locations of invasive plants found in the Sucker Creek Legacy Roads Project area .. 96

Figure 12. Land and Resource Management (1989) direction as amended by the Northwest Forest 

Plan (1994) for the Sucker Creek Legacy Roads and Trails analysis area.......................... 100

Figure 13. Phytophthora lateralis Infested and uninfested sites in the analysis area.................. 109

Figure 14. Fish distribution in the Sucker Creek watershed........................................................ 162

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Sucker Creek Legacy Roads and Trails Project

vi
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Chapter I. Purpose and Need for Action

Introduction 

We are proposing to restore watershed health, fisheries and wildlife habitat in the Sucker Creek 

watershed. by: (1) stormproofing 118 miles of road; (2) decommissioning 28 miles of road; (3) 

putting 31 miles of road into storage; and (4) converting 3 miles of road to non-motorized trail 

(table 2, table 3 and table 4) on National Forest System (NFS) lands in the Wild Rivers Ranger 

District of the Rogue River-Siskiyou National Forest. 

We prepared this environmental assessment to determine whether effects of the above proposed 

activities may be significant enough to prepare an environmental impact statement. By 

preparing this environmental assessment, we are fulfilling agency policy and direction to 

comply with the National Environmental Policy Act (NEPA) and other relevant federal and 

state laws and regulations. The project is intended to implement the forest’s land management 

plan and is subject to the objection process specified in 36 CFR §218, subparts A and B. For 

more details of the modified proposed action, see chapter 2, alternative 2-modified proposed 

action section beginning on page 12.

Purpose and Need for the Proposal 

The purpose of the Sucker Creek Legacy Roads and Trails project is to reduce the risk of

sediment delivery to streams in the 5th field Sucker Creek watershed from National Forest System

roads that cannot be maintained because of the lack of maintenance funding, while retaining

roads needed for management, special uses, recreation, fire suppression, and other emergency

needs. The need for the project is to restore watershed health and fisheries and wildlife habitat in

the Sucker Creek watershed.

Location of the Proposed Project Area

The Sucker Creek Legacy Roads and Trails Project targets roads throughout the Sucker Creek

watershed. The proposed project is located in Josephine County in Oregon, approximately 16 

river miles (on Sucker Creek) upstream of Cave Junction, Oregon. The legal description of the 

project area includes roads and trails in Township 39 South, Range 6 West, T. 39 S. R. 5 W., T. 40 

S., R. 6 W., T. 40 S., R. 5 W., and T. 41 S., R. 6 W., of the Willamette Meridian. Grayback, Lower

Sucker, Middle Sucker, and Upper Sucker are 6th field hydrologic unit subwatersheds located 

within the Sucker Creek 5th field watershed (61,515 acres) (figure 1), which in turn, makes up 10 

percent of the 628,000 acre Illinois River subbasin of the Rogue River Basin. The Illinois River

subbasin makes up 20 percent of the 3.3 million acre Rogue River Basin. Sucker Creek flows into

the East Fork Illinois River and then the Illinois River before proceeding to the Pacific Ocean via 

the Rogue River. This watershed is located within the Klamath Mountains Province of

southwestern Oregon (USDA Forest Service 2011).

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Sucker Creek Legacy Roads and Trails Project

Figure 1. Sucker Creek watershed vicinity map

Background Information

While roads often provide important access and transportation, their presence can also influence 

the habitat quality, hydrology, geomorphology, and ecosystem processes of watersheds. Roads 

can substantially alter hillslope hydrology, overland flow can cause geomorphic changes, 

including chronic erosion, extended channel systems, and increased risk of landslides. Roads also 

influence the ecology of terrestrial and aquatic ecosystems through direct habitat loss, 

fragmentation, and associated human impacts as a result of increased access.

Aquatic systems are primarily affected by roads through the associated increase in peak stream 

flows, interception of overland flow, and addition of sediment from road surfaces. Increases in 

flow as a result of roads can cause stream bank cutting and channel destabilization. Too much 

sediment can embed fish spawning gravels and suffocate developing fish eggs that are laid there. 

The primary mechanism for the transfer of sediment is from culverts plugging at stream crossings 

(Siskiyou NF Storm Assessment 1998). Fill failures at stream crossings, and the subsequent 

landslide associated with it, can contribute substantial amounts of sediment to streams. It can take 

decades for this material to be flushed out of the channel through normal stream flows.

Roads also cause negative impacts to terrestrial habitat and wildlife including displacement or 

avoidance where animals alter their use of habitats (Gaines et al. 2003). Disturbance at a specific 

site is common and includes disruption of animal nesting, breeding, or wintering areas. Collisions 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

between animals and vehicles occur to a variety of species from large mammals to amphibians. 

Finally, edge effects associated with roads or road networks constructed within habitats, 

especially late-successional forests, lead to lower habitat quality and increased predation and 

competition.

Road decommissioning activities have been in the forefront for watershed restoration projects 

over the last decade. Monitoring has shown it to be effective at reducing surface erosion and mass 

failure risk while increasing water infiltration rates and vegetative ground cover (e.g. Foltz et al. 

2007; Cook and Dresser 2007). It can also have positive effects on wildlife from a reduction in 

habitat fragmentation and human disturbance (Switalski et al. 2007).

Currently, the Sucker Creek watershed contains approximately 200 miles of road with an average 

road density of 3.4 miles per square mile. National Forest System roads were engineered and built 

to allow for long-term use. Metal culverts were installed at stream crossings. Main haul routes 

had gravel surfaces and lesser used routes were either graveled or had a native (dirt) surface. The 

costs associated with maintaining the road system at current maintenance levels has become 

impractical under current funding levels, creating a large backlog of road maintenance and 

improvements. The Forest Service is currently able to maintain 20 percent or less of National 

Forest System roads each year.

The Sucker Creek watershed is located in the Rogue River Basin within the Southern Oregon 

Coastal Basin, which has been identified by the Forest Service in the Pacific Northwest Region as 

one of the three priority basins for watershed restoration. The Illinois River subbasin is identified 

as a focal basin and salmon stronghold by the nonprofit Wild Salmon Center. This stream 

contains some of the highest quality freshwater and fish habitat in the Illinois River subbasin. 

Sucker Creek is designated as a key watershed in the Northwest Forest Plan in recognition of the 

anadromous fish populations (fall Chinook salmon, coho salmon, winter steelhead, and Pacific 

lamprey). Coho salmon and its critical habitat within the Sucker Creek watershed are listed as 

Threatened under the Endangered Species Act. The upper Illinois River tributaries, including 

Sucker Creek, produce about 33 percent of the wild coho salmon in the entire Rogue basin. The 

Sucker Creek watershed has been identified as one of the top three priority watersheds on the 

Rogue River-Siskiyou National Forest for watershed restoration since 2006.

Additionally, in 2011, Grayback Creek and Middle Sucker Creek were identified as priority 

watersheds as part of the National Watershed Condition Framework (WCF), which is a 

comprehensive approach for proactively implementing integrated restoration on priority 

watersheds on national forests and grasslands. A Watershed Restoration Action Plan (WRAP) was 

completed for the Sucker Creek watershed in 2011, updating the 2007 WRAP for the watershed. 

The 2007 and 2011 WRAPs provide greater detail to the 1995 Grayback/Sucker Watershed 

Analysis by adjusting and adding essential projects to improve the subwatershed condition class, 

which addresses an outcome-based performance measure of progress toward restoring the 

productivity and resilience of watersheds and their associated aquatic systems on NFS lands.

Most of the watershed contains lands managed by the Rogue River-Siskiyou National Forest 

(71.7 percent) with primary Forest Service ownership on Grayback Creek (81.9 percent), Middle 

Sucker (80 percent), and Upper Sucker (99.9 percent). See figure 3, figure 5, and figure 6

respectively. A large portion of Grayback Creek, Middle Sucker Creek and Upper Sucker Creek 

subwatersheds are within the transient snow zone with narrow stream valleys and steep side 

slopes. The lower subwatershed—Lower Sucker Creek—has considerable private ownership 

(48.7 percent) within an unconfined valley setting with wide floodplains and some steeper 

dissected landscapes under public and private ownership (figure 4). Streamflows vary

3
Sucker Creek Legacy Roads and Trails Project

considerably from summer to winter and snowpack in upper Sucker Creek prolongs summer 

stream flows longer than most other watersheds in the Illinois River subbasin (USDA Forest 

Service 2011).

The watershed was a prime location for timber harvest from productive conifer forests on both 

public and private lands after World War II. The private lands downstream of public lands are 

primarily under agricultural use with some private timberlands on the surrounding hillslopes. The 

upper and middle subwatersheds have a long history of placer gold mining on public lands 

principally in the Sucker Creek stream channel and on the floodplain. Mining, agriculture, timber 

harvest and recreation have had a dramatic impact on the watershed since its settlement (by nonIndian people) in the mid-1800s. Conflicts between different uses and values continue, despite 

many efforts (USDA Forest Service 1995).

Current Condition

Fine sediment is prevalent in cobble interspace habitat in many stream reaches causing channel 

widening, water quality impairment and aquatic habitat simplification – particularly Grayback 

Creek and the depositional reaches of Sucker Creek. The road system contributes to habitat 

degradation from fine sediment in several ways: road-related slope failures, chronic sediment 

delivery, plugged culverts, and other road drainage problems are identified in the 1998 Siskiyou 

NF Flood Assessment and 2007 WRAP. Peak flows may also be affected by extension of the 

channel network by in-sloped roads and their accompanying ditches.

There are approximately 200 miles of road on National Forest System land within the Sucker 

Creek Watershed. Approximately 9 percent of all roads are within 100 feet of perennial streams, 

while 5 percent of all roads are within 100 feet of perennial fish bearing streams. In addition, 

there are 261 road crossings on perennial streams, and 26 road crossings on perennial fish bearing 

streams. The average road density (total road length for a given area) in the watershed is 3.4 miles 

per square mile, which is generally considered to be at moderate risk levels for generating 

cumulative watershed effects (USDA Forest Service 1995, 1998).

Roads in the riparian area have caused adverse impacts to salmonid habitat and production and 

water quality. Some culverts on Forest Service land are total fish barriers, although the amount of 

fish habitat above them is generally insignificant as the streams are steep and small (USDA Forest 

Service 2007).

The Upper Sucker Creek subwatershed is currently ranked as having a “functioning properly” 

condition class by Watershed Condition Framework model standards. Whereas, Grayback, Lower 

Sucker Creek and Middle Sucker Creek subwatersheds are currently ranked as having a 

“functioning at risk” condition class.

Desired Future Condition

Controlled drainage, stormproofing, or revegetation for closed roads maintained for future land 

management activities, and closed or decommissioned roads that are not needed for current or 

projected resource management. Priority work should focus on roads located in areas with erosive 

soils or where delivery of fine sediment can impact the fishery and water quality (USDA Forest 

4
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Service 2011). The target condition class for all subwatersheds in the Sucker Creek watershed is 

the “functioning properly” condition class1

.

The Northwest Forest Plan (USDI Bureau of Land Management and USDA Forest Service 1994) 

states that the objective of late-successional reserves is to protect and enhance conditions of latesuccessional and old-growth forest ecosystems. The plan also identified and directs the reduction 

of existing roads within key watersheds through the decommissioning of roads (page B-19) to 

contribute to the conservation of salmon species. Tier 1 key watersheds were designated because 

they contribute directly to conservation of at-risk fish species and to ensure refugia are well 

distributed.

The 1995 Grayback/Sucker Pilot Watershed Analysis (WA) identified a number of desired 

objectives for the watershed, which include (USDA Forest Service 1995, pages 4 to 7):

♦ Maintain and restore water quality (i.e., low turbidity and the sediment regime) by 

reducing rill and gully erosion from road drainage interceptions.

♦ Maintain and restore instream flows, protect timing, magnitude, duration, and distribution 

of peak, high, and low flows.

♦ Maintain and restore large wood delivery processes and sediment regime.

Proposed Action

Comments received during the scoping period led to several modifications to the proposed action, 

which led the responsible official to decide to analyze one action alternative. The modifications to 

the proposed action that was scoped to the public are discussed in chapter 2, alternative 2. The 

acres for the subsequent modified proposed action are presented here.

In response to the needs for action discussed in the sections above, this project would:

♦ Stormproof 118 miles of Forest Service System roads

♦ Decommission 28 miles of Forest Service System roads

♦ Put 31 miles of Forest Service System roads into storage

♦ Convert 3 miles of Forest Service System roads into non-motorized trails

Decision Framework

Given the purpose and need, the deciding official for this project reviews the modified proposed 

action and the other alternative in order to make the following decisions: 

♦ to implement the alternative as proposed

♦ to select and modify the alternative

♦ to take no action at this time

The decision will be based on: 

♦ how well the selected alternative achieves the purpose and need

1 See the aquatic biota section in chapter 3 for description of functioning properly condition class and tier 1 

key watersheds.

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Sucker Creek Legacy Roads and Trails Project

♦ how well the selected alternative protects the environment and addresses issues and 

concerns

♦ how well the selected alternative complies with relevant policies, laws and regulations

Management Direction

This Environmental Assessment tiers to the Siskiyou National Forest Land and Resource 

Management Plan Final Environmental Impact Statement and Record of Decision (1989), as 

amended by the Final Environmental Impact Statement and Record of Decision for Amendments 

to Forest Service and Bureau of Land Management Planning Documents Within the Range of the 

Northern Spotted Owl and the Standards and Guidelines for Management of Habitat for LateSuccessional and Old-Growth Forest Related Species Within the Range of the Northern Spotted 

Owl (Northwest Forest Plan) (1994), and incorporates by reference the accompanying Siskiyou 

National Forest Land and Resource Management Plan (Siskiyou Forest Plan) (1989). When 

direction is inconsistent, the most restrictive direction applies.

Siskiyou Forest Plan

The Siskiyou Forest Plan (1989) established land management allocations for the Sucker Creek 

Legacy Roads and Trails project area (table 1 and figure 2). The standards and guidelines of the 

Siskiyou Forest Plan (1994) apply where they are more restrictive or provide greater benefits to 

late-successional forest-related species than do those identified in the Northwest Forest Plan. 

Actual decommissioning and stormproofing activities would occur on roadways within the 

project area for which the following designations have been made:

♦ East IV/Williams-Deer Late-Successional Reserve (LSR) – The Northwest Forest Plan 

set objectives for LSRs to protect and enhance conditions of late-successional and oldgrowth forest ecosystems, which serve as habitat for late-successional and old-growth 

forest species, including the northern spotted owl. Late-successional reserve is the largest 

land allocation within the Sucker Creek Watershed, covering approximately 26,286 acres.

♦ Matrix/General Forest, Retention Visual, and Partial Retention Visual – The Matrix 

is where most timber harvest and other silvicultural activities would be conducted under 

the Northwest Forest Plan. The Forest Plan goals for this allocation are to provide for 

long-term growth and production of commercially valuable wood products. Matrix 

covers approximately 6,250 acres of the Sucker Creek Watershed.

♦ Congressionally Reserved Areas/Red Buttes Wilderness – Congressionally Reserved 

Areas include lands that have been reserved by act of Congress for a specific purpose. A 

portion of the Red Buttes Wilderness, totaling approximately 2,831 acres, is located 

within the Sucker Creek Watershed.

♦ Administratively Withdrawn Areas – Administratively Withdrawn Areas identified in 

current Forest Plans, and within the Sucker Creek watershed include: Bigelow Lakes 

(proposed) Botanical Area, Bolan Lake (proposed) Botanical Area, Grayback Mountain 

(proposed) Botanical Area, Craggy Peak (proposed) Research Natural Area, several 

backcountry recreation areas, and numerous special wildlife sites. These areas cover 

3,469 acres of the Sucker Creek Watershed.

♦ Riparian Reserves/Riparian – The purpose of these areas along streams, ponds, and 

other wetted areas, is to protect the health of the aquatic system and its dependent 

species. Riparian-dependent resources receive primary emphasis in these areas. Riparian 

Reserves vary in width from 100 to 300 feet on each side of a stream, pond, or wetted 

6
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

area depending on the feature’s particular characteristics. These allocations overlay the 

designations mapped in figure 2.

Table 1. Summary of Siskiyou Forest Plan land allocations within the Sucker Creek Watershed

Land Allocations in the Sucker Creek Watershed Total Acres

East IV/Williams-Deer Late-Successional Reserve 26,290

Matrix/General Forest, Retention Visual, and Partial Retention Visual 6,250 

Congressionally Reserved Areas/Red Buttes Wilderness 2,830

Administratively Withdrawn Areas 3,470

Riparian Reserve/Riparian 2,770

Figure 2. Siskiyou Forest Plan land allocations within the Sucker Creek watershed

7
Sucker Creek Legacy Roads and Trails Project

Additional guidance for the Sucker Creek watershed is provided by the Grayback/Sucker 

Watershed Assessment (USDA Forest Service 1995, 1998), Sucker Creek Watershed Restoration 

Action Plan (USDA Forest Service 2011), and Southwest Oregon Late-Successional Reserve 

Assessment (USDA Forest Service 1995, 2004).

Port Orford Cedar FSEIS

The 2004 Port Orford cedar Final Supplemental Environmental Impact Statement (FSEIS) for the 

Management of Port Orford cedar in Southwest Oregon and the accompanying Record of 

Decision amended the 1989 Siskiyou Forest Plan. The FSEIS produced a risk key to determine 

the environmental conditions that require implementation of one or more disease-control 

treatments. The key also requires management to reduce appreciable additional risk to uninfested 

7th field watersheds.

GIS and Best Available Science

The Forest Service uses the most current and complete data available. Geographic information 

system (GIS) data and product accuracy may vary. They may be developed from sources of 

differing accuracy, accurate only at certain scales based on modeling or interpretation, incomplete 

while being created or revised, etc. Using GIS products for purposes other than those, for which 

they were created, may yield inaccurate or misleading results. The Forest Service reserves the 

right to correct, update, modify, or replace, GIS products without notification. 

The best available science is considered in the preparation of this EA. However, what constitutes 

best available science might vary over time and across scientific disciplines as new science is 

brought into play. We show consideration of best available science when we insure the scientific 

integrity of the discussions and analyses in the project NEPA document. Specifically, this EA and 

the accompanying project record identifies methods used, references reliable scientific sources, 

discusses responsible opposing views, and discloses incomplete and unavailable information, 

scientific uncertainty and risk (40 CFR 1502.9 (b), 1502.22, 1502.24). The project record 

references all scientific information considered: papers, reports, literature reviews, review 

citations, academic peer reviews, science consistency reviews, and results of ground-based 

observations to validate best available science. 

Public Involvement and Consultation

The proposal was first published in the Schedule of Proposed Actions (SOPA), which is available 

for public viewing on the Forest website, on October 1, 2010. The proposed action was mailed to 

the public and other agencies that have an interest in the project on September 20, 2013, for 

comment. A legal notice to initiate scoping was published on October 1, 2013 in the Grants Pass 

Courier. A total of 15 responses were received before or shortly after the public scoping period

ended.

Separate government-to-government consultation was initiated with the Confederated Tribes of 

the Grand Ronde Community of Oregon and the Confederated Tribes of the Siletz. Letters were

sent September 3, 2013. No specific concerns regarding project impacts on resources of tribal 

interest were identified.

A cultural resource inventory report was completed and submitted to the Oregon State Historic 

Preservation Office under the Programmatic Agreement among the United States Department of 

Agriculture Forest Service Pacific Northwest Region (Region 6), the Advisory Council on 

Historic Preservation, and the Oregon State Historic Preservation Officer Regarding Cultural 

8
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Resource Management in the State of Oregon by the USDA Forest Service (R6 PA), 2004. This 

report found no cultural resources.

Because this project fits under the categories described in the Re-initiation of the Endangered 

Species Act Section 7 Formal Programmatic Conference and Biological Opinion, and MagnusonStevens Fishery Conservation and Management Act Essential Fish Habitat Consultation for 

Aquatic Restoration Activities in the States of Oregon and Washington (2013 ARBO) for category 

#12. Road and Trail Erosion Control and Decommissioning, no formal consultation with the 

National Marine Fisheries Service is required provided the project design criteria (chapter 2) are 

followed.

Issues

The NEPA requires Federal agencies to focus analysis and documentation on the important issues 

related to a proposed action. Analysis was completed for recreation, visuals, fire and fuels, 

cultural resources, hydrology, soils, sensitive plants, invasive plants, vegetation, Port Orford

cedar, wildlife, aquatic biota, roads and mining. Information from these reports has been 

summarized in chapter 3. Separate biological evaluations were completed for terrestrial wildlife 

species and aquatic species for this analysis and are available in appendices C and D respectively.

The following issues have been identified associated with the proposed action.

Key Issues

Issues are defined in this environmental analysis as points of discussion, debate, or dispute about 

the environmental effects of a proposal. Key issues as used in this environmental analysis are 

those used to evaluate alternatives, affect the design of component proposals, prescribe mitigation 

measures, and/or describe important and variable environmental effects. They are ‘key’ because 

of the extent of their geographic consequence, the duration of the effects, or the intensity of 

interest or resource conflict.

NEPA requires Federal agencies to focus analysis and documentation on the key issues related to 

the proposed action. The interdisciplinary team (IDT), with Responsible Official involvement and 

approval, has identified the following as key issues associated with the proposed action presented 

in this analysis. These represent both public and internal issues. 

1. Impacts to fish and water quality from sediment delivery to streams – Implementing 

recommendations to decommission and hydrologically stabilize the proposed road 

segments could reduce detrimental sediment sources and restore hydrologic function to 

many areas of the Sucker Creek watershed while lessening the risks to aquatic habitat and 

fisheries in these areas (especially the ESA listed Coho salmon).

2. Change in access – Issues with access for mining, recreation, hunting, and wildland fire 

escape routes were raised during scoping. Mineral claimants utilize road access to their 

claims for prospecting and mining operations. Decommissioning these open or closed 

roads could restrict access to these areas by making them impassable to vehicles.

Other Issues

Other issues as used in this environmental analysis are those that have been determined to be 

relevant, are used to disclose consequences, may affect design of component actions, may 

prescribe mitigation measures, or whose disclosure of environmental effects are required by law 

9
Sucker Creek Legacy Roads and Trails Project

or policy. Other Issues differ from key issues in that they often describe minor and/or nonvariable consequences.

This list is limited to those issues that specifically identify potential effects that may result from 

implementation of elements of the modified proposed action; their corresponding effects are 

documented in the EA. These represent both public and internal issues. 

1. Soil Resources

2. Fire Risk

3. Terrestrial Wildlife

4. Port Orford cedar Root Disease

5. Botanical Resources

6. Non-native Plants

7. Visuals

8. Cultural Resources

9. Recreation/Human Safety

10. Wilderness

11. Climate Change

Out-of-Scope Issues

Out-of-scope issues include points of discussion that are not relevant to the proposed action, 

including those that cannot be addressed with a project level analysis, issues already decided by 

law, regulation, or other higher level decisions, and/or issues received from the public that were 

found to be conjectural or non-substantive. Out-of-scope issues are contained in the analysis file 

(generally in the analysis of public comment) and are not discussed further in this document.

♦ Decommission unauthorized mining routes and roads along Sucker Creek –

Decommissioning unauthorized mining routes is outside the scope of this analysis 

because the Federal funds designated to design and implement this project are 

specifically for legacy road and trail projects. This effort would need to be undertaken

under a separate NEPA effort.

10
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Chapter II. Alternatives, Including the Proposed 

Action

Introduction

This chapter describes the process used to develop alternatives for the Sucker Creek Legacy 

Roads and Trails Project, including a description and map of the modified proposed action. This 

chapter also presents the alternatives in comparative form, defining the differences between each 

and providing a clear basis for choice among options for the decision maker.

Alternatives Considered in Detail

Two alternatives, alternative 1 (no-action) and alternative 2 (modified proposed action) were fully 

developed and are described in this section. The analyses of their effects are disclosed in chapter 

III. Actions included under alternative 2 are designed to address the issues identified by the ID 

team and incorporate the standards and guidelines established by the Siskiyou Forest Plan (1989), 

as amended by the Northwest Forest Plan (1994). All quantities illustrated for the alternatives in 

this environmental assessment and its appendices are estimates.

Alternative 1 – No Action

Function

The no-action alternative is required by the Council on Environmental Quality (CEQ) regulations 

(40 CFR 1502.14(d)). The no-action alternative provides a basis for evaluating environmental 

effects and comparisons with the proposed action. It provides information on components of the 

environment that may be affected by the proposed action. It also provides information about how 

the absence of an action may affect the environment. This alternative does not meet the purpose 

and need for the project.

Description

Under the no-action alternative, none of the proposed actions would occur and the road system in 

the Sucker Creek watershed would remain relatively unchanged. However, some resource 

management activities with implications for the road system are ongoing within the watershed, 

and current management plans would continue to guide management of the road system. The 

ongoing situation includes:

Current access would remain relatively unchanged with closed roads (roads that are bermed, 

gated, or overgrown) continuing to be inaccessible to motor vehicles and experiencing very little, 

if any, use for public or administrative needs. Roads that are currently open would remain open 

and available for access.

Current road restrictions are likely to change as a result of other management directives. Roads 

that are currently closed to motor vehicles would remain closed. Most roads that are currently 

open would likely remain open; but some open roads would be closed to motor vehicle use in the 

future due to travel planning currently in progress across the Rogue River-Siskiyou National 

Forest. Some decommissioning would likely occur in association with future projects, but at a 

smaller scale.

11
Sucker Creek Legacy Roads and Trails Project

Current road maintenance is minimal and would remain so. Closed roads that are not open to 

motorized use have been put into a maintenance-free condition (waterbars for drainage, seeded 

with grass). Open roads receive the appropriate level of maintenance for use as needed and as 

funds are available.

Current risks and impacts to natural resources would continue. Roads would continue to 

increase the risk of uncontrolled water runoff, surface erosion, fill failures, and decreased slope 

stability. Leaving undersized culverts in place would increase the potential for future road 

failures. Road segments fragmented by failures would be difficult to decommission as access 

would be reduced (i.e. reaching the far end of a road with failures might not be possible). The noaction alternative has a higher risk of road failures and impacts to aquatic resources through 

sediment input than the proposed action.

Alternative 2 – Modified Proposed Action

Function

Under this alternative, the Forest Service would meet the project purpose and need by 

implementing the actions and treatments described and visually displayed (figure 3, figure 4, 

figure 5 and figure 6) in this section.

Description

Alternative 2 was developed through an interdisciplinary process. A team of resource specialists 

reviewed every road segment on National Forest System land in the Sucker Creek watershed to 

identify segments that would benefit the most from road treatment (e.g., to reduce sediment 

inputs into streams supporting Coho salmon), and segments to be maintained for access (e.g., for 

land management, emergency access, and recreation).

When there are no unresolved conflicts concerning alternative uses of available resources (NEPA, 

section 102(22) (E)), the EA need only analyze the proposed action and proceed without 

consideration of additional alternatives. (36 CFR 220.7(b)(2)(i)). Comments received during the 

scoping period led to several modifications to the proposed action, which led the responsible 

official to decide to analyze one action alternative. The modifications to the proposed action that 

was scoped to the public are:

Modifications to the Proposed Action

♦ Modify 4600 from stormproof to no treatment – This road is under the jurisdiction of 

the Federal Highways Administration and was mistakenly included in the proposed action 

sent to the public during scoping.

♦ Modify FS Road 4611-042 from decommissioning to no treatment – This road was 

initially proposed for decommissioning. However, further review of the US Forest 

Service’s i-web database found that this road segment was already decommissioned 

around the year 2000.

♦ Modify FS Road 4611-964 from decommissioning to storage – This road was initially 

proposed for road decommissioning to reduce road density for wildlife benefits; this road 

does not have the issue of sediment delivery to streams. However, during scoping a 

commenter noted that this road segment is used to access a waterline for the Oregon 

Caves National Monument. Accordingly, alternative 2 was modified to put this road into 

storage to maintain access for future management needs by the National Park Service.

12
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

♦ Modify FS Road 4612-058 from decommissioning to stormproofing – This road was 

initially proposed for road decommissioning to reduce road density for wildlife benefits; 

this road does not have the issue of sediment delivery to streams. During scoping several 

commenters noted that this road accesses several mining claims. Accordingly, alternative 

2 was modified to stormproofing to maintain access to these mining claims.

♦ Modify a portion of FS Road 4612-069 from decommissioning to stormproofing –

This road was proposed for road decommissioning to reduce sediment delivery to 

streams; there are several culverts on the road that are problematic. Several commenters 

brought forward the information that the road is used by miners, hikers, and hunters. The 

first 0.25 miles is used to park cars and for camping. So, alternative 2 was modified to 

stormproof the first 0.25 miles of the road (to Sucker Creek), and then decommission the 

remainder of the road; the first 0.25 miles of FS Road 4612-069 does not have issues with 

sediment delivery to nearby streams.

♦ Modify a portion of FS Road 4612-080 from decommissioning and constructing a 

new route, to stormproofing – Initially 1.32 miles of this road was proposed for 

decommissioning, along with constructing a new 1.25-mile route to reduce sediment 

delivery issues from multiple stream crossings. This road is needed to access Matrix land 

and provide access for fire suppression. During scoping, several commenters brought up 

concerns both with constructing a new route and losing access for recreation into this 

area. Members of the ID team went on a fieldtrip to view the new proposed route and 

determined that constructing would not be feasible due to the terrain in the area and 

number of large trees that would need to be removed. Therefore, alternative 2 was 

modified to drop the proposal to construct a new route and decommission a portion of the 

road; FS Road 4612-080 is proposed for stormproofing only.

♦ Modify FS Road 4612-465 from no treatment to decommissioning – This road 

segment was initially overlooked for treatment in error. This road would lose access when 

FS Road 4612-069 is decommissioned as part of alternative 2; this road segment is now 

also being proposed for decommissioning.

♦ Modify FS Road 4703-429 from decommissioning to no treatment – This road 

segment is being dropped from treatment as part of this project because it is located 

outside of the Sucker Creek watershed boundary; it was mistakenly included in the 

proposed action sent to the public during scoping.

♦ Modify FS Road 4703-440 from decommissioning to storage – This road segment was 

initially proposed for decommissioning to reduce sediment delivery to streams and to 

reduce road density for wildlife. During scoping a commenter brought up a concern that 

this road is used to access several mining claims and for recreation by hunters. This road 

segment was modified from decommissioning to storage to maintain access to this area.

♦ Modify FS Road 4703-458 decommissioning to stormproofing – This road was 

initially proposed for road decommissioning to reduce road density for wildlife benefits; 

this road does not have the issue of sediment delivery to streams. During scoping a 

commenter brought up a concern that this road is used to access several mining claims. 

Therefore, alternative 2 was modified to stormproofing to maintain access to these 

mining claims.

The modified proposed action would meet the purpose and need by: (1) stormproofing 118 miles 

of road; (2) decommissioning 28 miles of road; (3) putting 31 miles of road into storage; and (4) 

converting 3 miles of road to non-motorized trail (table 2, table 3, and table 4). The treatment 

elements are defined below.

13
Sucker Creek Legacy Roads and Trails Project

Stormproofing

Roads to be stormproofed are currently needed and needed into the future. Stormproofing 

activities are a part of road maintenance and consist of improving road drainage to protect the 

road surface and upgrading stream crossings to reduce the risk of sediment delivery to stream 

channels during storm events. Six culverts that are currently barriers to aquatic passage would be 

a high priority for replacement. Stormproofing work may entail any or all of the following 

treatments:

♦ Apply rock aggregate or paving to the road surface where necessary

♦ Add rolling dips where feasible

♦ Upgrade stream crossing culverts to withstand 100-year peak flows and/or debris flows

♦ Construct dips at stream crossing that have a diversion potential

♦ Install downspouts

♦ Add ditch relief culverts

♦ Improve ditch line

♦ Fill in road ditch and outslope roads where feasible

♦ Where the ditch is hydrologic connect to a stream install a cross-drain to prevent ditch 

water from entering a stream channel

♦ Provide fish passage

Road Decommissioning

Road decommissioning is the physical treatment of a roadbed to restore the integrity of associated 

hillslopes, channels, and flood plains and their related hydrologic, geomorphic, and ecological 

processes and properties. Two levels of road decommissioning are proposed. “Level a” treatments 

would be more intensive and occur on any road with a road stream crossing. Treatment would 

include culvert removal, outsloping, scarification, and revegetation of all or part of the road 

segment. There are approximately 28 culverts on live streams that are proposed for removal under 

these treatments. “Level b” treatments would be less intensive and occur on roads with no stream 

crossings and few if any ditch drainage culverts. This treatment would only occur on part of the 

road segment. The road would be closed to motor vehicles either using barricades or 

recontouring. Waterbar installation and ditch drainage culvert removal would also occur. 

The objectives of road decommissioning include:

♦ Reducing the risk of mass failures and subsequent impact on streams

♦ Protecting fish and fish habitat

♦ Restoring natural surface and subsurface drainage patterns

♦ Restoring vegetation and site productivity

♦ Restoring stream channels at road crossings

♦ Increasing road maintenance cost-effectiveness by concentrating available funds on roads 

needed for long-term access

♦ Restoring terrestrial habitat that has been invaded by vehicles and other human activities

The primary goals of road decommissioning are to restore natural drainage patterns and 

infiltration capacity. Decommissioning a road involves one or more of the following restorative 

actions, dependent upon site-specific evaluations and recommendations of resource specialists:

14
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

♦ Removing drainage structures including culverts and bridges

♦ Pulling back stream banks to natural channel slope

♦ Restoring out-slopes for drainage by placing waste on sub-grade to reestablish original 

ground lines

♦ Outsloping roads by pulling sub-grade material back toward the hillslope

♦ Constructing cross-drains and waterbars

♦ Scattering woody debris on road travel ways

♦ Subsoiling and/or ripping compacted road travel ways

♦ Seeding and/or planting road travel ways with native seed and vegetation (conifers, 

hardwoods, shrubs)

♦ Blocking road entrances with barriers

Decommissioned roads are removed from the Forest transportation system once restorative 

actions have been implemented and closing barriers installed.

Storage

Roads that were identified as needed for reasonably foreseeable future resource management 

activities would be closed to vehicular traffic until needed, and changed in the Forest Service 

transportation system to custodial maintenance “level 1.” These roads would be closed for periods 

of 1 year or more.

Objectives for Level 1 closed roads are to eliminate traffic and minimize resource impacts. Road 

surface deterioration may occur at this level. Management emphasis for these roads is on 

maintaining drainage facilities and runoff patterns. The treatment on these roads would include 

the removal of high risk road stream crossings with the culverts stored on-site for easy installation 

if the road is reopened, construction of cross drains, and blocking the road entrance with a barrier. 

There are approximately 44 culverts on live streams which are proposed for removal due to the 

high sediment yield and high plug potential associated with them. Ditch drainage culverts and 

low risk culverts on stream crossings would be left in place for future road use.

Closing roads under Level 1 custodial maintenance involves one or more of the following actions, 

dependent upon site specific evaluations and recommendations of resource specialists:

♦ Construct a dip in the fill at road stream crossings

♦ Fills and culverts would be removed and stored at the site for culvert stream crossing 

identified as having a high potential to fail and impact anadromous fish habitat and water 

quality

♦ Sub-soiling or ripping a portion of the compacted road travel way

♦ Constructing a series of cross-drains and or waterbars

♦ Blocking the road entrance with a barrier

Conversion of Road to Trail

Several roads in the watershed were identified in the interdisciplinary process as not needed and 

proposed for decommissioning with part of the road template converted into a non-motorized trail 

to expand the existing trail system.

Conversion of a road to a non-motorized trail would involve the removal or replacement of all 

culverts, blocking the road entrance to motorized vehicles, installation of cross drains, and ripping 

15
Sucker Creek Legacy Roads and Trails Project

of some of the road surface where needed to improve revegetation and narrow the road prism. 

There are approximately 24 culverts on live streams that would be removed.

16
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Figure 3. Alternative 2-modified proposed action: Treatments proposed for Grayback Creek Subwatershed

17

Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Figure 4. Alternative 2-modified proposed action: Treatments proposed for Lower Sucker Creek Subwatershed

19

Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Figure 5. Alternative 2-modified proposed action: Treatments proposed for Middle Sucker Creek Subwatershed

21

Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Figure 6. Alternative 2-modified proposed action: Treatments proposed for Upper Sucker Creek Subwatershed

23

Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Table 2. Potential sediment delivery (yd3) from roads proposed for decommissioning in the Sucker Creek Project by alternative

Road 

number

Road 

miles

Proposed 

treatment

Alternative 1 Alternative 2

Potential 

sediment 

delivery from 

culvert failures 

before treatment 

(yds3

)

Potential 

sediment 

delivery from 

other sediment 

sources before 

treatment (yds3)

Total 

potential 

sediment 

yield before 

treatments

(yds3

)

Number of 

culverts 

proposed for 

removal

Potential 

sediment 

during and 

post 

decom 

(yds3

)

Potential 

sediment 

delivery from 

other sediment 

sources after 

treatment (yds3)

Total 

potential 

sediment 

yield after 

treatments

(yds3

)

Grayback Creek Watershed

4609-947 0.15 Level b 0 0 0 0 0 0 0

4609-948 0.05 Level b 0 0 0 0 0 0 0

4609-955 0.28 Level b 0 0 0 0 0 0 0

4611-085 0.15 Level b 0 0 0 0 0 0 0

4611-917 0.14 Level b 0 0 0 0 0 0 0

4611-918 0.30 Level b 0 0 0 0 0 0 0

4611-950 0.72 Level a 183 0 183 1 18 0 18

4611-951 0.51 Level b 0 0 0 0 0 0 0

4611-980 0.69 Level a 201 18 219 1 20 6 26

4611-990 0.15 Level b 0 0 0 0 0 0 0

4611-996 0.13 Level b 0 0 0 0 0 0 0

4613-057 0.12 Level b 0 0 0 0 0 0 0

Subtotal 3.39 384 18 402 2 38 6 44

Lower Sucker Creek Watershed

4609-032 0.07 Level b 0 0 0 0 0 0 0

4609-036 0.63 Level b 0 489 489 0 0 171 171

4609-039 0.32 Level b 0 0 0 0 0 0 0

4609-041 0.28 Level b 0 0 0 0 0 0 0

4609-922 0.46 Level b 0 10 10 0 0 4 4

4609-947 0.33 Level b 0 0 0 0 0 0 0

25
Sucker Creek Legacy Roads and Trails Project

Road 

number

Road 

miles

Proposed 

treatment

Alternative 1 Alternative 2

Potential 

sediment 

delivery from 

culvert failures 

before treatment 

(yds3

)

Potential 

sediment 

delivery from 

other sediment 

sources before 

treatment (yds3

)

Total 

potential 

sediment 

yield before 

treatments

(yds3

)

Number of 

culverts 

proposed for 

removal

Potential 

sediment 

during and 

post 

decom 

(yds3

)

Potential 

sediment 

delivery from 

other sediment 

sources after 

treatment (yds3

)

Total 

potential 

sediment 

yield after 

treatments

(yds3

)

4609-948 0.10 Level b 0 0 0 0 0 0 0

Subtotal 2.19 0 499 499 0 0 175 175

Middle Sucker Creek Watershed

4600-113 1.09 Level a 0 1,521 1,521 0 0 532 532

4600-176 0.71 Level a 0 71 71 0 0 25 25

4611-070 1.35 Convert to 

trail 403 875 1,278 10 40 306 346

4611-962 0.19 Level b 0 0 0 0 0 0 0

4611-965 0.51 Level a 93 26 119 1 9 9 18

4611-969 0.80 Level b 0 0 0 0 0 0 0

4612-011 0.16 Level a 0 350 350 0 0 123 123

4612-069 2.28 Level a 2,266 221 2,487 4 227 77 304

4612-435 0.74 Level a 1,108 0 1,108 3 111 0 111

4612-440 0.40 Level b 0 0 0 0 0 0 0

4612-460 0.07 Level b 0 0 0 0 0 0 0

4612-461 0.99 Level a 387 90 477 1 39 32 71

4612-462 0.16 Level b 0 0 0 0 0 0 0

4612-463 0.37 Level b 0 0 0 0 0 0 0

4612-465 0.20 Level b 0 110 110 0 0 39 39

4613-057 0.27 Level b 0 0 0 0 0 0 0

4613-066 1.82 Level a 771 67 838 10 77 23 100

4613-406 0.41 Level b 0 0 0 0 0 0 0

4614-015 0.34 Level a 422 356 778 3 42 125 167

26
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Road 

number

Road 

miles

Proposed 

treatment

Alternative 1 Alternative 2

Potential 

sediment 

delivery from 

culvert failures 

before treatment 

(yds3

)

Potential 

sediment 

delivery from 

other sediment 

sources before 

treatment (yds3

)

Total 

potential 

sediment 

yield before 

treatments

(yds3

)

Number of 

culverts 

proposed for 

removal

Potential 

sediment 

during and 

post 

decom 

(yds3

)

Potential 

sediment 

delivery from 

other sediment 

sources after 

treatment (yds3

)

Total 

potential 

sediment 

yield after 

treatments

(yds3

)

4614-016 0.14 Level b 0 0 0 0 0 0 0

4614-040 0.72 Level b 0 0 0 0 0 0 0

4614-414 0.11 Level b 0 0 0 0 0 0 0

4614-422 0.13 Level a 357 0 357 1 36 0 36

4614-423 0.30 Level b 0 0 0 0 0 0 0

4614-425 0.07 Level b 0 0 0 0 0 0 0

4614-433 0.71 Level b 0 0 0 0 0 0 0

4614-435 0.21 Level b 0 0 0 0 0 0 0

4614-448 0.06 Level b 0 0 0 1 0 0 0

4703-106 0.25 Level b 0 0 0 0 0 0 0

4703-112 0.53 Level b 0 35 35 0 0 35 35

4703-135 0.02 Level b 0 0 0 0 0 0 0

4703-425 0.14 Level b 0 0 0 0 0 0 0

4703-426 0.40 Level b 0 0 0 0 0 0 0

4703-428 0.25 Level b 0 0 0 0 0 0 0

4703-455 0.26 Level b 38 0 38 1 4 0 4

4703-521 0.19 Level b 0 0 0 0 0 0 0

4812-534 0.35 Level b 0 0 0 0 0 0 0

4812-535 0.32 Level b 0 0 0 0 0 0 0

4812-539 0.79 Level b 0 0 0 0 0 0 0

Subtotal 18.81 5,845 3,722 9,567 35 585 1,326 1,911

27
Sucker Creek Legacy Roads and Trails Project

Road 

number

Road 

miles

Proposed 

treatment

Alternative 1 Alternative 2

Potential 

sediment 

delivery from 

culvert failures 

before treatment 

(yds3

)

Potential 

sediment 

delivery from 

other sediment 

sources before 

treatment (yds3

)

Total 

potential 

sediment 

yield before 

treatments

(yds3

)

Number of 

culverts 

proposed for 

removal

Potential 

sediment 

during and 

post 

decom 

(yds3

)

Potential 

sediment 

delivery from 

other sediment 

sources after 

treatment (yds3

)

Total 

potential 

sediment 

yield after 

treatments

(yds3

)

Upper Sucker Creek Watershed

4612-098 1.78 Convert to 

trail 7,798 1 7,799 14 783 0 783

4612-455 0.09 Level b 0 0 0 0 0 0 0

4612-467 0.98 Level b 0 0 0 0 0 0 0

4612-475 0.23 Level b 0 0 0 0 0 0 0

4612-485 0.15 Level b 0 0 0 0 0 0 0

4612-486 0.29 Level b 0 0 0 0 0 0 0

4612-490 0.15 Level b 0 0 0 0 0 0 0

4612-542 0.45 Level b 97 0 97 1 10 0 10

4614-446 0.11 Level b 0 0 0 0 0 0 0

4614-455 0.16 Level b 0 0 0 0 0 0 0

4703-135 0.07 Level b 0 0 0 0 0 0 0

4703-150 0.12 Level b 0 0 0 0 0 0 0

4703-151 0.23 Level b 0 0 0 0 0 0 0

4703-152 0.24 Level b 0 0 0 0 0 0 0

4812-041 1.10 Level a 3,162 0 3,162 3 316 0 316

4812-576 0.25 Level b 0 0 0 0 0 0 0

4812-578 0.16 Level b 0 0 0 0 0 0 0

4812-580 0.20 Level b 0 0 0 0 0 0 0

4812-590 0.23 Level b 0 0 0 0 0 0 0

Subtotal 6.99 11,057 1 11,058 18 1,109 0 1,109

28
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Road 

number

Road 

miles

Proposed 

treatment

Alternative 1 Alternative 2

Potential 

sediment 

delivery from 

culvert failures 

before treatment 

(yds3

)

Potential 

sediment 

delivery from 

other sediment 

sources before 

treatment (yds3

)

Total 

potential 

sediment 

yield before 

treatments

(yds3

)

Number of 

culverts 

proposed for 

removal

Potential 

sediment 

during and 

post 

decom 

(yds3

)

Potential 

sediment 

delivery from 

other sediment 

sources after 

treatment (yds3

)

Total 

potential 

sediment 

yield after 

treatments

(yds3

)

Total for 

Sucker 

Creek 

Analysis 

Area

31.38 17,321 4,205 21,526 49 1,732 1,507 3,239

*Maintenance level 1 – Basic custodial care (closed); Maintenance level 2 – High clearance vehicles; Maintenance level 3 – Suitable for passenger cars; Maintenance level 4 –

Moderate degree of user comfort; and Maintenance level 5 – High degree of user comfort.

**AC – Asphalt; AGG – Crushed aggregate or gravel; BST – Bituminous surface treatment; and NAT – Native material.

***Level of decommissioning:

Level a – More Intensive treatment (e.g., culvert removal, outsloping, scarification/decompaction, revegetation) in part or all of the road segment in order to achieve restoration 

objectives.

Level b – Less intensive treatment across only part of the road or road segment (e.g., waterbars, small culvert removal, entrance blockage) to achieve restoration objectives.

****Priority for treatment:

Tier 1 – Area of roads with highest potential sediment delivery to streams.

Tier 2 – Area of roads with intermediate potential sediment delivery to streams.

Tier 3 – Area of roads with lowest potential sediment delivery to streams

29
Sucker Creek Legacy Roads and Trails Project

Table 3. Potential sediment delivery (yd3) from roads proposed for storage in the Sucker Creek Project by alternative

Road 

number

Road 

miles

Alternative 1 Alternative 2

Potential 

sediment 

delivery from 

culvert failures 

before 

treatments (yds3

)

Potential 

sediment 

delivery from 

other sediment 

sources before 

treatment (yds3)

Total potential 

sediment 

delivery before 

treatments

(yds3

)

Number of 

culverts 

proposed 

for 

removal

Potential 

sediment during 

and post 

storage (yds3

)

Potential 

sediment 

delivery from 

other sediment 

sources after 

treatment

(yds3

)

Total potential 

sediment yield 

after 

treatments

(yds3)

Grayback Creek Watershed

4609-056 2.25 0 0 0 0 0 0 0

4609-911 0.47 0 0 0 0 0 0 0

4609-920 0.57 0 0 0 0 0 0 0

4611-078 0.82 109 0 109 0 109 0 109

4611-085 0.11 0 0 0 0 0 0 0

4611-086 0.22 0 0 0 0 0 0 0

4611-910 2.09 1,931 2,391 4,322 6 193 837 1,030

4611-912 1.53 1,626 0 1,626 6 229 0 229

4611-914 0.86 122 0 122 1 12 0 12

4611-955 0.67 0 0 0 0 0 0 0

4611-968 0.40 0 0 0 0 0 0 0

4611-988 1.79 1,353 4 1,357 6 135 1 136

4613-015 0.64 55 7 62 1 6 2 8

4613-059 0.08 0 0 0 0 0 0 0

Subtotal 12.50 5,196 2,402 7,598 20 684 840 1,524

Lower Sucker Creek Watershed

4609-053 0.91 616 602 1,218 7 62 211 273

4609-056 0.01 0 0 0 0 0 0 0

4609-911 0.36 0 0 0 0 0 0 0

30
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Road 

number

Road 

miles

Alternative 1 Alternative 2

Potential 

sediment 

delivery from 

culvert failures 

before 

treatments (yds3

)

Potential 

sediment 

delivery from 

other sediment 

sources before 

treatment (yds3)

Total potential 

sediment 

delivery before 

treatments

(yds3

)

Number of 

culverts 

proposed 

for 

removal

Potential 

sediment during 

and post 

storage (yds3

)

Potential 

sediment 

delivery from 

other sediment 

sources after 

treatment

(yds3

)

Total potential 

sediment yield 

after 

treatments

(yds3

)

4609-912 0.10 0 0 0 0 0 0 0

4609-920 1.47 439 208 647 3 44 73 117

4609-922 0.25 0 0 0 0 0 0 0

4609-923 0.10 0 0 0 0 0 0 0

Subtotal 3.20 1,055 810 1,865 10 106 284 390

Middle Sucker Creek Watershed

4611-964 0.15 0 0 0 0 0 0 0

4611-968 0.03 0 0 0 0 0 0 0

4612-013 0.76 394 93 487 1 39 33 72

4613-059 0.30 0 0 0 0 0 0 0

4614-017 1.24 4,332 1,286 5,618 8 436 450 886

4614-024 1.76 533 1,164 1,697 2 53 407 460

4614-047 1.25 6 0 6 0 6 0 6

4614-456 0.04 0 0 0 0 0 0 0

4703-100 0.35 0 0 0 0 0 0 0

4703-146 0.05 0 0 0 0 0 0 0

4703-433 1.29 0 0 0 0 0 0 0

4703-440 1.81 1,158 0 1,158 4 116 0 116

Subtotal 9.03 6,423 2,543 8,966 15 650 890 1,540

31
Sucker Creek Legacy Roads and Trails Project

Road 

number

Road 

miles

Alternative 1 Alternative 2

Potential 

sediment 

delivery from 

culvert failures 

before 

treatments (yds3

)

Potential 

sediment 

delivery from 

other sediment 

sources before 

treatment (yds3)

Total potential 

sediment 

delivery before 

treatments

(yds3

)

Number of 

culverts 

proposed 

for 

removal

Potential 

sediment during 

and post 

storage (yds3

)

Potential 

sediment 

delivery from 

other sediment 

sources after 

treatment

(yds3

)

Total potential 

sediment yield 

after 

treatments

(yds3

)

Upper Sucker Creek Watershed

4612-540 1.96 1,150 0 1,150 6 115 0 115

4612-541 0.41 602 0 602 1 60 0 60

4614-047 1.26 469 0 469 1 47 0 47

4614-456 0.03 0 0 0 0 0 0 0

4703-146 0.44 0 0 0 0 0 0 0

4812-575 1.32 0 0 0 0 0 0 0

4812-577 0.67 0 0 0 0 0 0 0

Subtotal 6.09 2,221 0 2,221 8 222 0 222

Total for 

Sucker 

Creek 

Analysis 

Area

30.82 14,901 5,755 20,656 53 1,662 2,014 3,676

32
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Table 4. Potential sediment delivery (yd3) from roads proposed for stormproofing in the Sucker Creek Project by alternative

Road number Road miles Current maintenance 

level

Potential sediment yield before 

stormproofing treatment (yds3

)

Potential sediment yield after 

stormproofing treatment (yds3)

Grayback Creek Watershed

4611 10.88 3 24,162 8,457

4611-019 3.48 1 1,282 449

4611-063 2.57 2 1,048 367

4611-070 3.35 2/3 5,396 1,889

4611-079 3.92 2 7,890 2,762

4611-952 0.31 2 0 0

4611-953 1.45 1 22 8

4611-954 0.05 2 0 0

4611-970 0.77 2 401 140

4611-972 0.39 2 0 0

4611-973 1.88 1 930 326

4613 4.79 3 1,814 635

4613-011 0.73 2 0 0

4613-031 0.01 2 0 0

4613-067 0.24 2 0 0

4613-401 0.27 2 0 0

Subtotal 35.09 42,945 15,031

Lower Sucker Creek Watershed

4600-105 0.43 3 0 0

4600-105A 0.09 3 0 0

4600-105B 0.05 3 0 0

4600-105C 0.05 3 0 0

33
Sucker Creek Legacy Roads and Trails Project

Road number Road miles Current maintenance 

level

Potential sediment yield before 

stormproofing treatment (yds3

)

Potential sediment yield after 

stormproofing treatment (yds3)

4609 5.73 2/3 2,564 897

Subtotal 6.35 2,564 897

Middle Sucker Creek Watershed

4600-112 0.65 2 19 7

4600-150 1.09 3 15,460 5,411

4600-180 0.64 1 736 258

4600-410 0.07 2 1,106 387

4611-070 1.43 2 116 41

4611-079 0.01 2 0 0

4611-960 2.94 2 1,696 594

4612 8.18 3 40,508 14,178

4612-036 2.71 2 1,324 463

4612-058 0.10 1 0 0

4612-069 0.33 1 17 6

4612-080 0.36 2 0 0

4612-430 2.35 2 4,719 1,652

4613 2.07 3 171 60

4613-011 1.07 2 0 0

4613-031 2.47 2 2,324 813

4613-067 0.81 2 0 0

4613-401 0.02 2 0 0

4614 4.52 2 3,639 1,274

4614-013 0.73 2 383 134

4614-014 1.92 2 0 0

34
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Road number Road miles Current maintenance 

level

Potential sediment yield before 

stormproofing treatment (yds3

)

Potential sediment yield after 

stormproofing treatment (yds3)

4614-046 1.52 2 0 0

4614-048 0.28 2 0 0

4703 3.49 2 2,512 879

4703-051 1.37 2 240 84

4703-430 1.03 2 0 0

4703-445 1.00 2 0 0

4703-450 3.44 2 1,517 531

4703-458 0.34 2 149 52

4812-538 0.90 2 0 0

4812-540 0.93 2 61 21

4812-540A 0.09 2 0 0

Subtotal 48.86 76,697 26,844

Upper Sucker Creek Watershed

4612 1.48 3 9,414 3,295

4612-080 8.34 2 20,473 7,166

4612-098 3.38 2 10,959 3,836

4612-472 4.13 2 14,382 5,034

4612-487 0.80 2 0 0

4614-048 2.58 2 1,333 467

4614-449 0.80 1 0 0

4614-457 0.45 1 0 0

4703 2.71 2 2,336 818

4703-156 1.02 1 460 161

4812-041 1.52 3 201 70

35
Sucker Creek Legacy Roads and Trails Project

Road number Road miles Current maintenance 

level

Potential sediment yield before 

stormproofing treatment (yds3

)

Potential sediment yield after 

stormproofing treatment (yds3)

Subtotal 27.21 59,558 20,845

Total for Sucker Creek 

Analysis Area 117.51 181,764 63,617

36
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Mitigation Measures and Project Design Criteria

Mitigation, as defined in the Council on Environmental Quality (CEQ) Regulations (40 Code of 

Federal Regulations [CFR] 1508.20) includes: 1) avoiding the impact altogether by not taking a 

certain action or parts of an action, 2) minimizing impacts by limiting the degree or magnitude of 

the action and its implementation, 3) rectifying or eliminating the impact over time by 

preservation and maintenance operations during the life of the action, 4) compensating for the 

impact by replacing or providing substitute resources or environments, and 5) rectifying the 

impact by repairing, rehabilitating, or restoring the affected environment. “Project design criteria” 

would be employed during on-the-ground project designation and implementation and are 

designed to address overall objectives (attain the purpose and need) and “mitigation measures” 

are designed to minimize consequences during actual project operations. Standards and guidelines 

and mitigation measures identified in the Siskiyou Forest Plan, as amended, are incorporated by 

reference as required mitigation measures. In addition, all contracts or other methodology for 

implementation of actions would comply with all requirements and standards for protection of 

threatened, endangered, and sensitive species, in compliance with the Endangered Species Act. 

Project design criteria would be implemented through project design and implementation, 

contract specifications, contract administration, and monitoring activities performed by Forest 

Service officers. 

Note that some measures would be enacted only if certain (future) conditions exist that would 

require it (e.g., if a nesting pair of spotted owls is discovered within 0.25 miles of an activity area, 

or a previously unknown heritage site is discovered).

Proposed mitigation measures and standard operating procedures designed to avoid or minimize 

adverse effects (or implement positive effects) for the alternatives are identified by resource topic 

area, and in some cases, by the specific component or sub-component project within the proposed 

activity. These measures are specific to implementation of actions considered within this EA.

We developed the following project design criteria and mitigation measures to apply to the 

modified proposed action. These criteria were developed to reduce or eliminate adverse impacts 

from project activities. Project design criteria are based upon standard practices and operating 

procedures that have been employed and proved effective in similar circumstances and 

conditions. Project design criteria are non-discretionary once approved in a decision. Project 

design criteria do not apply to alternative 1- no action because no project activities are proposed; 

no changes would be made to the existing system of roads and trails in the planning area under 

alternative 1. However, continuing current management under alternative 1 would include the use 

of standard operating procedures and best management practices for routine road and trail 

maintenance and other routine activities as part of managing the current transportation system.

Forest Service National Best management Practices for Water Quality Management on National 

Forest System Lands, Volume 1 National Core BMP Technical Guide (BMPs, USDA Forest 

Service 2012) and the Region 6 General Water Quality Best Management Practices (USDA Forest 

Service 1988) applicable to road and trail management are incorporated by reference, and are 

incorporated into the development of mitigation measures for the Sucker Creek Legacy Roads 

and Trails Project. These best management practices are widely adopted and accepted as being 

effective in avoiding, minimizing, or mitigating adverse effects to soil, water quality, and 

instream riparian resources and would be implemented under the action alternative for the Sucker 

Creek Legacy Roads and Trails Project. A list of the BMPs that are an integral part of 

implementation are available in appendix B. 

37
Sucker Creek Legacy Roads and Trails Project

Standards and Guidelines and mitigation measures identified in the 1989 Siskiyou National Forest 

Land and Resource Management Plan, as amended, are required measures and are incorporated 

by reference. 

Cultural Resources

1. If cultural resources are encountered during the course of this project, earth-disturbing 

activities in the vicinity of the find must be suspended, and a Forest Service Archaeologist or

Archaeological Technician notified to evaluate the discovery and recommend the subsequent 

course of action.

2. In the event that project activities occur outside of road prism, they must be coordinated with 

a Forest Service Archaeologist or Archaeological Technician prior to initiation.

3. A Forest Service Archaeologist or Archaeological Technician will survey several roads 

immediately prior to project activities.

Hydrology and Soils

4. A sediment control plan would be developed during the implementation phase for this 

planning decision; this is a standard best management practice that would be followed. 

5. Decommissioned roadbeds and project staging areas are to be left in a condition that prevents 

channeling of surface flows and allows infiltration suitable for revegetation.

6. Follow the Sucker Creek Legacy Roads and Trails Revegetation Plan for guidance on plant 

species when using seeding/planting for erosion control and re-establishment of site 

productivity.

7. During decommissioning and storage activities, unstable road fill slopes will be pulled back 

adequately to prevent future failure.

8. Stockpile slash generated from vegetation clearing during road decommissioning, storage, 

and stormproofing activities to scatter over disturbed sites. Seed exposed soils with an

appropriate native seed mix, particularly areas with minimal residual slash cover.

9. Before the onset of extended wet weather, install appropriate temporary erosion control 

measures at incomplete project sites with exposed soil, such as silt fencing or mulch; remove 

temporary drainage crossings or other temporary obstructions from drainages.

10. Project activities will cease at any time when the travelway of the road is wet and turbid 

water or fines are observed moving off the road surface to ditch lines that deliver to stream 

channels, regardless of time of year.

Aquatic Biota2

11. Follow the appropriate state (ODFW 2008) or most recent guidelines for timing of in-water 

work. 

12. Ensure that an experienced fisheries biologist or hydrologist is involved in the design of all 

activities in this project. The experience should be commensurate with technical requirements 

of a project.

2 Project design criteria listed here are specific to the Sucker Creek Legacy Roads and Trails Project. 

38

 
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

13. The project fisheries biologist/hydrologist will ensure that project design criteria (chapter 2)

and reporting are incorporated into implementation contracts. If a biologist or hydrologist is 

not the contracting officer representative, then the biologist or hydrologist must regularly 

coordinate with the project contracting officer representative to ensure the project design 

criteria and conservation measures are being followed.

14. Best management practices to confine vegetation and soil disturbance to the minimum area, 

and minimum length of time, as necessary to complete the action, and otherwise prevent or 

minimize erosion associated with the action area.

15. Specific to Road and Trail Erosion Control and Decommissioning includes hydrologically 

closing or decommissioning roads and trails, including culvert removal in perennial and 

intermittent streams; removing, installing or upgrading cross-drainage culverts; upgrading 

culverts on non-fish-bearing steams; constructing water bars and dips; reshaping road prisms; 

vegetating fill and cut slopes; removing and stabilizing of side- cast materials; grading or 

resurfacing roads that have been improved for aquatic restoration with gravel, bark chips, or 

other permeable materials; contour shaping of the road or trail base; removing road fill to 

native soils; soil stabilization and tilling compacted surfaces to reestablish native vegetation. 

Equipment such as excavators, bull dozers, dump trucks, front-end loaders, and similar 

equipment may be used to implement projects.

Decommissioning

♦ For road decommissioning and hydrologic closure projects within riparian areas, 

recontour the affected area to mimic natural floodplain contours and gradient to the 

extent possible.

♦ When obliterating or removing road segments adjacent to a stream, use sediment 

control barriers between the road and stream if space is available.

♦ Dispose of slide and waste material in stable sites out of the flood-prone area. Native 

material may be used to restore natural or near-natural contours.

♦ Drainage features used for stormproofing and treatment projects should be spaced as 

to hydrologically disconnect road surface runoff from stream channels. If grading and 

resurfacing is required, use gravel, bark, or other permeable materials for resurfacing.

♦ Minimize disturbance of existing vegetation in ditches and at stream crossings.

♦ Conduct activities during dry-field conditions (generally May 15 to October 15) 

when the soil is more resistant to compaction and soil moisture is low.

♦ When removing a culvert from a first or second order non-fish bearing stream, 

project specialists shall determine if culvert removal should include stream isolation 

and rerouting in project design. Culvert removal on fish bearing streams shall adhere 

to the measures described in Fish Passage Restoration (National Marine Fisheries 

Services 2013). See appendix D.

♦ For culvert removal projects, restore natural drainage patterns and channel 

morphology. Evaluate channel incision risk and construct in-channel grade control 

structures when necessary.

16. Heavy equipment will be commensurate with the project and operated in a manner that 

minimizes adverse effects to the environment (e.g. minimally-sized, low pressure tires, 

minimal hard turn paths for tracked vehicles, temporary mats or plates within wet areas or 

sensitive soils).

39
Sucker Creek Legacy Roads and Trails Project

Heavy Equipment Use

♦ Fueling and cleaning and inspection for petroleum products and invasive weeds

♦ All equipment used for instream work will be cleaned for petroleum accumulations, 

dirt, plant material (to prevent the spread of noxious weeds), and leaks repaired prior 

to entering the project area. Such equipment includes large machinery, stationary 

power equipment (e.g., generators, canes), and gas-powered equipment with tanks 

larger than five gallons.

♦ Store and fuel equipment in staging areas after daily use.

♦ Inspect daily for fluid leaks before leaving the vehicle staging area for operation.

♦ Thoroughly clean equipment before operation below ordinary high water or within 50

feet of any natural water body or areas that drain directly to streams or wetlands and 

as often as necessary during operation to remain grease free.

17. Existing roadways will be used whenever possible. Minimize the number of temporary access 

roads and travel paths to lessen soil disturbance and compaction and impacts to vegetation. 

Temporary access roads will not be built on slopes where grade, soil, or other features suggest 

a likelihood of excessive erosion or failure. When necessary, temporary access roads will be 

obliterated or revegetated. Temporary roads in wet or flooded areas will be restored by the 

end of the applicable in-water work period. Construction of new permanent roads is not 

permitted.

18. Minimize number and length of stream crossings. Such crossings will be at right angles and 

avoid potential spawning areas to the greatest extent possible. Stream crossings shall not 

increase the risk of channel re-routing at low and high water conditions. After project 

completion, temporary stream crossings will be abandoned and the stream channel and banks 

restored.

19. Work from top of bank – To the extent feasible, heavy equipment will work from the top of 

the bank, unless work instream would result in less damage to the aquatic ecosystem.

20. Timely completion – Minimize time in which heavy equipment is in stream channels, riparian 

areas, and wetlands. Complete earthwork (including drilling, excavation, dredging, filling and 

compacting) as quickly as possible. During excavation, stockpile native streambed materials 

above the bankfull elevation, where it cannot reenter the stream, for later use.

Sensitive Plants3

21. The district botanist will be notified adequately prior to implementation in treatment areas in 

order to protect and flag sensitive species occurrences.

a. If implementation is to occur outside of the field season, the implementation 

schedule should be relayed to Botany specialists in the previous field season to 

flag sensitive species occurrences. 

3 If any threatened or endangered plant species or Forest Service sensitive plant, lichen, or fungi species are 

found prior to or during implementation, there will be an amendment to the BE and additional mitigations 

may be created.

40

 
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

b. All sensitive plant species will be flagged by RRSNF Botanists prior to 

implementation and avoided during implementation to prevent direct impacts to 

any of these species.

22. The district botanist, prior to implementation, would survey all proposed areas that would 

receive ground disturbing activities. This would include but not limited to: removing or 

replacing culverts; decommissioning roads; or any other proposed activities that would 

disturb areas where sensitive species may occur. Surveys would be conducted at the proper 

time of year to identify any target species.

23. There is an occurrence of Siskiyou phacelia at Portuguese Flat on FS Road 4703521. The 

road directly past this sensitive plant area is proposed to be decommissioned. For this area:

a. No project activities would occur within the open sensitive plant occurrence area; 

this includes staging equipment, any form of decommissioning of this sensitive 

plant area, and any project implementation within sensitive plant area.

b. Vehicles, all equipment, implementation tools, and personnel would be restricted 

to the existing road prism 

c. All equipment would be washed and clean of invasive plant and noxious weed 

seeds and materials prior to driving through or accessing the road segment slated 

to be decommissioned.

d. The district botanist would be notified prior to implementation to flag area and be 

on site during implementation.

24. There is an occurrence of Lee's lewisia on FS Road 4614435. This road is proposed to be 

decommissioned. For this road:

a. No project activities would occur within the Lee's lewisia area including: staging 

of equipment; any form of decommissioning of this sensitive plant area; and any 

project implementation within sensitive plant area.

b. All equipment would be washed and clean of invasive plant and noxious weed 

seeds and materials prior to driving through or accessing the road segment slated 

to be decommissioned.

c. The district botanist will be notified prior to implementation to flag area and be 

on site during implementation.

25. FS roads 4703051, 4609053, 4611968, and 4611955 are proposed to be placed in to storage. 

For these roads:

a. No project activities would occur within the Howell's fawnlily (FS road 4703051 

and 4609053) and California globemallow (FS roads 4611968 and 4611955) 

areas including: staging of equipment; any form of decommissioning of this 

sensitive plant area; and any project implementation within sensitive plant area.

b. Culverts may be removed on FS road 4609053; there are two culverts within 310 

feet and one culvert within 510 feet of the Howell's fawnlily occurrence. To 

prevent direct impacts no project activities would occur within sensitive plant 

areas.

c. All equipment will be washed and clean of invasive plant and noxious weed 

seeds and materials prior to driving through or accessing the road segment slated 

to be placed into storage.

41
Sucker Creek Legacy Roads and Trails Project

d. The district botanist will be notified prior to implementation to flag area and be 

on site during implementation.

26. FS road 4611070 is proposed for decommissioning. This road is within the Bigelow Botanical 

Area and has infestations of invasive plants (refer to the Sucker Creek Roads and Trails 

Invasive Plant Risk Assessment). It also serves as a walking trail to access parts of the 

Botanical Area and trail to Bigelow Lakes. For this road:

a. Project Lead will consult and work with the district botanist to plan and 

determine implementation activities that would occur there.

27. Areas that would receive ground disturbing activities would be re-vegetated to maintain 

native plant diversity, prohibit the spread and introduction of invasive plants, and restore 

impacted ecosystems 

a. Re-vegetation areas include but are not limited to: culvert replacement, road 

decommissioning, disturbed areas, creation of bare soil areas, staging areas, 

canopy removal areas, other areas 

b. Refer to the Sucker Creek Legacy Roads and Trails Re-vegetation Plan

Invasive Plants

28. Forest botanists will be notified adequately (minimum of 2 weeks) prior to any project 

implementation of each unit to treat and/or properly flag infested areas in field season. 

a. If implementation is to occur outside of field season then schedule should be 

relayed to botany department in previous field season to adequately treat 

infestations.

29. Disturbed areas would be re-vegetated to prevent the establishment or spread of invasive 

plants and noxious weeds. The following areas may be re-vegetated dependent on the 

requirement and need of each individual site influenced by the activity that would occur at 

these sites. See the Sucker Creek Legacy Roads and Trails Revegetation Plan in appendix C.

a. Culvert removal or replacements areas

b. Areas with vegetation removal and canopy loss

c. Decommissioned roads

d. Roads placed into storage 

e. Staging areas

f. Disturbed areas from project implementation

g. Areas needing erosion control

30. Project lead would work with the district botanist for all roads proposed for decommissioning 

with infestations to ensure that infestations are controlled and not spread. Roads proposed for 

decommissioning with infestations examples below but not limited to:

a. 4611070 Bigelow Lakes

b. 4611965 Black Pepper

c. 4612098 Sucker Creek Extension

31. All WRRD target invasive plants and noxious weed infestations within the project area or 

along travel routes near the project area will be hand treated where feasible or “flagged and 

42
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

avoided” according to the species present and project constraints. Roadside invasive plant 

sites would be flagged and/or staked by the Forest Botanist/Invasive Plant Coordinator. 

Infested sites will be avoided or the FS contracting officer’s representative or other FS 

representative (representatives may include COR/ER/FSR/SA.) would direct contractor to 

blade or ditch in a manner that reduces the potential spread from infested to un-infested sites 

(e.g. blading into instead of through from infestations).

32. All off-road equipment used on this project shall be washed and cleaned before moving into 

the project area to ensure that the equipment is free of soil, seeds, vegetative material, or 

other debris that could contain or hold seeds of noxious weeds. "Off-road equipment" 

includes all logging and construction equipment (bull dozers, graders, etc.) and such brushing 

equipment as brush hogs, masticators, and chippers; it does not include log trucks, chip vans, 

service vehicles, water trucks, pickup trucks, and similar vehicles not intended for off-road

use. However, it is recommended that all vehicles, especially large vehicles, are cleaned when 

they come onto the Forest Service lands or come from a known weed infested area. This is to 

reduce the potential for spreading invasive plants. In addition, the Forest Service would 

inspect all off-road equipment prior to entry onto NFS lands.

a. Wash stations would be created throughout the treatment area in conjunction with 

Port Orford Cedar (POC) disease control of Phytophthora lateralis

b. Wash stations would be dependent on project implementation locations and 

invasive species and POC disease restraints present

c. Wash stations would be dependent on project implementation locations and 

invasive species and POC disease restraints present Wash stations will follow the

design recommended in the Attachment 2: General Specifications for a Washing 

Station and Equipment Cleaning Checklist FSEIS ROD 2004 Management of 

Port Orford Cedar. This design will consist of a 6-inch rock lift from the existing 

road surface and be at least 1.5 times the length of the longest truck used in 

operations. Water would be caught at the lowest point off of the road in a hole 

lined with bio mesh that would be disposed of by burning, or bagged and 

disposed to a landfill to remove any invasive weed seeds. 

d. A wash station may also be a mobile wash station that can be moved from site to 

site for cleaning of the equipment. The mobile wash station mush use treated 

water following the below criteria for bleach concentration. Wash station filters 

would be bagged and disposed of in a landfill to prevent spread or establishment 

of invasive plant seeds or materials.

e. All parts of equipment must be clean including the undercarriage and chassis 

before transport to the project area or between project areas.

f. Equipment will be considered clean when visual inspection by FS Contracting 

Officer Representative (or other FS representative) does not reveal soil, seeds, 

plant material, or other such debris.

g. When working in known weed infested areas equipment shall then be cleaned 

before moving to other Forest Service lands that are un-infested or do not contain 

the same invasive plant species.

33. To be in compliance with the 2005 ROD for managing invasive plants, all earth-moving 

equipment, gravel, fill, or other materials are required to be weed-free. Use on-site sand, 

gravel, rock, or organic matter when possible. Otherwise, obtain weed-free materials from 

43
Sucker Creek Legacy Roads and Trails Project

gravel pits and fill sources that have been surveyed and approved by a RRS botanist/invasive 

plant coordinator.

34. Landings or staging areas for equipment, materials, or crews will not be sited in invasive 

plant or noxious weed infested areas.

35. Minimize the amount of ground and vegetation disturbance in the construction areas.

Reestablish vegetation where feasible on disturbed bare ground to minimize weed 

establishment and infestation. Re-vegetation is especially important in staging areas.

36. Use weed-free mulches, and seed sources. Salvage topsoil from project area for use in onsite 

revegetation, unless contaminated with noxious weeds. All activities that require seeding or 

planting must utilize locally collected native seed sources when possible. Plant and seed 

material should be collected from or near the project area, from within the same watershed, 

and at a similar elevation when possible. Persistent non-natives such as Phleum pratense

(cultivated timothy), Dactylis glomerata (orchard grass), or Lolium spp. (ryegrass) will not be 

used. This requirement is consistent with the Forest Service Manual 2000 (Chapter 2070-

Vegetation Ecology) policy that directs the use of native plant material for re-vegetation and 

restoration for maintaining “the overall national goal of conserving the biodiversity, health, 

productivity, and sustainable use of forest, rangeland, and aquatic ecosystems”. Seed mixes 

must be approved by District Botanist.

37. Soil moved from an infested site would be disposed of at designated site coordinated by 

engineers and the District Botanist /Invasive Plant Coordinator.

38. After the project phase is completed the district botanist must be notified so that the project 

area can be monitored for 3 years subsequent to project implementation to ensure additional 

invasive plant species do not become established in the areas affected by the project and to 

ensure that known weeds do not spread. Monitoring will result in early detection and 

treatment of invasive plant sites, thus reducing the cost of treatment and the long-term 

environmental impacts of invasion.

a. All disturbed sites including: culvert replacement and removal; decommissioned 

roads; landings; wash station sites; exiting infestations; and other project 

implementation areas would be monitored

39. Any new invasive plants found in the project area will be documented and the Wild 

Riversdistrict botanist will be notified of the infestation location.

Revegetation Requirements

40. Areas that would receive ground disturbing activities would be revegetated to maintain native 

plant diversity, prohibit the spread and introduction of invasive plants, and restore impacted 

ecosystems 

a. Revegetation areas include but are not limited to: culvert replacement, road 

decommissioning, disturbed areas, creation of bare soil areas, staging areas, 

canopy removal areas, other areas. 

b. Refer to the Sucker Creek Legacy Roads and Trails Revegetation Plan (appendix 

C).

41. Culvert replacement and removal areas would be re-vegetated with the riparian native tree, 

shrub, forb, or grass species listed.

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

a. Resistant Port Orford cedar would be used at least 25 feet above the stream and 

25 feet between seedlings to prevent spores migrating with water into their root 

system.(approximately 70 trees/acre).

b. Other riparian tree and shrub species can be planted in disturbed areas and to the 

stream channel.

c. Tree and shrubs will be planted in all disturbed areas to minimize soil erosion 

into stream channel and provide bank stability. Grass and forbs could be utilized 

for appropriate site needs.

42. Decommissioned roads would be seeded with the appropriate native grass seeds and/or trees 

and shrubs.

a. The first 100 feet or wherever there is ripping and re-contouring would be seeded 

with native grass seed. 

b. Areas with slopes over 45 percent may be seeded with native grass seed and 

mulched with weed free mulch and/or planted with the appropriate trees, shrubs, 

or herbs for the habitat.

c. If road is ripped and re-contoured beyond the first 100 feet trees, shrubs, forbs, 

and grass seed may be planted.

43. Staging areas or other disturbed areas would be planted with the appropriate tree, shrub, herb, 

or grass species dependent on habitat, soils, elevation, and disturbance area.

44. Plant resistant stock POC in their respective planting zones. Follow the breeding zone map 

for stock placement. Plant resistant stock only in un-infested sites where POC normally 

occurs. Space POC seedlings 25 feet from water sources and 25 foot spacing.

Port Orford Cedar

45. Schedule project activities during the dry season: June 1 – September 30.

46. Conduct work on roads where P. lateralis is not present before working on sites that are 

infested. The following table lists roads within the analyses area that have Port Orford cedar 

infested with P. lateralis along with proposed treatments.

Forest Service Road Proposed Treatment

4600000, 4600105B, 4600112, 4609000, 4611000, 4611063,

4611070, 4611079, 4612000 Stormproof

4611988 Storage

4612069 Decommission

47. Use uninfested water sources for planned activities such as equipment washing, road 

watering, and other water-distribution needs, or treat water with Ultra Clorox®, at a rate of 1 

gallon of bleach/1000 gallons of water.

48. Designate ingress and egress routes to minimize exposure to PL.

49. Resistant POC Planting: Site specific based on uninfected areas where the proposed action 

treatment for a road is either storage or decommission (Revegetation Plan appendix C). 

50. Washing project equipment:

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Sucker Creek Legacy Roads and Trails Project

a. Wash project equipment before entering National Forest land the first time in the 

work period. Wash equipment again before entering National Forest lands if 

work is halted and equipment is taken to another job site or for any reason 

equipment is taken to another job site away from this project. 

b. Wash project equipment, work boots and any hand tools after working in each 

area where PL is already known to be present and before working on the next 

scheduled site.

c. Wash stations will be established through coordination with the botanist and the 

contract inspector on the project.

d. Wash stations would follow the design recommended in the Attachment 2: 

General Specifications for a Washing Station and Equipment Cleaning Checklist

POC FSEIS ROD 2004. This design will consist of a 6-inch rock lift from the 

existing road surface and be at least 1.5 times the length of the longest truck used 

in operations. Water would be caught at the lowest point off of the road in a hole 

lined with bio mesh that would be disposed of by burning, or bagged and 

disposed to a landfill to remove any invasive weed seeds. 

e. A wash station may also be a mobile wash station that can be moved from site to 

site for cleaning of the equipment. The mobile wash station mush use treated 

water following the below criteria for bleach concentration. Wash station filters 

would be bagged and disposed of in a landfill to prevent spread or establishment 

of invasive plant seeds or materials. 

51. Rout new trails (off-highway vehicle, motorcycle, mountain bike, horse, and foot) away from 

areas with POC or PL, or provide other mitigation such as seasonal closures. Trailheads will 

be relocated and/or established trails will be rerouted in the same matter where trails present 

significant risk to POC, or provide other mitigation such a site hardening.

52. In the case of a summer rain event, apply permit or contract clause or otherwise require 

cessation of operations when indicators such as puddles in the roadway, water running in 

roadside ditches, or increase in soils moisture (as by moisture meter or equivalent) indicate an 

unacceptable increase in the likelihood of spreading PL.

Wildlife

Spotted Owl

53. Work activities (such as tree felling, yarding, road construction, hauling on roads not 

generally used by the public, prescribed fire, muffled blasting) that produce loud noises above 

ambient levels, or produce thick smoke that would enter the stand, will not occur within 

restricted distances of any spotted owl nest site or activity center of known pairs and resident 

singles, unsurveyed suitable NRF habitat between 1 March and 30 June (or until two weeks 

after the fledging period) – unless protocol surveys have determined the activity center or 

NRF habitat to be not occupied, non-nesting, or failed in their nesting attempt. The restricted 

zone is 1.0 mile for any unmuffled blasting. This distance may be shortened if significant 

topographical breaks or blast blankets (or other devices) muffle sound traveling between the 

blast and nest sites. March 1 – June 30 is considered the critical early nesting period; the 

action agency biologist has the option to extend the restricted season during the year of 

harvest, based on site-specific knowledge (such as a late or recycle nesting attempt). The 

boundary of the prescribed area may be modified by the action agency biologist using 

46
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

topographic features or other site-specific information. The restricted area is calculated as a 

radius from the assumed nest site (point). 

Restricted distances are calculated as:

♦ less than or equal to1 mile for blast of more than 2 lbs. of explosive; 

♦ less than or equal to 1/4 mile for Type I or II helicopters; 

♦ less than or equal to120 yards for blast of less than 2 lbs. of explosive and Type IIIIV helicopters or single-engine airplanes; 

♦ less than or equal to 65 yards for chainsaws; 

♦ less than or equal to 60 yards for impact pile driver, jackhammer, or rock drill; 

♦ less than or equal to 35 yards for heavy equipment.

54. Designated Critical Habitat for Northern Spotted Owl: Trees cut within designated habitat for 

the northern spotted owl (KLW-4) as roadside hazards or for drainage improvement at culvert 

sites will either be left on-site in riparian reserves or distributed within the designated critical 

habitat to serve as primary constituent elements of critical habitat. Excess of this material 

could be hauled off-site and utilized in stream restoration projects, needs in other latesuccessional reserve locations that are deficient in downed wood for wildlife, or for other 

special wood products such as firewood.

55. If an active spotted owl nest or activity center is located within or adjacent to a project area, 

delay the project activity until September 30th or until an action agency biologist determines 

that young are not present. For a given situation, the “adjacent” distance is determined by the 

action agency biologist – if needed, contact Level 1 team for guidance. If any project activity 

is so close to a known or suspected owl site that the disturbance would flush a nesting spotted 

owl, curtail the project activity until September 30. The field biologist has the discretion to 

conduct surveys and determine fledging activity.

Snag-dependent Species

56. To the extent compatible with safety provisions retain all snags with tree diameter greater 

than or equal to10 inches. Retain on site, all commercial size down-woody material. "Leavetrees" damaged during project operations will be left on site. The intent is to maintain or 

minimize the loss of existing snag numbers following all treatment activities. All snags felled 

for safety will remain on-site. Excess of this material could be hauled off-site and utilized in 

stream restoration projects, needs in other late-successional reserve locations that are 

deficient in downed wood for wildlife, or for other special wood products such as firewood.

Black Salamander, Del Norte Salamander, Foothill Yellow-legged Frog, 

Northwestern Pond Turtle

57. Any salamanders, frogs or turtles found during culvert work would either be left unharmed or 

moved to suitable moist, shaded habitat adjacent to but undisturbed by the work site if there is 

potential for harm.

Siskiyou Short-horned Grasshopper

58. To the extent possible, avoid disturbance or removal of blue elderberry from roadsides, road

prisms to be decommissioned, and culvert locations.

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Sucker Creek Legacy Roads and Trails Project

Migratory Birds

59. Avoid disturbance of any active bird nests during project activities. To the extent possible, 

avoid any activities within 328 feet of active bird nests until young have left the nest.

Late-Successional Reserves

60. Trees cut within the East IV LSR as roadside hazards or for drainage improvement at culvert 

sites would be left on-site in riparian reserves or distributed in the LSR for down woody 

material. Excess of this material could be hauled off-site and utilized in stream restoration 

projects, needs in other late-successional reserve locations that are deficient in downed wood 

for wildlife, or for other special wood products such as firewood.

Cultural Resources

61. In the event that project activities occur outside of the area defined in the heritage resource 

inventory schema, they must be coordinated with the Forest Archaeologist or Archaeological 

Technician prior to initiation.

62. Should heritage resources be discovered as a result of any project activities, earth-disturbing 

activities must be suspended in the vicinity of the find, in accordance with federal regulations 

(NHPA and 36 CFR 800). The Forest Archaeologist or Archaeological Technician must be 

notified to evaluate the discovery and recommend a subsequent course of action.

Recreation

63. Mitigation measures to reduce the impacts to recreational users may include advance notice 

of closures (website, press releases, and postings), signing at appropriate locations, alternative 

route recommendations, notification of user groups, and timing activities outside of the 

season of highest recreational use.

64. Contractors would be required to set up project operation warning signs. Prior to 

implementation, site-specific public safety plans would be developed.

65. When possible, road closures will not exceed 30 minutes.

Alternatives Considered, but Eliminated from Detailed Study

Federal agencies are required by the NEPA to rigorously explore and objectively evaluate a 

reasonable range of alternatives and to briefly discuss the reasons for eliminating any alternatives 

that were not developed in detail (40 CFR 1502.14). Public comments received in response to the 

proposed action during scoping provided suggestions for alternative methods of achieving the 

purpose and need. Some of these alternatives are outside the scope of the Sucker Creek Legacy 

Roads and Trails Project, duplicative of the alternatives considered in detail, or determined to be 

components that would cause unnecessary environmental harm. These are:

♦ Decommission NFS Road 4611 in sections 27, 35, and 36 – One commenter suggested 

that FS Road 4611 be decommissioned in sections 27, 35, and 36 to reduce risk of 

impacts to Coho salmon. The ID team considered but eliminated this alternative from 

detailed study because this is a paved backbone system road that is needed to access 

private land, and for land management, fire suppression, and recreation access.

♦ Put a stream crossing on NFS Road 4611-910 – NFS Roads 4611-910, 4611-912, and 

4611-914 will be needed in the future to access Matrix land. However, the bridge on NFS 

Road 4611-910 near its junction with 4611-019 has been blown out. The ID team 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

considered but eliminated from detailed study the alternative of putting a bridge in at this 

time because there is no immediate need to access this area; putting the road into storage 

will meet current management needs. Constructing a bridge at this site could be an option 

in the future to access Matrix land.

♦ Connect NFS Road 4611-912 to 4611-019 – As mentioned above, NFS Roads 4611-910, 

4611-912, and 4611-914 will be needed in the future to access Matrix land. The ID team 

considered but eliminated from detailed study the alternative of connecting NFS Road 

4611-912 to 4611-019 along the boundary between sections 16 and 21, Township 39 

South, Range 6 West. The ID team determined that this alternative is not feasible at this 

time because it would require purchasing a right-of-way easement to construct a portion 

of the road on private land.

♦ Do not decommission NFS Road 4613-066 – One commenter brought up a concern that 

NFS Road 4613-066 is used by many local hunters. The ID team considered but 

eliminated this alternative from detailed study because similar access to the area is 

provided by NFS Roads 4600 and 4613. Non-motorized recreational access would still be 

maintained under the modified proposed action.

♦ Decommission NFS Road 4612-080 and its spur roads past Deep Creek (NFS Roads 

4612-467, 4612-475, 4612-741, 4612-485, 4612-486, 4612-487, and 4612-490) – One 

commenter suggested that NFS Road 4612-080 and its spur roads be decommissioned 

past its intersection with Deep Creek to address sediment delivery concerns and impacts 

to Coho salmon. The option of decommissioning several spur roads (NFS Roads 4612-

467, 4612-475, 4612-472, 4612-485, 4612-486, and 4612-490) off of NFS Road 4612-

080 is analyzed as part of alternative 2 in this EA. The ID team considered but eliminated 

this alternative of decommissioning NFS Roads 4612-080 (past Deep Creek) and 4612-

487 from detailed study because these roads are needed to access Matrix land and provide 

access for fire suppression.

♦ Decommission NFS Road 4612-540 past Yew Creek – One commenter suggested that 

NFS Road 4612-540 be decommissioned past its intersection with Yew Creek. The option 

of decommissioning NFS Road 4612-5400 is analyzed as part of alternative 2 in this EA. 

The ID team considered but eliminated this alternative from detailed study because this 

road is needed to access to Matrix land and provide access for fire suppression.

♦ Do not decommission NFS Road 4703-521 – One commenter brought up a concern that 

NFS Road 4613-521 could be used as an escape route to the Happy Camp, CA road in 

case of a forest fire. The ID team considered but eliminated this alternative from detailed 

study because similar access to the area is provided by NFS Roads 4703 and 4812-530. 

Non-motorized recreational access would still be maintained under the modified 

proposed action.

♦ Reopen roads decommissioned in the past in the Sucker Creek drainage for mining 

claim access – Reopening road that were decommissioned in the past would not meet the 

purpose and need for this project to reduce the risk of National Forest System roadcaused sediment delivery to streams in the 5th field Sucker Creek watershed.

Monitoring

Monitoring for both implementation (whether the project was implemented as planned) and 

effectiveness (whether overall management objectives were met) would occur. Forest Service 

personnel would conduct monitoring in areas that have the highest probability of showing effects. 

The following monitoring would occur if an action alternative is implemented.

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Sucker Creek Legacy Roads and Trails Project

Project activities: Project design criteria and mitigation measures would be incorporated into 

contracts and subject to inspection. While project activities are occurring, the Forest Service 

contracting officer representative (COR) or the designated project inspector would monitor 

activities to ensure that prescribed project design, mitigation measures, and seasonal restrictions 

are implemented appropriately. For example, the inspector would monitor the weather and stop 

operations if turbid water is observed moving off the road surface and into streams. Inspectors 

would also ensure vehicles are washed prior to entering the project area. Project inspectors and 

physical scientists would evaluate erosion control methods prior to completion of the project.

Port Orford cedar: The project inspector would insure compliance with the contract that would 

include the appropriate disease control prescriptions. This includes the entire project area and 

travel routes.

Forest-level POC monitoring is ongoing as follows:

♦ Healthy and diseased stands have been identified. Past aerial photography and intensive 

sampling has been conducted and recorded in GIS. Site-specific surveys have been 

conducted during field reconnaissance for this project. Summaries of disease status and 

the use of control strategies will be completed and reported to the Forest level for 

completion of their annual report that coincides with the interregional summary and 

report.

♦ The USDA-FS Southwest Oregon Forest Insect and Disease Service Center continues to 

evaluate and coordinate existing management techniques to reduce the occurrence of P. 

lateralis and retain healthy Port Orford cedar.

♦ Sampling of uninfested 7th field watersheds would occur by baiting P. lateralis with 

nonresistant POC seedlings to validate uninfected status post treatment activities. 

Fish: The project biologist would ensure that design criteria and conservation measures are 

incorporated into any implementation contract agreements. If a biologist is not the COR, then the 

biologist must regularly coordinate with the project COR to ensure the design criteria and 

conservation measures are being followed.

Soils: Erosion control methods and effective ground cover would be monitored and assessed.

Botany: District botanists would monitor the effects of the project implementation on sensitive 

plant occurrences. They would assess the effectiveness of design criteria and if the criteria were 

implemented properly. Botanists would document any decline in species viability due to project 

activities.

Native plant revegetation: District botanists would monitor revegetation of disturbed areas for 

survival success of planted species, effectiveness of preventing invasive species, effectiveness of 

preventing soil erosion, and effectiveness of bank stabilization.

Invasive plants: Known invasive infestations and implementation-caused disturbed areas would 

be monitored by the District botanists. Monitoring would include detecting new infestations in 

disturbed areas and the spread of invasive plants from known infestations. Areas would be 

monitored for 3 years post implementation and infestations would be treated.

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Comparison of Alternatives

This section provides a summary of the effects of implementing each alternative. Information in 

table 5 is focused on activities and effects where different levels of effects or outputs can be 

distinguished quantitatively or qualitatively among alternatives.

Table 5. Comparing the estimated key quantitative differences between alternatives

Indicators Alternative 1 

(no-action)

Alternative 2 

(modified 

proposed action)

Miles of National Forest System road 180 149

Miles of open NFS road (ML 2-5) 167 118

Miles of closed NFS road (ML 1) 13 31

Miles of road stormproofed 7 118

Miles of road decommissioned 0 28

Miles of road put into storage 0 31

Miles of road converted to trail 0 3

Total road density 2.6 miles of road 

/ square mile

2.2 miles of road / 

square mile

Number of road stream crossings 480 380

Percent of roads within 300 feet of streams 38% 33%

Potential sediment delivered to streams ( cubic yards) 245,000 95,000

Acres of accessible Matrix land 2495 2443

Estimated cost to maintain road system $396,360 $259,836

Acres of soil productivity restored 0 90

Miles of road traversing 45%+ slopes with reduced risk of 

failure over time 0 98

Additional Risk of spread of P. lateralis None Low

Miles of motorized trails 6 6

Miles of motorized mixed use roads 151 126

Miles of non-motorized trail 25 28

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Sucker Creek Legacy Roads and Trails Project

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Chapter III. Affected Environment and 

Environmental Consequences

Introduction

Chapter III summarizes the physical, biological, social, and economic environments of the project 

area and the direct, indirect, and cumulative effects of implementing each alternative on these 

environments. The effects disclosed have considered the effectiveness of the mitigation measures 

outlined in chapter II. Chapter III complies with the implementing regulations of the National 

Environmental Policy Act (NEPA) for analytic and concise environmental documents (40 CFR 

1500-1508).

In the development of the environmental analyses that follow, credible science was considered 

and is documented in the project record for each resource area. Consistency with the Siskiyou 

National Forest Land and Resource Management Plan, as amended (Siskiyou Forest Plan) was 

built into the project design and the analyses. The environmental analyses incorporate issues 

identified through the scoping process. An environmental effect, impact, or consequence is 

defined as a modification of or change in the existing environment brought about by the action 

taken. The NEPA defines these effects as:

♦ Direct effects – are caused by the action and occur at the same time and place.

♦ Indirect effects – are caused by the action but occur later in time or further removed in 

distance, but are still reasonably foreseeable.

♦ Cumulative effects – are those that result from the incremental impacts of the action 

when added to other past, present, and reasonably foreseeable actions.

NEPA regulations (40 CFR 1508.27) refer to effects that are direct, indirect, or cumulative as 

short term or long term. For this project, short term is defined as around 1-10 years and long term 

is defined as around 10-20 years, unless otherwise defined in the resource sections of this chapter. 

Effects can vary in degree, ranging from only a slightly discernible change to a measurable 

alteration in the environment.

Cumulative Effects

A cumulative effect is the impact to the environment resulting from the incremental impact of the 

action when added to effects from other past, present, and reasonably foreseeable future actions. 

Other actions are considered regardless of what agency or person undertakes such other actions 

and regardless of land ownership on which the other actions occur (40 CFR 1508.7). An 

individual action when considered alone may not have a significant effect, but when its effects are 

considered in sum with the effects of other actions, the effects may be significant.

Cumulative effects were assessed for this project in terms of how the alternatives would add to 

the past, present, and future activities. Existing conditions described under each resource section 

reflect the cumulative effects of past and present activities that have occurred in this area. Each 

resource section identifies specific past and present actions with a discernible effect on a 

particular resource as reflected in the existing condition. Only those past, present, and reasonably 

foreseeable actions that overlap the geographic analysis area boundary for each particular 

resource area are considered, and only if those other actions are expected to have overlapping 

effects with the Sucker Creek Legacy Roads and Trails Project. Some past actions may still be 

53
Sucker Creek Legacy Roads and Trails Project

having effects on one resource, but not another. Each resource area considered different mixes of 

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

affected.

This cumulative effects analysis does not attempt to quantify the effects of every past human 

action. There are several reasons for not taking this approach. First, an exhaustive 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. By looking at current conditions, we are sure to capture the residual effects of past 

human actions and natural events, regardless of which particular action or event contributed those 

effects. Second, public scoping for this project did not identify any public interest or need for 

detailed information on individual past actions. Finally, the CEQ issued an interpretive 

memorandum on June 24, 2005 regarding analysis of past 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.”

Climate Change

Introduction

Projected global climate change impacts include air temperature increases, sea level rise, changes 

in the timing, location and quantity of precipitation, and increased frequency of extreme weather 

events such as heat waves, droughts, and floods. These changes will vary regionally and affect 

renewable resources, aquatic and terrestrial ecosystems, and agriculture. While uncertainties will 

remain regarding the timing and magnitude of climate change impacts, the scientific evidence 

predicts that continued increases in greenhouse gas emissions will lead to increased climate 

change.

In the summer of 2008, the University of Oregon Climate Leadership Initiative, in partnership

with The National Center for Conservation Science & Policy and the MAPSS Team at the U.S. 

Forest Service Pacific Northwest Research Station, initiated a project to assess the likely 

consequences of climate change for the Rogue River Basin. A panel of scientists and land 

managers then assessed the likely risks posed by changing climate conditions to natural systems 

and made recommendations for increasing the capacity of ecosystems and species to withstand 

and adapt to those stressors.

Based on the analysis of the risks to natural systems, the policy panel identified as one of the 

main risks in relation to infrastructure in the Rogue Basin, the potential for increased disruption 

and direct damage to transportation systems from more flooding. In response to this risk, the 

policy panel made recommendations in regard to the infrastructure.

In relation to the Sucker Creek Project these include: 

♦ Link public transportation systems as much as possible to facilitate movement of people 

and equipment in emergency situations.

♦ Expand road upgrading and maintenance to prevent wash outs during major storms and 

floods.

The Forest is reviewing and implementing these recommendations as opportunities arise during

the planning of road upgrades and maintenance activities.

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Analysis Framework

There are two types of climate change effects for proposed projects to consider, as appropriate:

♦ The effect of a proposed project on climate change (greenhouse gas emissions and carbon 

cycling). 

♦ The effect of climate change on a proposed project.

Consideration was given as to whether some element of the modified proposed action would 

result in direct, indirect, or cumulative effects on greenhouse gas emissions or the carbon cycle 

and the direction of effects (e.g., increase, decrease, or combination of both). Scoping was used to 

determine if climate change issues are specifically related to this proposal. The Interdisciplinary 

Team did not identify potential for a cause-effect relationship between this proposal and climate 

change.

Direct and Indirect Effects

Many proposed projects and programs would emit greenhouse gases (direct effect) and, thus, 

contribute to the global concentration of greenhouse gases that could affect climate (indirect 

effect). Since greenhouse gases mix readily into the global pool, it is not currently possible to 

ascertain the effects of emissions from single or multiple projects.

Also, because Forest Service projects are extremely small in the global atmospheric CO2 context, 

it is not presently possible to conduct quantitative analysis of actual climate change effects based 

on individual or multiple projects.

The modified proposed action was determined to be of such a minor scale at the global or even 

regional scale, that the direct effects would be inconsequential. The direct and indirect effects 

regarding these relationships are insignificant because there would be very minimal amounts of 

vegetation (no trees of any substantial diameters), and disposal of brush and slash associated with 

trail clearing or maintenance would be very minor under all alternatives.

Cumulative Effects

As greenhouse gas emissions are integrated across the global atmosphere, it is not possible to 

determine the incremental cumulative impact on global climate from emissions associated with 

any number of particular projects. Nor is it expected that such disclosure would provide a 

practical or meaningful effects analysis for local project decisions. Uncertainty in climate change 

effects is expected since it is not possible to meaningfully link individual project actions to 

quantitative effects on climatic patterns.

It is recognized that global climate change may affect human health, that there is scientific 

controversy surrounding the effects of human activity on climate change, that there is uncertainty 

and unknown risks associated with global climate change. The ultimate effects on climate change 

are indeed the results of incremental cumulative effects of many actions, most of which are 

outside of Forest Service control.

Recreation

Introduction 

Two types of recreation sites are available in the watershed: developed (established facilities) and 

dispersed (scattered, undeveloped areas). The developed sites are used more than dispersed sites. 

55
Sucker Creek Legacy Roads and Trails Project

Grayback/Sucker is the only watershed on the Siskiyou side of the Rogue River-Siskiyou 

National Forest where developed recreation predominates. Several small, undeveloped campsites 

are dispersed throughout the watershed. Some of these have been used since the late 1800s.

The Oregon Caves were discovered in 1873 by Elijah Davidson. In 1909, 480 acres were set aside 

as the Oregon Caves National Monument. The monument is managed by the United States 

Department of Interior National Park Service. Visitor use to the monument gradually decreased

from approximately181,000 people in 1977 to about 100,000 in 1993, however recently visitor 

use has increased. In the 1970s most of the visitors were from non-western states; in more recent

years, almost all visitors are from Oregon, Washington and California (Oregon Economic 

Development Department, 1994).

Affected Environment

Five developed campgrounds are found within this watershed: Bolan Lake, Cave Creek, 

Grayback, Chinquapin (including the historic Cedar Guard Station site of the early CCC camp), 

and the Country Hills Resort. The first four campgrounds are managed by the Forest Service and 

are the only developed campgrounds on the Wild Rivers Ranger District. Country Hills Resort is

privately owned.

The Forest Service campgrounds provide vehicle access and parking, tent pads, firepits, and toilet 

facilities. Grayback and Bolan Lake are accessible to recreational vehicles. Further, the Grayback

Campground is accessible to people with disabilities. It also includes an interpretive trail. 

Camping, picnicking, swimming and hiking are the most popular activities in the campgrounds.

Forest Service campgrounds, with the exception of Bolan Lake Campground, and private

campground serve as overnight facilities for people in route to the Oregon Caves National

Monument.

Wilderness, Backcountry and Botanical Areas

Several areas in the Grayback/Sucker watershed provide for dispersed recreation, however, the 

influx of large numbers of people in the area and motorized vehicle use cause environmental

concerns. The Red Buttes Wilderness—about 3,500 acres of which are in Sucker Creek and

includes the Tanner Lakes and the Boundary Trails—are popular destinations within the 

wilderness. 

The trail system in the watershed evolved from Aboriginal Indian trails. These trails were further

developed by early settlers to serve isolated homesteads and mining areas. Following the creation 

of the Siskiyou National Forest in 1906, many administrative trails were developed primarily for 

fire protection purposes. As development of the area progressed, many miles of trails were 

replaced with administrative, mining and timber sale roads. Recreational use of the still existing 

trails has been growing and now constitutes the primary use of the trail system.

The Boundary Trail crosses two Ranger Districts (Wild Rivers and Siskiyou Mountains) and the

Red Buttes Wilderness. The Boundary Trail is designated as a National Recreation Trail. High 

Divide Backcountry Recreation Area is adjacent to the wilderness. Approximately 2,300 acres are 

designated "Motorized Backcountry" (Siskiyou National Forest LRMP IV-97). Most of the use is 

concentrated on primitive roads, jeep and hiking trails, and dispersed campsites.

Three botanical areas are found in the watershed: Bolan Lake, Bigelow Lakes, and Grayback 

Mountain (see Siskiyou National Forest LRMP Appendix F, Volume I, F-55, 60, 88 for 

descriptions of the areas). Mount Elijah is a popular destination for hikers in the Bigelow Lakes 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Botanical Area. Views from the peak are expansive; it and other peaks are considered sacred sites 

for many people.

Environmental Consequences 

Alternative 1 – No Action

Direct, Indirect and Cumulative Effects

The recreational experience would remain the same and number of visitors would not potentially 

change. There would be no direct, indirect or cumulative effects to recreation under this 

alternative because no project activities are proposed. 

Alternative 2 – Modified Proposed Action

Direct, Indirect and Cumulative Effects

Recreational opportunities would be enhanced with the addition of 3 miles of new trail. No access 

to developed or dispersed recreation sites would be eliminated by implementation of road 

decommissioning, stormproofing or storage through this project. The conversion of roads to trails 

will remove several road stream crossings, which will reduce the potential for future sediment 

delivery from road failures. Therefore, no adverse cumulative effects are anticipated from this 

project when combined with any past, ongoing or reasonably foreseeable future activities.

Red Buttes Wilderness Trail Expansion #1237

The new trail would be developed from the conversion of the 4612098 road into trail. This new 

trail would be the Sucker Creek Tie Trail# 1237A, adding 1.7 miles of new trail to the existing 0.4 

miles. It would provide easier access for equestrian use. This Sucker Creek Tie Trail would give

improved access from the trailhead to the Red Butte Wilderness. The existing Sucker Creek Trail 

#1237 in the wilderness contains stream crossings that are challenging for horses and can cause 

erosion. The new section of the Sucker Creek Tie Trail would have improved stream crossings for 

horses and reduce the potential for erosion. The new trail system would provide access deeper 

into the wilderness and creates a new loop system. 

Lake Mountain Bigalow Lakes Trail #1214 and the Mt. Elijah Tie Trail 1206A

The new trail would be developed from the conversion of the 4611070 road into trail. This would 

add 1.4 miles of new trail to the existing trail system. A new developed trail head would be 

constructed at the beginning of the road conversion adding equestrian trailer turn-around and 

parking. This trail system is an important loop system that connects to Mt. Elijah, Oregon Caves 

and the Boundary Trail.

Visuals

The scenic resources on the Rogue River-Siskiyou National Forest were inventoried under the 

Forest Service’s Visual Management System (VMS) during the late 1970s and have been updated 

as specific projects were identified. This motorized vehicle use designation project is analyzed 

utilizing the VMS in order to maintain the integrity of the original inventory and established 

Visual Quality Objectives (VQOs).

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Sucker Creek Legacy Roads and Trails Project

Introduction

The Siskiyou Forest Plan (1989) states that management activities shall be designed to achieve 

the allocated Visual Quality Objective (VQO) for the area. The Northwest Forest Plan indicated 

that VQOs identified in current Forest Plans would remain. Most land allocations in both the 

Siskiyou Forest Plan and Northwest Forest Plan can be related to each other. VQOs attached to 

the land allocations in the Siskiyou Forest Plan, as amended by the Northwest Forest Plan, are 

now considered the legal minimums for managing the scenic resources.

In 1995, the Scenery Management System was implemented and supersedes the Visual 

Management System which was utilized and incorporated into the Siskiyou Forest Plans (1989). 

Both systems have maintained and enhanced the visual character of National Forests and 

Grasslands since 1974. The newer Scenery Management System, also referred to as Landscape 

Aesthetics, is a further refinement for integrating the benefits, values, desires, and preferences 

regarding aesthetics and scenery for all levels of land management planning on the Forest.

Implementation of all projects on the Rogue River-Siskiyou National Forest will incorporate the 

Scenery Management System. Although, very similar, the Visual Management System is utilized 

for the effects analysis of road stormproofing, decommissioning, closure, and conversion to trail 

on scenic quality for Forest settings.

Affected Environment

Portions of the Forest are visible from several important viewpoints within the Sucker Creek 

watershed, in particular along the Caves Highway (FS Road 4600), other Forest roads and trails.

The majority of the visual land allocations in the Sucker Creek watershed are to retention and 

partial retention. The management goal for these areas is to conduct activities in such a way that 

they are subordinate to the character of the landscape and not evident to the casual forest visitor 

(USDA Forest Service 1989, pages 4-66 to 4-143).

Environmental Consequences

Effects Mechanisms and Analysis Framework

The analysis area to assess direct, indirect, and cumulative effects is confined to the Sucker Creek 

project planning area. This is an appropriate space since the analysis is focused on how well 

activities from the modified proposed action alternative would meet the project planning area’s 

assigned VQOs for affected land allocations.

Alternative 1 – No Action

Direct and Indirect Effects

The scenic quality of the Sucker Creek watershed would not be directly affected by alternative 1. 

The existing condition would persist with no road stormproofing, decommissioning, storage or 

conversion to non-motorized trail.

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Alternative 2 – Modified Proposed Action

Direct and Indirect Effects

The scenic quality of the Forest could be directly affected by alternative 2 (modified proposed 

action). Stormproofing approximately 118 miles of road and converting approximately 3 miles of 

road to trails would involve minor direct impacts related to simple maintenance since the 

travelway already exists. The 31 miles of road that would be put into storage under alternative 2 

would also experience these minor impacts in the future when they are reopened for management 

or emergency access.

Decommissioning approximately 28 miles of road would indirectly affect the scenic quality of the 

Forest. A short section at the beginning of each decommissioned road would be outsloped or 

blocked with another type of barrier to deter illegal use of the road. In the long term, planting or 

natural reestablishment of vegetation on these roadbeds would help develop a more natural 

appearance.

Cumulative Effects

Alternative 2 would not result in substantive cumulative effects to the visual resource. While, 

alternative 2 would remove a few small diameter trees and incur a minimal amount of brushing

during road maintenance, these actions would be insignificant and visually unnoticeable. 

Therefore the effects of the alternative would not combine with past, present, or foreseeable 

future projects to warrant an adverse cumulative effect to visuals or scenic quality.

Fire and Fuels

Introduction

The Siskiyou National Forest Land and Resource Management Plan (1989), as amended by the

2010 Fire Amendment for the Rogue River-Siskiyou National Forest, states that we will manage 

wildland fire in a cost-efficient, timely, and safe manner consistent with land management 

objectives and fire management direction. In that amendment, we are directed to use wildland fire 

to obtain and enhance the ecological characteristics of the area when warranted by conditions.

Affected Environment 

Fire Risk

Open, drivable roads play a role in fire management providing access to fires for initial attack fire 

suppression. Roads are used as suppression lines and anchor points. They also can serve as 

ingress/egress routes for firefighters during active fires. Currently, road maintenance funding has 

declined and many roads are becoming non-drivable because seasonal damage is not repaired. 

Unmaintained, non-drivable roads that have the road profile or template intact can be reopened 

for extended attack fire suppression and to access areas for forest restoration projects.

Lightning occurs in the Sucker Creek drainage area on a low to moderate frequency with usually 

one, sometimes two, lightning storms passing through during the summer months, usually in July 

and August. Typically, but not exclusively, lightning-caused fires occur on ridgetops and upper 

portions of the slopes, burn with low to moderate intensity, and are relatively easy to suppress.

Normal size at control is predominantly less than 0.25 acre.

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Sucker Creek Legacy Roads and Trails Project

Human-caused fires in the area occur with more frequency than lightning fires and typically start 

along the roads. These fires usually range from small to large in size, with corresponding intensity 

and difficulty to suppress. 

As with any fuel type on the Wild Rivers Ranger District, high to extreme conditions can result in 

extreme fire behavior with rapid rates of spread and stand replacement characteristics. 

Historically road access has not made a significant difference in initial attack success under these 

conditions. 

Fire Occurrence

Fire occurrence is the average number of fires in a specified area during a specified time. The

10-year average for Sucker Creek is three fire starts with no recent history of large fires, although 

this fuel type will support large fires in high to extreme fire danger conditions. When initial attack 

is successful, fire size is usually less than 0.25 acres.

Environmental Consequences

Alternative 1 – No Action

There would be no change in the level of maintenance to roads in the Sucker Creek watershed

under the no action alternative. Unmaintained roads would continue to deteriorate through storm 

damage and the growth of vegetation within the road travel way. This would mean the 

continuation of a slowly declining level of road access for immediate initial attack fire 

suppression as vegetation grows and roads close themselves. Most roads would remain available 

for hazardous fuels reduction projects, though some may require repair before use.

Alternative 2 – Modified Proposed Action

Proposed activities for the modified proposed action would reduce some available road access for 

initial attack fire suppression; however, travel corridors for fire suppression would be maintained 

throughout the watershed. Decommissioned roads would still provide foot access, but would

eliminate motor vehicle access. Roads put into storage would be made available if there is a need 

during extended fire operations, and would require heavy equipment to reopen them. Stored 

ridgetop roads would continue to serve as a fire barrier. Mid-slope roads historically provide little 

impediment to fire spread during high fire danger in this terrain and fuel type. Although 

decommissioning roads would reduce access for initial attack fire suppression, aerially delivered 

firefighting resources such as helitack crews, helicopter rappellers and smokejumpers could 

provide an initial attack fire suppression response in those areas when needed. Therefore, no 

effects to fire and fuels are expected from this project. 

Cumulative Effects 

There would be no effects on fire and fuels from project activities, so there would be no 

cumulative effects.

Cultural Resources

Introduction

Protection and management of heritage resources is mandated by federal laws and regulations

identified in the cultural resources report and incorporated by reference here for this project.

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Cultural resource information required for planning projects includes an inventory (existing 

record review and usually a field survey), and consultation with the State Historic Preservation 

Office (SHPO), Indian tribes, local governments, and other interested parties (36 CFR 800.2(c)).

Affected Environment

The Sucker Creek watershed lies within the aboriginal territory of the Confederated Tribes of the 

Grand Ronde Community of Oregon and the Confederated Tribes of the Siletz. The project 

proposal was submitted to these tribes to solicit concerns during the planning phase under a 

government-to-government relationship. No concerns were raised, and no traditional cultural 

properties were identified that would be affected by the modified proposed action alternative

In preparation for the proposed project, a search of Heritage Program reports and site records, and 

application of the Forest’s GIS Heritage layer to the project area, found no recorded cultural sites 

within the project area. However, some of the roads slated for decommissioning may lead to, or 

cross over, existing historic mining-related features where there is a possibility of undocumented 

sites being discovered during field reconnaissance.

Environmental Consequences 

Effects Mechanisms and Analysis Framework

Effects mechanisms serve as tools to quantify effects and offer a basis for comparing the effects 

of management practices. Since there are currently no known sites within the proposed project 

activity areas, possible effects of the proposed action on cultural resources are discussed 

qualitatively, and overall risk is reported in general terms.

The analysis area for cultural resources is confined to the road prisms of road segments proposed 

for treatment. This has been deemed appropriate since the level of risk to the area’s cultural 

resources is directly tied to management practices proposed in this project.

The analysis of environmental consequences is based on the assumption that the project design 

criteria and mitigation measures listed in chapter 2 for cultural resources would be applied during 

implementation.

Alternative 1 – No Action

Direct, Indirect and Cumulative Effects

Under alternative 1, no project activities are proposed, therefore, there would be no direct effects 

to cultural resources. Any as yet undiscovered sites would likely remain undisturbed, although 

there is low potential for indirect and cumulative effects relating to daily use of the forest, 

domestic animal and wildlife activities, natural deterioration, scavenging/artifact collection, and 

catastrophic events such as fire, flood, and landslide. For example, should a road failure cause 

extensive erosion through a site.

Alternative 2 – Modified Proposed Action

Direct and Indirect Effects

Project activities (discussed in chapter 2) would primarily occur within the already heavily 

impacted existing road prisms of roads proposed for treatment. Thus, the potential for direct or 

indirect effects impacting unknown cultural resources is low. However, should any previously 

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Sucker Creek Legacy Roads and Trails Project

unknown sites be found during ground disturbing activities, activity near the find would be 

suspended and a Forest Service Archaeologist or Archaeological Technician would be notified to 

evaluate the discovery and recommend the subsequent course of action.

If any sites are encountered in the course of additional inventory or during project 

implementation, Forest specialists would consult with the State Historic Preservation Office, as 

required by law, to determine the significance of the discovery and potential effects of the project. 

The Confederated Tribes of the Grand Ronde Community of Oregon and the Confederated Tribes 

of the Siletz would be included in these discussions if Native American sites are involved. 

Mitigation would be applied and may include avoidance of the sites, or scientific investigation.

A cultural resource inventory report was completed and submitted to the Oregon State Historic 

Preservation Office under the Programmatic Agreement among the United States Department of 

Agriculture Forest Service Pacific Northwest Region (Region 6), the Advisory Council on 

Historic Preservation, and the Oregon State Historic Preservation Officer Regarding Cultural 

Resource Management in the State of Oregon by the USDA Forest Service (R6 PA), 2004. This 

report found no cultural resources.

Cumulative Effects

When considering past, present, and reasonably foreseeable future actions, this project would not 

exacerbate effects to historic properties. The current condition and trend would continue, which 

protects historic properties through inventory and project design so no historic properties are 

impacted by project implementation.

Hydrology

Introduction

A pilot watershed analysis area inventory, covering the Sucker Creek watershed was conducted in 

1995 and resulted in the Grayback/Sucker Key Watershed Analysis (USDA Forest Service 1995).

The pilot analysis was supplemented with the Grayback-Sucker Watershed Analysis in 1998

(USDA Forest Service 1998). In 2011 the area was analyzed using the watershed condition 

framework process (USDA Forest Service 2010). This analysis found that the Grayback Creek, 

Middle Sucker Creek, and Lower Sucker Creek watersheds are in Condition Class II, functioning

at risk (FSM 2521.1). This rating is due largely to road density, fine sediment in stream channels, 

high summer water temperature, simplification of instream channel habitat, and lack of offchannel habitat. The Upper Sucker Creek watershed was found to be in Condition Class I, 

functioning properly. In response to these ratings a Watershed Restoration Action Plan (WRAP) 

for the Sucker Creek watershed was completed in 2011 and identified both Grayback Creek and 

Middle Sucker Creek as priority subwatersheds. The Sucker Creek watershed is also considered a 

Tier 1 Key Watershed under the Northwest Forest Plan (USDA Forest Service, USDI Bureau of 

Land Management 1994). These analyses are incorporated by reference here.

Affected Environment

Watershed Condition 

According to the WRAP (USDA Forest Service 2011) and Grayback/Sucker Watershed Analysis

(1995), aquatic resources have been altered by past timber harvest, road construction, and placer 

mining operations. In some areas this has led to excessive bank erosion, increased sedimentation, 

and simplified habitat. Channel modifications due to hydraulic mining and other placer operations 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

are especially evident along Sucker Creek. Landslide activity and severe flooding of the 

watershed in 1964 and 1997 accentuated pre-existing channel changes. Many channels exhibit 

disturbance responses such as increased width, elevated water temperature, loss of pool habitat 

due to sedimentation or loss of substrate, loss of side channel habitat due to channel straightening, 

increased channel migration, and loss of channel structure and habitat due to lack of large wood.

To improve stream function and habitat, as recommended in the WRAP, a major stream 

restoration project was completed along both Grayback and Sucker Creeks. The project included 

construction of a new meandering channel, installation of large wood structures, distribution of 

historic mining tailings piles to create floodplains, construction of side channels and other off 

channel habitat, such as rearing ponds and alcoves, spreading of soil on new floodplains, and 

revegetation of floodplains and riparian areas. This project was completed in 2013 and has 

improved stream health, including increasing stream shading and lowering water temperature, 

over approximately 2.5 miles.

Riparian Areas and Wetlands

Riparian vegetation consists of primarily Port Orford cedar, Douglas-fir, incense cedar and some 

ponderosa pine along with hardwoods such as alder, ash and bigleaf maple. Riparian areas 

throughout the watersheds have been impacted by stream cleanout, past hydraulic and placer 

mining activities, logging and roads in the riparian area. These impacts have decreased stream 

shade along the stream systems. Executive Order 11990 (1977) protects riparian areas by 

requiring federal agencies to avoid to the extent possible, the long- and short-term adverse 

impacts associated with the destruction or modification of wetlands. 

Channel Morphology-Stream Channel Characteristics

Streams can be classified into general types by organizing stream feature data into discrete

combinations that typically occur together. The Rosgen classification scheme utilizes stream 

types based on landscape morphology and stream reach characteristics (Rosgen 1996). For each 

stream reach a “most frequent range” of values is given for morphological descriptions, such as 

width-depth ratio (Rosgen 1996). The following descriptions are based on stream surveys and 

descriptions from the WRAP.

The streams along the mainstem of Sucker Creek and lower reaches of Grayback and Caves 

Creeks are “C” channel types (sinuous, low gradient channels; Rosgen 1994). The tributaries are 

mostly “B” (low sinuosity, moderate gradient) and “A” (low sinuosity, high gradient) channel 

types. Sediment and large wood can move quickly during storms from the upper reaches to the 

“C” depositional stream reaches in the mainstem of Sucker Creek and lower Grayback Creek. 

Generally, there is a surplus of sediment and lack of large wood in these areas. The Lower Sucker 

Creek subwatershed contains a wide alluvial valley that is primarily agricultural use. 

Water Quality

Water quality is protected under the Clean Water Act (33 USC 1251-1387), which requires 

maintenance and restoration of the physical, chemical, and biological integrity of waters of the 

United States. The federal government has granted states the regulatory authority to enforce state 

water quality standards and requirements of the Clean Water Act. Sucker Creek watershed 

provides for many state designated beneficial uses. These include domestic water supply, 

irrigation, livestock watering, mining, and cold water biota (salmonid). Water from the Sucker 

Creek watershed is appropriated for irrigation, livestock, industrial and domestic use. There are 

no point source discharges within the Sucker Creek watershed.

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Sucker Creek Legacy Roads and Trails Project

Stream Temperature 

Stream temperature is protected under the Clean Water Act and State Water Quality Standards. On 

March 1, 2004, new water temperature standards were adopted by the State of Oregon (Oregon 

DEQ 2004). The temperature policy of the Commission is to protect aquatic warming and cooling 

caused by anthropogenic activities.

A Water Quality Management Plan (WQMP) was completed for the national forest portion of 

Sucker Creek and for all of Grayback Creek (Blanchard et al. 1998). In this plan, the Oregon 

Department of Environmental Quality established a Total Maximum Daily Load (TMDL) for 

stream temperature. In 2000, a WQMP and TMDL were completed for the remaining BLM and 

private lands. Both plans developed a strategy for maintaining existing stream temperature and 

future recovery through active and passive restoration of stream shade. Based on the WQMP and 

TMDL, Sucker Creek was removed from the 303(d) list in 2000.

Turbidity (Fine Sediment)

Turbidity, or the loss of water clarity, is due to the presence of suspended particles of silt and clay.

Other materials, such as finely divided organic matter can also contribute to the loss of water 

clarity. A large input of fine sediment from the road system has been determined to be an issue in 

the Sucker Creek watershed as detailed in the December 1996/January 1997 Rogue RiverSiskiyou National Forest Flood Report. Fine sediment is prevalent in cobble interspace habitat in 

many stream reaches causing channel widening, water quality impairment, and aquatic 

simplification, particularly in Grayback Creek and the depositional reaches of Sucker Creek. The 

road system contributes fine sediment in several ways, including road-related slope failures, 

chronic sediment delivery, road drainage problems, and increasing the channel network through 

in-sloped roads and ditches. 

Pacific Watershed Associates measured the potential for both chronic and episodic sediment 

delivery from road systems that could impact stream channels. As seen in table 6, the potential 

future sediment input they measured is very high in all the watersheds and will continue to add 

fine sediment to the stream systems during high flow events (Weppner and Weaver 2010, 2013).

Table 6. Current road impacts by watershed, including miles of road, road density, percent of road 

within 300 feet of streams and potential future sediment yield to stream channels

Watershed Name

Area within 

NFS 

Boundary

(mi2

)

Miles of 

NFS road

Road Density 

on NFS land

(mi/mi2

)

Percent of 

NFS Road 

within 300 

feet of 

streams

Potential 

future 

sediment yield 

(yds3

)

Grayback Creek 24.2 51.1 2.1 39 55,515

Lower Sucker Creek 4.3 12.4 2.9 36 4,929

Middle Sucker Creek 22.7 84.2 3.7 37 111,556

Upper Sucker Creek 23.0 40.3 1.8 38 73,521

Total for Sucker 

Creek watershed 74.2 188.0 3.4 38 245,521

Sedimentation (Coarse)

Sediment delivery to stream channels from roads and road networks has been regionally 

documented and is recognized as a significant impediment to watershed health and salmonid 

habitat (Cederholm et al. 1981; Furniss et al. 1991; Harr and Nichols 1993; Flosi et al. 1998; 

NMFS, 2001; Suttle et al. 2004). Erosion prevention through stormproofing rural, ranch, and 

forest roads provides immediate benefits to the streams and aquatic habitat of a watershed 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

(Weaver and Hagans, 1994; Nature Conservancy 2010). It diminishes the impact of road-related 

erosion on the biological productivity of the watershed's streams and allows future storm runoff to 

transport accumulated coarse and fine sediment rather than continuing to allow accelerated 

anthropogenic erosion and sediment delivery from managed areas. The combination of intense

rainfall, rapid snowmelt and steep colluvial filled channels results in high rates of erosion and 

sediment delivery from debris flows and debris torrents. These mass wasting processes often 

initiate at or upslope from roads and act to deliver sediment to stream channels, increasing 

sediment deposition and triggering bank erosion, channel scour, culvert plugging, stream 

diversions and subsequent road failures, mass wasting and erosion. 

Past, Present and Future Actions

The project interdisciplinary team (IDT) identified past actions that might have cumulative 

impacts with the proposed action early in the analysis process. Past timber harvest, road 

construction, mining, and natural flood events have affected the existing condition in the analysis 

area. Past timber harvest and road construction have increased water yields, extended the channel 

network, and increased sedimentation to the stream system through connected disturbed areas. 

These actions are discussed below. 

Timber Harvest

Regeneration harvest and associated road construction has occurred throughout the watershed. 

Approximately 30 percent of the National Forest System lands have been harvested since 1940. 

Historical harvest activities included stream clean-out operations that removed large wood and 

resulted in construction of a high road density. Past timber harvest impacted riparian vegetation 

by clearing large wood from along the stream channels. This had multiple impacts on stream 

condition including, decreasing shade and increasing temperature; removing large wood creating 

more simplified in-stream habitat; and increasing stream erosion and widening due to loss of 

riparian vegetation. Harvest rates on the National Forest System lands in the Sucker Creek 

watershed have slowed substantially since 1990, allowing forest canopy to become reestablished 

in managed stands.

Roads

Although roads facilitate the use and management of natural resources, roads may also result in 

adverse changes in watershed processes. The road system contributes to aquatic habitat 

degradation in several ways including, road-related slope failures generating sediment or 

aggravating existing landslides; road drainage increasing routes for sediment to enter channels; 

and culverts often acting as barriers to fish passage. Roads can alter hydrologic processes that 

influence geomorphic processes such as sediment transport, sediment delivery, and mass-wasting.

Roads can impact hillslope hydrology by transforming slower subsurface flow to rapid surface 

flow, which may alter the synchronization of hillslope runoff to the stream channel. Roads are 

relatively impermeable surfaces that increase both peak rates and runoff volumes. This increased 

runoff facilitates gully development below road drainage structures such as ditch relief culverts, 

waterbars, or rolling dips creating continuous flow paths into streams. Roads can also divert 

existing stream channels into road ditches when culverts become blocked by debris (i.e., stream 

piracy; Wemple et al. 2001). Culvert plugging has been found to be the largest source of sediment 

delivery to stream systems (USDA 1998, Weppner and Weaver 2010, 2013). 

There are approximately 200 miles of road within the Sucker Creek watershed. The average road 

density in the watershed is 3.4 miles per square mile, which is generally considered to be at high

risk levels for generating cumulative watershed effects. The 2010 Forest Service Watershed 

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Sucker Creek Legacy Roads and Trails Project

Condition Classification (WCC) Guide identifies a threshold of 2.4 miles per square mile where 

“the density and distribution of roads and linear features in the watershed indicates that there is a 

higher probability that the hydrologic regime (timing, magnitude, duration, and spatial 

distribution of runoff flows) is substantially altered (USDA Forest Service 2010).” 

Approximately, 38 percent of the road length is within 300 feet of streams which increases the 

probability that the road system is hydrologically connected to the stream network. According to 

the WCC watersheds with more than 25 percent of the road length within 300 feet of streams are 

likely to be in poor condition or have impaired watershed function (ibid.). The WRAP identified 

road restoration including stormproofing, decommissioning, and putting roads into storage as 

essential projects for improving watershed condition throughout the Sucker Creek watershed 

(USDA Forest Service 2011).

Pacific Watershed Associates collected data on the road system within Sucker Creek watershed as 

documented in the Grayback Creek Sediment Source Assessment and Sediment Control Plan and 

2013 Phase II Sucker Creek Sediment Source Assessment and Sediment Control Plan. The 

Grayback Assessment surveyed nearly 69 miles of road and determined that a total of 234 

individual sites and approximately 29 miles of paved, rock surfaced and unsurfaced roads and 

associated ditches and cutbanks either were currently eroding and delivering sediment to streams 

in the project area, or showed a potential to do so in the future (Weppner and Weaver 2010).

Phase II of the assessment surveyed the other three subwatersheds within the Sucker Creek 

watershed. This inventory collected data on 139 miles of road and determined that a total of 482 

sites and 59.5 miles of hydrologically connected road surfaces have potential to deliver sediment 

to streams. Stream crossings, especially those with undersized culverts, represented the most 

important sites for future road failures throughout both assessment areas (Weppner and Weaver 

2013). Total chronic sediment delivery from roads to the stream system was estimated at 28,000 

cubic yards over a 10-year period, with episodic sediment delivery being much greater at 

approximately 245,000 cubic yards as seen in table 7 (Weppner and Weaver 2010, 2013).

In addition to producing sediment, culverts can also block passage of aquatic organisms, such as 

fish and the foothill yellow-legged frog. There are five culverts within the Middle Sucker Creek 

watershed that are considered barriers for migration of juvenile steelhead and one that is a barrier 

for juvenile rainbow trout. The Grayback Creek watershed has two culverts considered barriers; 

one for juvenile steelhead and one for juvenile cutthroat trout.

Past Flood Events

The December 1996/January 1997 storm and flood was estimated to be a 25-year hydrologic 

event in Sucker Creek. This flood event provided a good source of data for evaluating 

susceptibilities of the road system within the Sucker Creek watershed to erosional events, 

identifying the downstream effects, and for reducing the frequency and magnitude of road failures 

during future storm events. The vast majority of road damage sites in 1996 were associated with 

culverts and stream crossings. Culvert plugging was over twice as common as the second leading 

cause of road failure, accounting for 43 percent of all road failure sites. The other causes included 

fill failure by stream undercutting, culvert plugging by debris torrents, fill failures not at stream 

crossings, cutbank failures, and exceedence of culvert capacity (USDA Forest Service 1998).

High flood flows in many streams mobilized stored sediment and woody debris that then passed 

through the culvert, exceeded culvert capacity or plugged culvert inlets. Culvert exceedence and 

plugging in turn caused ponding, overtopping and crossing failure (washout) or stream diversion. 

Stream diversions led to gullying, landsliding and other cascading effects where small failures 

high in the watershed produced or contributed to increasingly large failures farther down the 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

hillside. For example, stream diversions frequently resulted in plugging of multiple ditch relief 

culverts, ditch scour, hillslope landslides and/or gullies. These processes resulted in greatly 

increased sediment delivery to the stream system.

Some road treatments have occurred to reduce the downstream impacts of future floods, but much 

of the road system has yet to be proactively treated. Roads that have already received

decommissioning treatments are dispersed throughout Sucker Creek Legacy Roads project area. 

These roads are typically overgrown and have been partially or completely decommissioned by 

removing culverts and excavating road fill at stream crossings, and constructing waterbars or 

cross road drains (large dips) on the road surface. However, in some locations the standards for 

effective road decommissioning were not followed and erosion is continuing (Weppner and 

Weaver 2010).

Mining

Placer gold mining, including historic and modern suction dredging has degraded stream channel 

structure and function. Historic mining operations straightened stream channels and created 

simplified in-stream channel habitat. Modern suction dredging activities work the streambed rearranging gravels into loose piles, creating an unstable stream bed. 

Peak Flows

Some researchers believe that there is a synergistic effect between roads, harvest, and peak flows.

Taken collectively, results of watershed studies indicate that the size of peak flows may be 

increased, decreased, or remain unchanged after logging. Whether or not a change occurs depends 

on what part of the hydrologic system is altered, to what degree, and how permanent the 

alteration is (Thomas and Megahan 1998). See the hydrology report for more information on 

these peak flow studies.

Environmental Consequences 

Effects Mechanisms and Analysis Framework

The Environmental Consequences were evaluated using multiple effects mechanisms to describe 

impacts to hydrologic resources associated with sediment delivery to streams from the road 

system resulting in impacts to water quality. These include:

♦ Potential sediment delivery to streams in cubic yards

♦ Road density in miles per square mile

♦ Percentage of road within 300 feet of streams

♦ Number of road stream crossings

♦ Number of culverts removed or replaced

Watershed effects were described using 6th field subwatersheds within the larger Sucker Creek 5th

field watershed. Watersheds were not analyzed beyond the Forest boundary due to a lack of data 

regarding past and present management actions, and watershed conditions off the Forest.

Potential Sediment Delivery

Potential sediment delivery to streams was determined using data collected by Pacific Watershed 

Associates and documented in the Grayback Creek Sediment Source Assessment and Sediment 

Control Plan and 2013 Phase II Sucker Creek Sediment Source Assessment and Sediment Control 

Plan. Their field inventory consisted of an assessment of all road-related erosion sites and road 

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Sucker Creek Legacy Roads and Trails Project

segments showing evidence for existing or potential erosion and sediment delivery to the stream 

system. The assessment did detailed field measurements to estimate, among other things, 

potential sediment delivery to streams. A total of 465 stream crossings sites were inventoried. For 

each site, the fill dimensions were measured and used to calculate road fill and potential sediment 

delivery volumes with the STREAM computer program. 

Removal of road stream crossings requires that all of the fill material over the culvert be removed 

and the width of the channel and banks be created to mimic the shape above and below the 

culvert. During this process a small amount of material is lost or spilled into the stream channel. 

As the newly restored stream channel goes through the first high flows, some channel adjustment 

may occur, also resulting in a small amount of material delivered to the stream. To account for 

this it was assumed that 10 percent of the total material removed in the fill could be delivered to 

the stream channel from removing the road stream crossing. This most likely is an over estimate 

of what would actually occur. 

A 65 percent reduction in sediment delivery was estimated for treatments at all sites contributing 

sediment that are not associated with a culvert on decommissioned and storage roads as well as 

on all roads proposed for stormproofing (Nelson et al. 2012). 

Road Calculations

All other indicators, including road density, percent of road within 300 feet of streams, number of 

road stream crossings, and number of culverts removed were analyzed using GIS data and layers 

from the Rogue River Siskiyou National Forest as well as data from the Pacific Watershed 

Associates reports and databases (Weppner and Weaver 2010, 2013). 

Alternative 1 – No Action

Direct and Indirect Effects

Under this alternative the existing condition would remain the same. No decommissioning or 

storage treatments would occur; however, normal road maintenance could still be done on level 2 

and 3 roads. Level 2 roads are considered a low priority and the likelihood of road maintenance 

occurring on these roads is very low. It was assumed that no treatments would occur on these 

roads under this alternative. Level 3 roads could receive road maintenance treatments as funding 

allowed. There is no way to determine which roads would be treated; therefore, all level 3 roads 

were assumed to have road maintenance treatments done, reducing potential sediment delivery to 

the stream channel. However, due to funding the amount of treatment would likely be less than in 

alternative 2. 

The existing roads would be managed in their current state, and would continue to affect hillslope 

hydrology, act as connected disturbed areas, and degrade water quality. Road densities would 

remain the same as summarized in table 7, and there would be no reduction in road segments 

adjacent to stream system. There would be a reduction in sediment transport to the stream system 

if maintenance was done on all level 3 roads. The high potential sediment yield especially within 

the Middle Sucker Creek, Upper Sucker Creek, and Grayback Creek watersheds indicate that 

these areas have been and will continue to be impacted by high sediment input to the stream 

system. 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Watershed Condition

Watershed condition would not be improved in either of the priority sub-watersheds. The resource 

concerns associated with roads in the WRAP (2011) would not be addressed. Subwatersheds that 

are currently functioning at risk would remain in this condition and may be further degraded if a 

large storm event causes a substantial pulse of sediment to the stream system. 

Riparian Areas and Wetlands

There would be no impacts to riparian areas and wetlands above those already occurring from 

mining operations under this alternative.

Channel Morphology

It is likely that impacts to channel morphology would occur under this alternative. Due to the 

high potential for sediment delivery to the stream network from the existing road system, a large 

flood event could impact channel morphology, causing pool filling, and channel widening and 

instability.

Water Quality

Temperature and Dissolved Oxygen

No increase in stream temperature is expected. Dissolved oxygen levels are dependent on stream 

temperature. An increase in temperature could decrease the water’s dissolved oxygen levels. 

Since no increase in stream temperature is expected there would be no change in dissolved 

oxygen. Alternative 1 would not affect temperature or dissolved oxygen concentrations. 

Hazardous Materials

With no road decommissioning or storage treatments and only the replacement of some culverts 

on level 3 roads, there would be no increased risk to hazardous materials entering the stream 

system4

. 

Turbidity and Sedimentation

Both chronic and episodic sediment delivery would continue to occur from stream crossings, 

landslides, ditch relief culverts and other sources. There are approximately 480 stream crossings 

within the Sucker Creek watershed. No culverts at road stream crossings would be removed, 

however some replacements would occur on level 3 roads. With little road maintenance occurring 

culvert inlets may plug. This would decrease the culvert’s carrying capacity during storm events 

so the water would overtop the culvert fill washing it out. The material, both fine and coarse 

sediment, would be transported downstream increasing turbidity and coarse sedimentation in the 

stream system. Failure of both stream crossings and road ditch culverts during storm events

would result in a total of approximately 224,000 cubic yards of sediment being delivered to the 

stream system within the Sucker Creek watershed. 

There would be a slight reduction in sediment supply due to stormproofing/maintenance on 

approximately 25 miles of level 3 roads. The amount of reduction would depend on the type of 

maintenance that is performed. It has been shown that stormproofing treatments reduce sediment 

4 Any treatments involving heavy equipment near the stream channel create a chance of fuel or hydraulic 

fluid spilling into the stream channel. Best management practices and contract specifications would 

mitigate any potential spill from entering a live stream during project activities for alternative 2.

69

 
Sucker Creek Legacy Roads and Trails Project

yield to streams by approximately 65 percent (Nelson et al. 2012), which would be approximately 

63,000 cubic yards. 

It is unlikely that all of the sites would fail during the same storm event, but several could fail at 

one time. The sediment from this type of failure would fill stream pools and change the 

composition of spawning gravels located downstream of failed sites.

With no reduction in the road system, current impacts to hillslope hydrology would continue to 

affect subsurface flow. The high amount of connected disturbed area associated with gully 

development below drainage features would remain and continue to increase flow and sediment 

load within the stream network. The road density and percent of road near a perennial stream 

would remain high. A higher road density would also increase the likelihood of road related slope 

failures especially in the Grayback Creek watersheds, where landslides currently have potential to 

contribute over 4,000 cubic yards of sediment to the stream system.

Cumulative Effects

Hydrologically, past and present actions influencing cumulative effects include past flooding, 

timber harvest, current and historic mining, road building, and stream restoration as discussed 

under the affected environment section. Reasonably foreseeable actions include continued 

hydraulic mining and potential timber harvest. With any ground disturbing activity, there is the 

potential for increased erosion and delivery of sediment to the stream system. With the high 

sediment loads currently present within the watershed any additional sediment yield would 

detrimentally impact watershed health. Alternative 1 would not be consistent with the Aquatic 

Conservation Strategy as detailed in chapter 4, and would impact stream and watershed health.

Alternative 2 – Modified Proposed Action

Direct and Indirect Effects

Proposed activities under alternative 2 include approximately 28 miles of road that would be 

decommissioned, 31 miles would be put into storage and 3 miles would be converted to nonmotorized trail. Another 118 miles would be stormproofed, which is 76 miles more than would 

occur under alternative 1 normal maintenance schedule. 

Table 7. Resulting miles of road, road density, percent of road within 300 feet of streams and 

potential future sediment yield to stream channels for alternative 2.

Watershed 

Name

Area within 

NFS 

Boundary

(mi2

)

Miles of 

NFS 

road

Road 

Density on 

NFS land

(mi/mi2

)

Percent of 

NFS Road 

within 300 

feet of 

streams

Potential 

future 

sediment 

yield (yds3

)

Percent 

change in 

potential 

sediment 

yield

Grayback 

Creek 24.2 48.3 2.0 38 16,599 70

Lower Sucker 

Creek 4.3 10.5 2.4 34 1,462 70

Middle Sucker 

Creek 22.7 67.1 3.0 29 30,295 73

Upper Sucker 

Creek 23.0 33.1 1.4 34 22,176 70

Total for 

Sucker Creek 

watershed

74.2 159.0 2.1 33 70,532 71

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Under the modified proposed action road densities would decrease, and there would be a 

reduction in road segments adjacent to stream systems and a reduction of potential sediment 

delivery to stream systems of approximately 70 percent as shown in table 7. 

Watershed Condition

Watershed condition would be improved by reducing road density and removing culverts, which 

would address the essential projects in the WRAP that are recommended as necessary to improve 

watershed condition (USDA Forest Service 2011). The road density on NFS lands would be 

reduced to 2.1 miles per square mile, which is below the 2.4 miles per square mile threshold set in 

the WCC and would move this attribute from poor to functioning at risk. The percent of road near 

a perennial stream would be lowered to 33 percent, which is still high. However, with the removal 

of high-risk culverts, road decommissioning, storage, and stormproofing the potential sediment 

yield from these roads would be greatly decreased (Nelson et al. 2012, Weppner and Weaver 

2010, 2013). Watershed condition in the subwatersheds classified as functioning at risk would 

move toward and possibly attain proper functioning condition. 

Riparian Areas and Wetlands

Riparian areas may be improved under this alternative. Approximately 9 miles of road would be 

decommissioned within 300 feet of the stream corridor. These treatments would help to improve 

subsurface flow, reduce sediment delivery, and reintroduce riparian species. 

Channel Morphology

Channel morphology would be improved, especially at approximately 108 proposed road stream 

crossing removal locations. Road crossings that are decommissioned would have stream channels 

rebuilt to mimic the upstream and downstream morphology allowing for a connection in flow 

through these sites which once were unnaturally impacted often through narrowing of the stream 

channel by undersized culverts. Future impacts to channel morphology would be reduced by 

decreasing sediment input and the risk of pool filling, and channel widening and instability.

Water Quality

Hazardous Materials

Heavy equipment used for decommissioning could potentially spill hydraulic fluid or fuel. Best 

management practices and project design criteria would mitigate any potential spill from entering 

a live stream channel. 

Turbidity and Sedimentation

No increase in turbidity is expected from decommissioned or stored roads during storm events. 

The small amount of sediment from removal of the culverts would cause some localized, shortterm and very small increases in turbidity. To ensure turbidity is not increased from roads put into 

storage all fill removed from stream crossings will be moved to an upland location away from the 

stream channel. 

Potential sediment yield off of decommissioned and storage roads would be reduced by 

approximately 35,000 cubic yards as shown in table 8. The reduction from stormproofing 

treatments above those considered in alternative 1 would be approximately 55,000 cubic yards 

(table 9). The total percent change in sediment yield with all treatments would be approximately 

70 percent (table 8), or 44 percent above that possible under alternative 1. A detailed analysis of 

potential sediment yield from each road is shown in table 4.

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Sucker Creek Legacy Roads and Trails Project

Table 8. Summary of potential sediment delivery to the stream system from decommissioning and 

storage treatments

SubWatershed Treatment

Miles of 

road 

treated

Number 

of 

culverts 

removed

Potential 

sediment 

delivery 

from 

culvert 

failures

Potential 

sediment 

delivery 

during and 

post decom 

(yds3)

Potential 

sediment 

delivery 

from other 

road 

impacts

(yds3)

Reduction in 

potential 

sediment 

delivery from 

Alternative 1

(yds3)

Grayback 

Creek

Decom. 3 2 0 38 6 358

Storage 13 20 183 501 840 4,511

Lower 

Sucker 

Creek

Decom. 2 0 0 0 175 324

Storage 3 10 0 106 284 949

Middle 

Sucker 

Creek

Decom. 18 29 0 585 1,326 7,656

Storage 9 15 9 641 890 5,773

Upper 

Sucker 

Creek

Decom. 5 18 3 1,109 0 9,949

Storage 6 8 6 222 0 1,999

Total

Decom. 28 49 3 1,732 1,507 18,287

Storage 31 53 198 1,470 2,015 16,972

Table 9. Summary of potential sediment delivery to the stream system from stormproofed roads

Sub-Watershed

Miles of 

road 

treated

Potential 

sediment 

delivery 

before 

treatment 

(yds3

)

Alternative 

1: potential 

sediment 

delivery 

after 

treatment of 

Level 3 

roads 

(yds3)

5

Alternative 2: 

potential 

sediment 

delivery after 

all road 

treatments 

(yds3

)

Reduction in 

potential 

sediment 

delivery from 

Alternative 1 

(yds3

)

Grayback Creek 35 42,945 22,553 15,031 7,522

Lower Sucker 

Creek 6 2,564 2,564 897 1,667

Middle Sucker 

Creek 49 76,697 40,207 26,844 13,363

Upper Sucker 

Creek 27 59,558 53,308 20,845 30,463

Total 117 181,764 118,632 63,617 55,015

Roads

The modified proposed action would improve infiltration, hillslope hydrology, stream health, and 

water quality. With a reduction in the road system, impacts to hillslope hydrology and infiltration

would be reduced especially on roads decommissioned using “Level a” treatments, improving 

subsurface flow. There would be a reduction in the extended channel network associated with the 

current road system, reducing the amount of connected disturbed area and sedimentation to the 

5 Level 3 roads were assumed to be treated with normal maintenance under Alternative 1.

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

stream system. Since culvert plugging contributes the greatest amount of sediment to the stream 

system (USDA Forest Service 1998) removing over 100 culverts will greatly reduce the risk of 

large sediment pulses to the stream system. 

Cumulative Effects

This alternative would reduce adverse cumulative effects by decreasing potential sediment yield 

to the stream system, improving hillslope hydrology and dispersed subsurface flow, and 

decreasing the extended channel network associated with the current road system. The proposed 

treatments would help reduce the cumulative effects of past road construction and ground 

disturbance on watershed function. With decreased sediment yield, the effectiveness of the 

watershed restoration projects would be maintained. Essential projects discussed in the WRAP 

associated with road decommissioning would be added to those already completed with the 

stream restoration project (USDA Forest Service 2011) moving the watersheds that are currently 

functioning at risk toward, and possibly attaining, proper functioning condition. The modified 

proposed action is consistent with the Aquatic Conservation Strategy as detailed in chapter 4 and 

watershed conditions would improve. 

Peak Flows

Based on the hydro-regions developed by Grant et al., the project area would be located in the 

transitional hydro-region. For basins within the transitional zone, Grant et al. found that the 

detection threshold for changes in peak flows occurs at 20 percent of watershed area harvested.

Thus, changes in peak flows cannot be detected at harvest levels of less than 20 percent. Further, 

Grant et al. found that peak flow increases decrease with decreasing percent of basin area 

harvested (Grant et al. 2006). Any trees lost from road decommissioning, storage and 

stormproofing activities would not be large enough to affect the overall watershed vegetation 

composition. Any conifers removed that are greater than 18 inches in diameter would be used for 

stream restoration projects throughout the Forest. It would be preferable to keep root wads 

attached to any trees that will be used for stream restoration. 

Megahan did a reanalysis of methods and data used by Jones and Grant (1996). Peak flows were 

increased up to 90 percent for the smallest peak events on the clear-cut watershed and up to 40

percent for the smallest peak flows on the patch-cut and roaded watershed. Percentage treatment 

effects decreased as flow event size increased and were not detectable for flows with a 2-year 

return interval or greater on either treated watershed. Treatment effects decreased over time but 

were still found after 20 years on the clearcut watershed but for only 10 years on the patch-cut 

and roaded watershed (Megahan 1998). On the basis of this assessment of the small watershed 

treatment effects, there is little support for concluding that forest roads had an inordinate effect on 

peak flows on the patch-cut and roaded watershed. Neither of the alternatives will affect peak 

flows.

Soil Resources

Introduction

The Grayback/Sucker Pilot Watershed Analysis (USDA Forest Service 1995) provides a detailed 

description of the physical setting of the Sucker Creek 5th field watershed, including climate, 

geology, soils, and landforms, and is incorporated by reference into this analysis. Please refer to 

this document for more detailed information.

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Sucker Creek Legacy Roads and Trails Project

Affected Environment

Soils are developing under a climate of moist, cool winters and warm dry summers. The 

relatively warm, humid climate promotes deep weathering of bedrock to soils. Soils in the 

analysis area have been mapped by the Natural Resources Conservation Service, as part of the 

Josephine County soil survey (SCS 1983; NRCS Web Soil Survey at 

http://websoilsurvey.nrcs.usda.gov/). Within the Sucker Creek watershed, there are 63 different 

soil map units. For this analysis, soil map units are combined and discussed based upon the 

common parent materials that formed the soils. Acres of major soil-parent material groups in the 

watershed are displayed in table 10. Figure 7 visually displays the locations of different soilparent material groups, as well as the soil survey map units. 

Table 10. Acres of each major soil-parent material group in the Sucker Creek watershed.

Soil Group by Parent Material Acres (approximate) in the Sucker 

Creek watershed

Alluvially influenced soils 3,025

Metasedimentary-metavolcanic soils 41,231

Mix, serpentine and metasediment/metavolcanic soils 1,072

Peridotite-Serpentinite soils 865

Granitic soils 15,100

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Figure 7. Soils by major parent material

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Sucker Creek Legacy Roads and Trails Project

Figure 8. Soil depths in the Sucker Creek watershed

Figure 9. Erosion hazard rating in the Sucker Creek watershed

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Past and Present Actions

The project ID team identified past actions that might have cumulative impacts with the proposed 

action early in the analysis process. These actions are described below. 

Past Roads Impacts to Soil

Effects of roads on slope stability can include road-related slope failures, typically from fill-slope 

failures that create landslides or slumping, or cut-slope failures due to undercutting the toe of an 

unstable slope. Cut-slope failures can be acute failures, or create slow moving slumps. In 

addition, when a natural landslide or debris torrent occurs, roads can exacerbate downslope 

erosion through the addition of volumes of road fill in the path of the slide when the road prism 

fails. Roads can also exacerbate hillslope failures when debris flows are diverted down a road 

prism and shedded onto a new hillslope location. Much of the early road building included the 

side-casting of material, which often resulted in increased fillslope instabilities as compared to 

modern road building practices that do not allow side-casting.

Pacific Watershed Associates conducted road-related sediment source assessments for the 

Grayback Creek subwatershed and the rest of the Sucker Creek watershed in 2010 and 2012, 

respectively (Weppner and Weaver, 2010; Weppner, 2012). In these assessments, they identified 

29 locations of road-related landslides in Grayback Creek subwatershed, and 71 locations in the 

rest of Sucker Creek watershed. Through field observations during the road-related sediment 

source assessments, roads traversing hillslopes of 45 percent or greater were highlighted as being 

at an increased risk for additional road-related failures in the future (Weppner and Weaver, 2010). 

Of the roughly 195 miles of road in the Sucker Creek watershed, approximately 116 miles are 

traversing hillslopes of 45 percent or greater. Of that, approximately 70 miles of road is on slope 

grades of 75 percent or greater.

Where roads traverse the steep slopes of glacial till (soil map units 10E and 10F in the Sucker 

Creek watershed), shallow groundwater is often intercepted due to the compacted till layer and 

converted to surface flows. This intercepted groundwater has caused road cut and fillslope 

instability and erosion issues in the past, requiring engineered rock designs for slope stability and 

installation of more drainage features. Roads that have sections which traverse through these soils 

include: 4611, 4611-070, 4611-079, 4611-969, 4611-988, 4612-098, 4612-472, 4612-540, 4703, 

4812-041, 4812-538, 4812-539, and 4812-540. 

Roads have not been identified as causing increased instability in deep seated earthflows in the 

watershed. However, it has been identified that where the 4611-910 road and spurs traverse 

through a deep seated earthflow in the Grayback Creek subwatershed, the natural instability of 

the inner gorges of stream channels during saturated soil conditions make it difficult to costeffectively design and maintain a road system with permanent stream crossings. Currently, the 

stream crossing on the 910 spur near the junction with 4611-019 is blown out and impassible. 

The effect of roads on soil productivity is a total soil resource commitment to manage an area for 

some other use than supporting the growth of otherwise desired plant communities; in this case, 

committing an area to a “non-productive” road prism for the foreseeable future. The acres of soil

in the Sucker Creek watershed currently committed to forest roads instead of site productivity is 

approximately 338 acres (0.5 percent of the watershed). 

Effects of roads on soil erosion can include sheetwash and channelization of flows down the road 

bed from ruts, causing rilling and gullying of native soils. Native surfaced roads are especially 

susceptible to soil erosion since the native soil in the roadbed is exposed to precipitation, and 

77
Sucker Creek Legacy Roads and Trails Project

directly impacted by vehicle traffic. Road surfacing, such as crushed aggregate or pavement, acts 

as a kind of “effective groundcover”, protecting the underlying native soils from erosion 

processes. Accumulation of litter and re-establishment of vegetation on the roadbeds of closed 

and decommissioned roads also reduce the risk of road surface erosion over time. Effective 

surfacing of roads and proper drainage to prevent channelization of surface flows down the 

roadbed, is particularly important in the Sucker Creek watershed, where the overwhelming 

majority of soils have a severe erosion hazard risk rating for roads and trails. Currently there are

roughly 38 miles of native surfaced roads in the Sucker Creek watershed. In addition, many roads 

that have historically been surfaced with crushed aggregate are in various states of aggregate loss 

due to deferred maintenance and road disrepair.

Past Timber Harvest Impacts to Soil

It is commonly accepted that clearcutting, particularly on steeper slopes, can lead to accelerated 

soil creep and increased mass wasting due to the loss of mechanical soil-to-bedrock 

reinforcement by the root system, and increased soil moistures. Roads in the path of slope failures 

off of clearcut stands often increased the damage of the debris torrents through diverting flows 

and/or blowing out and adding volumes of fill to the debris flow. An example of a historic debris 

torrent that appears to have been triggered at least in part by a clear cut is in the Upper Sucker 

Creek subwatershed. The 2012 Sucker Creek Sediment Source Assessment documents a 

relatively recent (likely triggered by the 1997 winter storm event) debris torrent at Site 616 on 

NFS road 4612-540, and aerial photos indicate an old clear cut at the head of this failure, which 

had blown out the road but had since been rebuilt at the crossing. The location of this failure is in 

granitic soils on a steep glacial sidewall. 

Past harvest practices also had little guidance or understanding of effects to soil productivity 

through compaction or displacement, and site preparation methods often resulted in a lack of 

residual organics to provide effective groundcover to protect the soils from erosion.

Past Mining Impacts to Soil

Mining in the watershed has been focused on gold, consisting mostly of hydraulic and suction 

dredge mining along stream channels. Effects to slope stability, soil productivity, and soil erosion 

has been primarily limited to disturbance on stream terraces, banks, and channels, and has had 

minor impacts to soils and slope stabilities when compared to natural processes and effects from 

other management activities.

Environmental Consequences 

Effects Mechanisms and Analysis Framework

The analysis area for slope stability, soil productivity and erosion consists of the locations of the 

roads being analyzed in this EA, since effects to a particular soil is typically localized to defined 

areas where direct and indirect effects can be measured. This analysis also takes into account the 

soils upslope and downslope of these roads, in particular where slopes are 45 percent or greater in 

slope, and/or have in the past or have the potential in the future, for slope instability. 

The environmental consequences were evaluated using multiple effects mechanisms to describe

impacts to slope stability, soil productivity, and erosion hazard from the road system. These 

include:

♦ Miles of open and closed roads traversing slopes of 45 percent or greater;

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

♦ Treatments on roads traversing glacial till soils (soil map units 10E, 10F);

♦ Acres of land put back into soil productivity for desired plant communities;

♦ Reduction of erosion hazard potential: miles of native-surfaced roads per proposed 

treatment.

The Grayback Creek and Sucker Creek Sediment Source Assessments (Weppner and Weaver, 

2010; Weppner, 2012) focused on road-related erosion and impacts to fish bearing streams; 

therefore erosion sites with no potential sediment delivery to streams were excluded. Also, only 

potential and existing landslides related to road systems were included in the inventory. Since 

predicting the exact locations of future potential road-related failures is difficult to predict or 

quantify, this analysis assumes that roads traversing hillslopes with slopes of 45 percent or greater 

are at a greater risk of potential failures, as this slope break was identified in the sediment source 

assessments as increasing risk.

We assume in this analysis that decommissioned roads are on a trajectory of soil productivity 

recovery, utilizing varying degrees of active and passive restoration; therefore their total acreages 

are not included in the total amount of land taken out of productivity. Roads that are put into 

storage (i.e. closed, maintenance level I), are still considered committed to something other than 

soil productivity because it is expected that these roads would be re-opened in the next 10 to 20

years, so any restoration of site productivity in the interim is temporary.

It is assumed that surfaced roads (such as pavement or crushed aggregate) provide effective 

erosion control to prevent native soil erosion of roads, as this cap acts as a form of effective 

groundcover that protects the underlying native soil particles from becoming detached and 

transported by precipitation or wind.

Slope ranges were generated in ArcMap by utilizing the “Slope (Spatial Analysis) Tool”, which 

identifies the slope (gradient, or rate of maximum change in z-value) from each cell of a raster 

surface, in this case the hill shade raster. The “Reclassify (Spatial Analyst) Tool” which 

reclassifies (or changes) the values in a raster, was then used to get the specified ranges.

Alternative 1 – No Action

Direct and Indirect Effects

Slope Stability

Under this alternative, the total amount of National Forest System roads traversing slopes of 45

percent or greater would remain at approximately 116 miles. Roads on these steeper slopes would 

continue to be at risk from fillslope failures and initiation of debris torrents over time. Locations 

of potential failures would not always be predictable, but some would develop cracks and slumps 

that would indicate a likely future failure upon inspection. These indicators could provide the 

potential for road maintenance to prevent the failure, but there is the potential that not all of these 

locations would get found and maintained in time to prevent failures, due to the current and 

foreseeable future predicted budget forecast for road maintenance. 

Roads that intercept compacted glacial till soils and associated shallow groundwater would 

continue in their existing condition. Roads that have sections which traverse through these soils 

include: 4611, 4611-070, 4611-079, 4611-969, 4611-988, 4612-098, 4612-472, 4612-540, 4703, 

4812-041, 4812-538, 4812-539, and 4812-540. 

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Sucker Creek Legacy Roads and Trails Project

The 4611-910, -912, and -914, which traverse through a deep seated earthflow, would remain as 

they are on the landscape. 

Soil Productivity

Under this alternative, the existing condition would remain the same. Three hundred thirty-eight 

acres of road bed would continue to be committed to a use other than site productivity into the 

foreseeable future.

Erosion Hazard

Approximately 35 miles of native surfaced roads in the Sucker Creek watershed would continue 

to have an increased potential for native soil erosion off the roadbed. Stormproofing could still be 

done on level 2 and level 3 roads, but there is a very low likelihood that this activity would occur 

on level 2 roads because they are considered a low priority. There are approximately 3 miles of 

level 3 road (the upper end of FS4611) that has some native surfacing, and it is assumed that 

stormproofing activities would be implemented on this section of road to prevent surface soil 

erosion.

Cumulative Effects

Cumulative effects would occur where other past, present, and reasonably foreseeable future 

activities overlap with the roads in the analysis area, or indirect effects of these roads (such as 

road-related landslides). Past and present actions influencing cumulative effects on soils and 

slope stability include past and current timber harvest, mining, and road building, as discussed 

under the affected environment section. Reasonably foreseeable actions include continued gold 

mining along stream drainages and potential timber harvest.

No measurable cumulative effects are expected, as these activities are not expected to overlap 

with any direct or indirect effects of the roads in the analysis area. Best management practices and 

standards and guidelines are implemented with mining and timber harvest activities that mitigate 

and avoid unstable and potentially unstable areas, including road-related instability. Best 

management practices and Forest Plan standards and guidelines are incorporated into mining and 

harvest activities to maintain, enhance, and/or restore soil productivity and effective ground 

cover, which protect soils from unacceptable levels of detrimental soil disturbance and soil 

erosion. This includes best management practices for the protection and restoration of roads that 

are utilized in mining and timber management activities.

Alternative 2 – Modified Proposed Action

Under alternative 2, approximately 28 miles of road would be decommissioned, 31 miles would 

be put into storage, and 3 miles would be converted to non-motorized trail. Another 118 miles 

would be stormproofed (see table 11).

Other connected actions of the Sucker Creek Legacy Roads and Trails Project include the use of 

existing rock quarries as rock sources for project activities and salvaged woody material from 

decommissioning, storage, and stormproofing activities that is in excess of what is needed on-site 

for stabilization, erosion control, and other terrestrial needs. This excess material could be hauled 

off-site and utilized in stream restoration projects, for wildlife needs in other late-successional 

reserve locations that are deficient in downed wood, or for special wood products, such as 

firewood.

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Slope Stability

With implementation of alternative 2, approximately 17 miles of roads that traverse 45 percent or 

greater slopes would be decommissioned, which would greatly reduce or eliminate the risk of 

future road-related failures and downslope debris torrents in these areas (table 11). Approximately 

2 miles of road traversing slopes of 45 percent or greater would be decommissioned and 

converted to a non-motorized trail. The potential for future trail-bed related failures would be 

greatly reduced or eliminated through decommissioning of the roadbed.

Approximately 19 miles of roads that traverse 45 percent or greater slopes would be put into 

storage, which would greatly reduce the risk of future road-related failures and downslope debris 

torrents in these areas. At implementation, stream crossing road fills would be removed, and any 

unstable or potentially unstable road fill slopes would be pulled back adequately to prevent the 

road from failing while in storage.

Approximately 71 miles of roads that traverse 45 percent or greater slopes would be storm 

proofed, which would reduce the risk of future road-related failures and downslope debris torrents 

in these areas. Storm proofing activities would include drainage improvements and maintenance 

that would help to prevent fill slope failures, as well as early detection and repair of fill slopes 

showing indications of likely future failure (cracking, slumping, etc.). 

Table 11. Miles of road per proposed treatment on slopes at a higher risk of road-related failure.

Treatment RoadsTreated 

(mi)

Roads Treated on 45% + 

Slopes (mi)

Decommission 28 17

Decommision / convert to non-motorized trail 3 2 

Storage 31 19 

Stormproof 118 71

Implementation of alternative 2 would benefit current and potential slope stability issues with all 

roads that traverse through steep, compacted glacial till soils. 

Roads that would be decommissioned through these soil types include part of 4611-070, 4611-

969, part of 4812-041, and 4812-539. Decommissioning would eliminate future road-related 

failures by pulling out the road fill in unstable areas, which in these soils tend to be at multiple 

drainage crossings. 

The 4612-098 road would be decommissioned and converted to a non-motorized trail. 

Decommissioning activities and design into a trail would reduce the larger road related potential 

future failure risk, though the maintenance of part of the original road bed for the trail would not 

eliminate all the risk. Conversion to a trail, however, would include establishment of proper 

drainage to mitigate ongoing and future effects of shallow groundwater capture and related 

cutslope instability, where it occurs. 

The 4611-988 and 4612-540 roads, where they cross through these soil types, would be put into 

storage. Stream crossings and associated shallow groundwater interception drainage areas would 

have culverts and fill removed to reduce the risk of slope failures in these areas while the roads 

are in storage. When the roads are needed in the future, these locations would be reconstructed for 

the life of the need using best management practices for road stream crossings and drainage 

design, then pulled and placed back into storage.

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The remaining roads that cross through compacted glacial till soils would be stormproofed. These 

include the 4611, part of 4611-070, 4611-079, part of 4612-098, 4612-472, 4703, part of 4812-

041, 4812-538, and the 4812-540. Stormproofing would reduce the risk of slope failures and 

erosion where road cuts intercept shallow groundwater through road maintenance practices that 

would include improvements to road drainage and cut and fillslope maintenance to maintain the 

stability and integrity of the road.

Additionally, the 4611-910, -912, and -914 roads that traverse through a deep seated earthflow, 

would be put into storage. Instability of the earthflow triggered by periodic saturated soil 

conditions would continue at natural rates, but increased localized slope failures triggered by 

location of the roads at stream crossings would be eliminated, through proper pull out of fill 

material at stream crossings.

Soil Productivity

Under alternative 2, all of the planned decommissioned roads, which totals roughly 50 acres, 

would be re-committed to soil productivity; 248 acres would continue to be committed for 

something other than soil productivity (i.e., used as a road, and include stored and stormproofed 

roads).

Roads that are decommissioned, including the 3 miles decommissioned and converted to singletrack, non-motorized trail, would experience a range of recovery to productive soils, depending 

on site conditions and level of active versus passive restoration techniques employed. Active 

decommissioning would include a range of road obliteration, such as at stream crossings, fill 

slope pull back, road bed decompaction, and vegetation planting, which would result in the direct 

effect of breaking up soil compaction within the soil profile in the road prism and more quickly 

revegetating the area. These actions would increase the ability of water and air to move through 

the soil profile, and allow plant roots to penetrate deeper into the soil. As successive generations 

of vegetation establish and die, the organic matter content of the surface and subsurface soils 

would increase, adding nutrients to the soil and promoting beneficial soil organisms. Through 

active decommissioning activities, it would be expected that soil productivity would improve to 

similar surrounding forest conditions much more quickly than through passive restoration. 

Road sections planned for decommissioning that are in areas with low risk for failure, erosion and 

sediment delivery to streams would likely employ more passive restoration techniques. These 

sections of roadbed may have no treatments, or the road prism may be scarified and seeded. Soils 

in these sections would be maintained in a state of soil impairment, and it would be expected that 

this would be a long-term (greater than 50 years) effect. Over a long period of time (decades to 

hundreds of years, depending on soil textures, depth to restrictive compaction, soil moisture, 

organic matter levels, etc.), as successive generations of shrubs and trees populate the road 

prisms, deposit organic matter to the surface and add fine and coarse organics to the soil profile 

from decomposing roots, soil productivity would approach and potentially return to levels seen in 

the surrrounding forested areas.

Most roads would end up with a range of active to passive restoration techniques, since site 

specific conditions can vary widely along the length of a road and site specific conditions would 

be incorporated into the final decommissioning design. 

Roads that would be put into storage and roads that are stormproofed would remain committed to 

a use other than soil productivity, but stored roads would experience some short-term 

improvement to soil productivity while in storage. Soil productivity in riparian areas at pulled 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

stream crossings would be temporarily reestablished, as well as other locations where road prism 

compaction would be temporarily broken up, such as berming or fill pull-back locations, and 

where vegetation is planted for interim erosion control.

Erosion Hazard

Under alternative 2, approximately 16 miles of native surfaced roads would be decommissioned, 

approximately 8 miles of native surfaced roads would be put into storage, and approximately 14

miles of native surfaced roads would be stormproofed.

Road decommissioning would re-establish surface roughness, and effective groundcover through 

re-establishment of vegetation and organic matter (fine and coarse litter) which would stabilize 

and protect surface soil particles from erosion processes.

Putting roads into storage would maintain the roads for future use; roads would be closed to 

vehicle travel which would allow litter to accumulate, as well as vegetation to re-establish in the 

roadbed over time, developing effective ground cover over the next 3 to 5 years. Particularly 

sensitive locations (i.e. evidence of sheetwash and/or rill erosion on the road prism) would be 

actively re-vegetated to establish effective groundcover more quickly (see the Sucker Creek 

Legacy Roads and Trails Revegetation Plan).

Stormproofing would involve normal road maintenance practices to eliminate or minimize the 

risk of road surface erosion, such as capping the roadbed with crushed aggregate, and improving 

road surface drainage through the addition of rolling dips, improving the ditch line, and adding 

ditch relief culverts. There are four existing gravel pits in the area which could be used as rock 

sources for road improvements.

Additionally, along all roads where decommissioning, storage, or stormproofing activities create 

soil disturbance, such as pulling or replacing culverts and cross-drains, or road prism ripping, 

there is the potential for soil erosion in and off of these disturbed sites. Best management 

practices for effective erosion control would be required, and are incorporated into the mitigation 

measures for project implementation, such as mulching, seeding, straw or wood chip wattles, 

and/or sediment fencing. It is expected that erosion potential would be greatly reduced and 

localized, or eliminated, with implementation of erosion control mitigations during project 

implementation.

Cumulative Effects

Cumulative effects would occur where other past, present, and reasonably foreseeable future 

activities overlap with the roads and proposed road treatments in the analysis area, or indirect 

effects of these roads (such as road-related landslides, or re-establishment of vegetation on a 

decommissioned roadbed). Past and present actions influencing cumulative effects on soils and 

slope stability include past and current timber harvest, mining, and road building, as discussed 

under the affected environment section. Reasonably foreseeable actions include continued gold 

mining along stream drainages and potential timber harvest.

No measurable cumulative effects are expected, as these activities are not expected to overlap 

with any direct or indirect effects of the road treatments in the analysis area. Best management 

practices and standards and guidelines are implemented with mining and timber harvest activities 

that mitigate and avoid unstable and potentially unstable areas, including road-related instability.

Best management practices and Forest Plan standards and guidelines are incorporated into mining 

and harvest activities to maintain, enhance, and/or restore soil productivity and effective ground 

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cover, which protect soils from unacceptable levels of detrimental soil disturbance and soil 

erosion. This includes best management practices for the protection and restoration of roads that 

are utilized in mining and timber management activities.

Conclusion 

None of the connected actions would have any measurable effect to slope stability, soil 

productivity, or erosion hazard. Rock quarries are existing, and are located and maintained in 

stable conditions, are already committed to the production of rock and not soil productivity, and 

require erosion prevention mitigations for their use. Salvaged woody material would be used first 

for on-site stability, enhancement of soil productivity, erosion control, or other on-site terrestrial 

needs. Effects of the additional materials are expected to be indecipherable from background 

productivity, particularly due to the expected scattered and localized application of this material.

Excess of this material could be hauled off-site and utilized in stream restoration projects, needs 

in other late-successional reserve locations that are deficient in downed wood for wildlife, or for 

special wood products such as firewood.

Implementation of alternative 2 would result in short- and long-term benefits to slope stability, 

soil productivity, and erosion hazard in the Sucker Creek watershed, over the no-action 

alternative. Table 12 displays the results of some of the key measurement indicators for effects to 

slope stability, soil productivity, and erosion hazard, per alternative.

Alternative 2 would reduce the potential for road-related slope failures and debris torrents by 

decommissioning, storing, and/or providing maintenance to roads traversing slopes that are at a 

higher risk for slope failures (45 percent or greater). Alternative 2 would address shallow 

groundwater interception, road drainage, and slope stability concerns on roads that cross through 

compacted glacial till, through decommissioning of four road segments, converting to trail one

segment, storing two road segments, and doing active stormproofing activities on nine segments 

of road. Under the no-action alternative, all of these road segments would remain on the 

landscape in their current condition.

Table 12. Summary of some key measurement indicators for slope stability, soil productivity, and 

erosion hazard, by alternative

Measurement Indicators No Action Alternative 2

Slope Stability

Miles of road traversing 45%+ slopes 123 miles 107 miles

Miles of road traversing 45%+ slopes with 

reduced risk of failure over time 0 miles 98 miles

Soil Productivity

Acres of soil committed to forest roads 

instead of productivity 338 acres 248 acres

Erosion Hazard

Miles of native surfaced roads at risk of 

surface soil erosion 35 miles 0 miles

Alternative 2 would result in 50 acres of soils recommitted to soil productivity. The no-action 

alternative would result in no acres of soils recommitted to soil productivity.

Under the no-action alternative, it is expected that approximately 3 miles of native surfaced 

road(upper end of 4611) would be treated through stormproofing to prevent the risk of surface 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

soil erosion. Under alternative 2, 38 miles of native surfaced road would be treated to prevent the 

risk of surface soil erosion (16 miles decommissioned, 8 miles put into storage, and 14 miles 

stormproofed). 

Sensitive Plants

Introduction

The two botanical areas within the Sucker Creek watershed are the Bigelow Lakes and Grayback 

Mountain Botanical Areas. They total 955 acres and within their borders have native plant 

diversity with rare sensitive plant species. The proposed Sucker Creek Legacy Roads Project area 

is delineated by a road prism that includes the road travel way and cut and fill slopes. The 

treatment area is a previously disturbed corridor. This treatment area is the focus of this analysis 

and the following species accounts are only the species that occur within the project treatment 

area (figure ). Other rare and sensitive species identified in table 13 will not be affected from the 

implementation of this project and will not be discussed further.

Affected Environment 

Within the proposed project area there are four occurrences of the Rogue River-Siskiyou National 

Forest sensitive plant species6 Erythronium howellii (Howell’s fawnlily), five occurrences of the

sensitive plant species Iliamna lactibracteata (California globemallow), one occurrence of the 

sensitive plant species Solanum parishii (Parish’s nightshade), one occurrence of the sensitive 

plant species Lewisia leeana (Lee’s bitterroot), and one occurrence of the sensitive plant species 

Phacelia leonis (Siskiyou phacelia). See table 13 and figure 10. All occurrences were previously 

known from the project treatment area. Following are species accounts of Rogue-River-Siskiyou 

sensitive plant species that are found in the proposed project treatment area

Table 13. Forest Service sensitive and survey and manage plant species found within Sucker Creek 

watershed

Plant Species Species Status Found in Project Area

Iliamna lactibracteata (California globemallow) FS Sensitive Yes

Erythronium howellii (Howell’s fawnlily) FS Sensitive Yes

Phacelia leonis (Siskiyou phacelia) FS Sensitive Yes

Solanum parishii (Parish’s nightshade) FS Sensitive Yes

Lewisia leeana (Lee’s bitterroot) FS Sensitive Yes

Gentiana plurisetosa (elegant gentian) FS Sensitive No

Streptanthus howellii (Howell’s streptanthus) FS Sensitive No

Sagifragopsis fragarioides

(strawberry saxifrage)

FS Sensitive No

Buxbaumia virides (buxbaumia moss) Survey and Manage No

6 Shown in light blue in figure 10

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Sucker Creek Legacy Roads and Trails Project

Figure 10. Location of Forest Service sensitive plants in the Sucker Creek Project area

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Iliamna lactibracteata (California globemallow)

The Forest Service sensitive plant Iliamna lactibracteata (California globemallow) is a member 

of the Malvaceae (hollyhock) family. The species range is from southwestern Oregon (Coos, 

Curry, Douglas, Jackson, and Josephine), with one widely disjunct occurrence in Linn County 

Oregon, to northwestern California (Del Norte, Humboldt, Siskiyou, and Trinity counties). 

Iliamna lactibracteata occurs in burned white fir and Douglas-fir forests. 

California globemallow is ranked G3 globally, vulnerable; ranked by Oregon as a S2, imperiled; 

California S2.2, endangered; and Oregon Biodiversity Information Center, list two species which 

are rare or threatened in Oregon but more common elsewhere.

Iliamna latibracteata is classified as a Forest Special Status and Sensitive Species in both 

Regions 5 and 6. In Oregon, the species has been documented in the Rogue River-Siskiyou, 

Umpqua, and Winema national forests (USDA Forest Service 2004). In California, the species has 

been documented in the Six Rivers and Shasta-Trinity national forests (CNDDB 2007). Iliamna 

latibracteata is classified as a Special Status and Sensitive Species by the Bureau of Land 

Management. It has been documented in the Coos Bay and Medford Districts, and is suspected to 

occur in the Roseburg District (USDI Bureau of Land Management 2005).

The species is nearly entirely restricted to lands managed by the Forest Service and BLM. The 

emphasis on fuels reduction and returning wildlands to natural fire regimes may benefit the 

species, provided that post-fire salvage logging, revegetation, and invasive species management 

does not negatively impact occurrences. The majority of occurrences are known from National 

Forest System lands in Region 6. Therefore the species is strongly dependent on Region 6

management and conservation efforts.

Erythronium howellii (Howell’s fawnlily)

The Forest Service sensitive plant Erythronium howellii (Howell’s fawnlily) is a member of the 

Liliaceae (Lily) family. The species range is from southwestern Oregon (Josephine and Jackson 

counties) south to the Trinity Mountains, California (Del Norte, Humboldt, Mendocino, Siskiyou 

and Trinity counties). It is sometimes listed as a synonym for Erythronium citrinum but the Forest 

Service and Oregon Biodiversity Information Center consider it to be a separate species due to 

range differences and the lack of an appendage on the inner petals.

It has a state rank of S3: vulnerable in Oregon and a rank of S2.3: imperiled in California. The 

global rank is G3G4: Vulnerable. The species is an Oregon Biodiversity Information Center 

(ORBIC) List 1, contains taxa that are threatened with extinction or presumed to be extinct 

throughout their entire range. In Oregon there are 33 known occurrences and a total of around 

230,000 plants. There are 12 occurrences that have a good to excellent viability. The plant species 

appear stable but is limited in range. Threats include timber harvesting and mining activities.

Phacelia leonis (Siskiyou phacelia)

The Forest Service sensitive plant Phacelia leonis (Siskiyou phacelia) is a member of the 

Boraginaceae (Borage) family. It is restricted to serpentine soils and is found on serpentine 

meadows and seeps and upper montane coniferous forests from 1200 to 2750 meters in elevation.

Its global status is G2: imperiled, the reason it is given this rank is because of the low number of 

occurrences, moderate threats, restricted habitat and its limited range. The status in California is 

S2.2: imperiled and in Oregon it is S1: critically imperiled. The species ranked as an Oregon 

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Biodiversity Information Center list 1; contains taxa that are threatened with extinction or 

presumed to be extinct throughout their entire range.

This species occurs in Siskiyou and Trinity Counties in California and occurs only in Josephine 

County in Oregon. According to the Oregon Biodiversity Information Center, there are two 

element occurrences in Oregon and about 7,000 plants were reported from these two populations.

One of these sites notes motor vehicle disturbance and possible development into a helicopter 

landing and the other has little information about site quality. This is the occurrence on NFS road 

4703521 proposed for decommissioning. According to the California Native Plant Society, there 

are 18 occurrences in California. Cattle grazing and trampling are listed as the major threats to the 

species. It is calculated to be moderately vulnerable to climate change.

Solanum parishii (Parish’s nightshade)

The Forest Service sensitive plant Solanum parishii (Parish’s nightshade) is a member of the 

Solanaceae Family. Its range is Oregon and California. In Oregon the status and ranking is S2; 

contains taxa that are threatened with extirpation or presumed to be extirpated from the state of 

Oregon. These are often peripheral or disjunct species which are of concern when considering 

species diversity within Oregon's borders. They can be very significant when protecting the 

genetic diversity of a taxon. The species in California has no status or ranking; and its global rank 

and status is G4: apparently secure. The species is ranked as an Oregon Biodiversity Information 

Center List 2, taxa that are threatened with extirpation or presumed to be extirpated from the state 

of Oregon.

The species blooms from April to July and occurs in dry chaparral, meadows and brush land in 

dry Douglas-fir communities, along road banks, oak woodland and pine forest below 2000 

meters. In Oregon it occurs in Curry, Josephine and Jackson counties. In California it occurs 

throughout the northern part of the state and it also occurs in the southwestern part of the state. 

Plants appear to respond positively towards fire. Solanum parishii may hybridize with Solanum 

xanti but this needs more study.

Lewisia leeana (Lee’s bitterroot)

Lewisia leeana (Lee’s bitterroot) is a perennial herb in the Montiaceae (Miner’s lettuce family).

In California it was considered for listing, but was rejected. In Oregon it is an S2, imperiled. It 

has a global rank of G4, apparently secure. The species is ranked as an Oregon Biodiversity 

Information Center List 2, contains taxa that are threatened with extirpation or presumed to be 

extirpated from the state of Oregon.

The range is restricted but there do not appear to be any threats to the species. It is listed as a 

sensitive species by the Forest Service. In Oregon it can be found in Douglas, Jackson and 

Josephine counties. In California it is found from Fresno County north through Trinity and 

Siskiyou counties.

Lewisia leeana can be found on granite, serpentine cliffs, rocky slopes, conifer forest from 1300 

to 3350 meters in elevation. The blooming period is from June through August. It can hybridize 

with Lewisia cotyledon.

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Table 14. Forest Service sensitive plant species, the road where it is located, and the proposed 

treatment for the road

Sensitive Plant Species Road Number Road Name Proposed Treatment

Erythronium howellii (Howell’s 

fawnlily) 4609 Little Grayback Stormproof

Erythronium howellii (Howell’s 

fawnlily) 4614014 Horse Cave Stormproof

Erythronium howellii (Howell’s 

fawnlily) 4609053 Gray Sky Storage

Erythronium howellii (Howell’s 

fawnlily) 4703051 Bull Pen Stormproof

Iliamna lactibracteata (California 

globemallow) 4611960 Lake Creek Stormproof

Iliamna lactibracteata (California 

globemallow) 4611070 Bigelow Lakes Stormproof

Iliamna lactibracteata (California 

globemallow) 4611079 Lake Mountain Stormproof

Iliamna lactibracteata (California 

globemallow) 4611968 Pepper Flats Storage

Iliamna lactibracteata (California 

globemallow) 4611955 Pepper Camp Spur Storage

Lewisia leeana (Lee’s bitterroot) 4614435 After Horse Decommission

Solanum parishii (Parish’s 

nightshade) 4612472 Swan Mountain Stormproof

Solanum parishii (Parish’s 

nightshade) 4612487 Swan Up Stormproof

Phacelia leonis (Siskiyou 

phacelia) 4703521 N. A. Hurry Decommission

Environmental Consequences

Effects Mechanisms and Analysis Framework

Effects mechanisms serve as tools to quantify the effects to offer a basis for comparing the effects 

of management practices. Since design criteria (chapter 2) has been created to ensure that no 

sensitive plants would receive direct impacts from the project activities, indirect effects of the 

proposed action on botanical resources are minimal. The analysis area to assess direct, indirect, 

and cumulative effects is confined to the road prisms of road segments proposed for treatment in 

the Sucker Creek watershed. This has been deemed appropriate since the level of risk to the area’s 

botanical resources is directly tied to management practices proposed in this project.

Summary of Findings for both Alternatives

For the no action alternative: there would be no direct, indirect or cumulative effects to any RRS 

sensitive plant, lichen, or fungi species because no project activities are proposed.

For the modified proposed action: There would be no effect to any federally threatened, 

endangered, or proposed plant species. RRSNF sensitive plant, lichen, or fungi species may be 

affected but will not lead to federal listing or loss of viability to any species. All TES species 

identified within the project treatment area that are known to exist would be flagged and avoided 

to prevent any direct impacts (pdc 2, chapter 2). 

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Sucker Creek Legacy Roads and Trails Project

Alternative 1 – No Action 

Direct and Indirect Effects 

Alternative 1 calls for “no action” within the total project area. There will be no implementation 

or activities within the project area therefore there will be no direct or indirect effects resulting 

from this alternative.

Cumulative Effects

There would be no cumulative effects resulting from this alternative. Under this alternative the 

proposed treatment area would progress naturally over time. Sensitive plants occurrences would 

also naturally progress over time. 

Effects Determination

For the Sucker Creek Legacy Roads and Trails Project, Alternative 1, it is my 

determination that:

♦ There would be no effect to Fritillaria gentneri (Gentner’s fritillaria) and Lomatium 

cookii (Cook’s Lomatium), or any other plant species listed as threatened, endangered, 

proposed for listing, or candidates under the Endangered Species Act of 1973, as 

amended (ESA), administered by the U.S. Fish and Wildlife Service (USFWS). This 

determination is based on the absence of suitable habitat within the project area and the 

absence of individuals known or expected to occur within the project area. 

♦ There would be no effect to any RRSNF sensitive botanical species.

Alternative 2 – Modified Proposed Action

Species-specific Effects:

Erythronium howellii (Howell’s fawnlily)

There would be no direct effects to Howell’s fawnlily from the proposed project. This includes all 

activities associated with storm proofing roads, decommissioning roads, and placing roads into 

storage. There are four occurrences of this sensitive plant species within the proposed treatment 

area. Design criteria have been established to prevent any direct effects to the Howell’s fawnlily

occurrences. No project activities would occur within the four occurrences. 

There may be some beneficial indirect effects from placing NFS road 4609053 into storage. This 

may prevent impacts from invasive plants and noxious weeds that may otherwise be introduced 

and spread from vehicles contaminated with invasive plant seeds or vegetative materials traveling 

on the road. However, there may be some negative indirect effects to the species if project 

implementation introduces invasive plants and noxious weeds into the four occurrence areas. 

Mitigations have been created to limit or prevent the spread or establishment of invasive plants 

and noxious weeds within the proposed treatment area. These mitigations can be found in the 

Sucker Creek Legacy Roads Invasive Plant Risk Assessment.

Cumulative effects to Howell’s fawnlily include past, present, and foreseeable future actions are 

bounded by the Sucker Creek watershed where they are found. The bounding was chosen because 

the gene flow and seed dispersal mechanisms of the Erythronium genus are believed to be 

restricted (Gutian et al. 2003, Weiblan and Thompson 1995). Because there will be no direct and 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

limited adverse indirect effects there will be negligible adverse cumulative effects as a result of 

the proposed project.

Iliamna lactibracteata (California globemallow)

There would be no direct effects to California globemallow from the proposed project. This 

includes all activities associated with storm proofing roads, decommissioning roads, and placing 

roads into storage. There are five occurrences of this sensitive plant species within the proposed 

treatment area. Design criteria have been established to prevent any direst effects to the California 

globemallow occurrences. No project activities would occur within the five occurrences. 

There may be some beneficial indirect effects from placing NFS roads 4611968 and 4611955 into 

storage. This may prevent impacts from invasive plants and noxious weeds that may otherwise be 

introduced and spread from vehicles contaminated with invasive plant seeds or vegetative 

materials traveling on the road. However, there may be some negative indirect effects to the 

species if project implementation introduces invasive plants and noxious weeds into the five

occurrence areas. Mitigations have been created to limit or prevent the spread or establishment of 

invasive plants and noxious weeds within the proposed treatment area. These mitigations can be 

found in the Sucker Creek Legacy Roads Invasive Plant Risk Assessment.

Cumulative effects to California globemallow include past, present, and foreseeable future 

actions are bounded by the Sucker Creek watershed where they are found. The bounding was 

chosen because the gene flow and seed dispersal mechanisms of the Iliamna genus is believed to 

be restricted (Harrod and Halpern 2005). Seeds were found to be most abundant within 10 meters 

of adult plants.

Current management direction is designed to eliminate or reduce possible negative cumulative 

impacts by protecting known sensitive plants species from direct and indirect impacts. Overall, 

management of the direct and indirect effects through project design criteria and implementation 

of appropriate recommendation measures will minimize the potential for negative cumulative 

effects. Because there will be no direct and limited adverse indirect effects there will be 

negligible adverse cumulative effects as a result of the proposed project.

Phacelia leonis (Siskiyou phacelia)

There would be no direct effects to Siskiyou phacelia from the proposed project. This includes all 

activities associated with storm proofing roads, decommissioning roads, and placing roads into 

storage. There is one occurrence of this sensitive plant species within the proposed treatment area. 

Design criteria have been established to prevent any direct effects to the Siskiyou phacelia 

occurrence. No project activities would occur within the occurrence. 

There may be some beneficial indirect effects from decommissioning NFS road 4703521. This 

may prevent impacts from invasive plants and noxious weeds that may otherwise be introduced

and spread from vehicles contaminated with invasive plant seeds or vegetative materials while 

accessing the road. However, there may be some negative indirect effects to the species if project 

implementation introduces invasive plants and noxious weeds into the occurrence area. 

Mitigations have been created to limit or prevent the spread or establishment of invasive plants 

and noxious weeds within the proposed treatment area. These mitigations can be found in the 

Sucker Creek Legacy Roads Invasive Plant Risk Assessment.

Cumulative effects to Siskiyou phacelia include past, present, and foreseeable future actions are 

bounded by the Sucker Creek and Althouse Creek watersheds where they are found. Siskiyou 

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Sucker Creek Legacy Roads and Trails Project

phacelia is a small annual phacelia with only two occurrences on the RRSNF and all are found on 

the Wild Rivers Ranger District. The bounded area is between and around these two occurrences. 

The bounding was chosen because the species range is restricted and not known to occur north of

Portuguese Flat where it borders on the proposed project treatment area. The other Wild Rivers 

Ranger District occurrence is located 2.2 miles to the southwest. This occurrence is in Oregon 

about 250 feet north of the California border. 

Current management direction is designed to eliminate or reduce possible negative cumulative 

impacts by protecting known sensitive plants species from direct and indirect impacts. Overall, 

management of the direct and indirect effects through project design criteria and implementation 

of appropriate recommendation measures will minimize the potential for negative cumulative 

effects. Because there will be no direct and limited adverse indirect effects there will be 

negligible adverse cumulative effects as a result of the proposed project.

Solanum parishii (Parish’s nightshade)

There would be no direct effects to Parish’s nightshade from the proposed project. This includes 

all activities associated with storm proofing roads, decommissioning roads, and placing roads into 

storage. There is one occurrence of this sensitive plant species within the proposed treatment area. 

Design criteria have been established to prevent any direst effects to the Parish’s nightshade. No 

project activities would occur within the two occurrences. 

However, there may be some negative indirect effects to the species if project implementation 

introduces invasive plants and noxious weeds into the occurrence area. Mitigations have been 

created to limit or prevent the spread or establishment of invasive plants and noxious weeds 

within the proposed treatment area. These mitigations can be found in the Sucker Creek Legacy 

Roads Invasive Plant Risk Assessment.

Cumulative effects to Parish’s nightshade include past, present, and foreseeable future actions are 

bounded by the area around the two occurrences in the Sucker Creek watershed where they are 

found. The bounding was chosen because the species is only known in the district from two 

locations on the district. The second occurrence lies geographically far away in the northern 

section of the district. There are occurrences in the Siskiyou Mountains Ranger District and the 

Medford District BLM that are geographically isolated from the occurrence within the proposed 

project treatment area.

Current management direction is designed to eliminate or reduce possible negative cumulative 

impacts by protecting known sensitive plants species from direct and indirect impacts. Overall, 

management of the direct and indirect effects through project design criteria and implementation 

of appropriate recommendation measures will minimize the potential for negative cumulative 

effects. Because there will be no direct and limited adverse indirect effects there will be 

negligible adverse cumulative effects as a result of the proposed project.

Lewisia leeana (Lee’s bitterroot)

There would be no direct effects to Lee’s bitterroot from the proposed project. This includes all 

activities associated with placing NFS road 4614435 into storage. There is one occurrence of this 

sensitive plant species within the proposed treatment area. Design criteria have been established 

to prevent any direst effects to the Lee’s bitterroot occurrence. No project activities would occur 

within the occurrence. 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

There may be some negative indirect effects to the species if project implementation introduces 

invasive plants and noxious weeds into the occurrence area. Mitigations have been created to 

limit or prevent the spread or establishment of invasive plants and noxious weeds within the 

proposed treatment area. These mitigations can be found in the Sucker Creek Legacy Roads 

Invasive Plant Risk Assessment.

Cumulative effects to Lee’s bitterroot include past, present, and foreseeable future actions are 

bounded by the area around the occurrence in the Sucker Creek watershed where they are found. 

The bounding was chosen because the occurrence of the species is geographically isolated from 

all other occurrences. 

Current management direction is designed to eliminate or reduce possible negative cumulative 

impacts by protecting known sensitive plants species from direct and indirect impacts. Overall, 

management of the direct and indirect effects through project design criteria and implementation 

of appropriate recommendation measures will minimize the potential for negative cumulative 

effects. Because there will be no direct and limited adverse indirect effects there will be 

negligible adverse cumulative effects as a result of the proposed project.

Effects Determination

For the Sucker Creek Legacy Roads and Trails Project, Alternative 2, it is my 

determination that:

♦ There would be no effect to Fritillaria gentneri (Gentner’s fritillaria) and Lomatium 

cookii (Cook’s Lomatium), or any other plant species listed as threatened, endangered, 

proposed for listing, or candidates under the Endangered Species Act of 1973, as 

amended (ESA), administered by the U.S. Fish and Wildlife Service (USFWS). This 

determination is based on the absence of suitable habitat within the project area and the 

absence of individuals known or expected to occur within the project area. 

♦ The proposed project may affect individuals, but is not likely to result in a trend 

toward Federal listing or loss of viability to the species for the following RRSNF

sensitive plant species: Erythronium howellii (Howell’s fawnlily), Iliamna latibracteata

(California globemallow), Lewisia leeana (Lee’s lewisia), Phacelia leonis (Siskiyou 

phacelia), and Solanum parishii (Parish’s horse-nettle). The basis of this determination is:

if there are unknown individuals within the project treatment area they may receive 

impacts during project implementation.

♦ The proposed project would have no effect to any other RRSNF sensitive botanical

species. This determination is based on the absence of project impacts to individuals 

known or expected to occur within the project area and/or the absence of suitable habitat 

within the project area

Invasive Plants

Introduction

There are many target invasive plant and Oregon State listed noxious weed infestations 

throughout the project area. Known infestations are controlled annually; however, most 

infestations take years to eradicate. Subsequently, these infestations may increase in size or 

spread to non-infested areas. A wide variety of vectors are expected to introduce and spread 

invasive species throughout the project area. Invasive plant seeds can be transported on vehicles 

traveling from roads with weed infested areas and are expected to spread readily as they are 

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Sucker Creek Legacy Roads and Trails Project

deposited along road sides. Additionally, off-road vehicle use is a common cause of invasive plant 

introduction and spread beyond the road prism. Finally, introduction and spread of invasive 

species by recreational activities, human activities, animals, wind, and water may also occur.

Affected Environment

The following table lists the Wild Rivers Ranger District target invasive species present in the 

Sucker Creek Legacy Roads Project area. There are 11 species with multiple infestations. Every 

road within the project area has known invasive plant species infestations (figure 11). Invasive 

plant surveys and manual treatment (hand-grubbing and/or solarizing with black plastic) of 

known infestations occurred throughout the proposed planning area. The following Oregon 

Department of Agriculture (ODA)7 listed noxious weeds and invasive plants are documented 

from the project area.

Table 15. Invasive plant species present in the project area

Species

ODA Noxious Weed 

Designation*

Life Cycle Habitat Preference

Centaurea debeauxii

(meadow knapweed)

List B

Perennial forb

Reproducing by seed

Best adapted to well-drained, light-textured soils in areas that 

receive some summer rainfall. This includes ponderosa pine 

and Douglas-fir forests and shrub-steppe habitats with 

bluebunch wheatgrass, needle-and-thread, and Idaho Fescue.

Centaurea stoebe var. 

micranthos

(spotted knapweed)

List B and T

Biennial perennial forb 

reproducing by seed 

(viable up to 8

years) and lateral 

shoots

Best adapted to well-drained, light-textured soils in areas that 

receive some summer rainfall. This includes ponderosa pine 

(Pinus ponderosa) and Douglas-fir (Pseudotsuga menziesii) 

forests and shrub-steppe habitats with bluebunch wheatgrass, 

needle-and-thread, and Idaho fescue. Infestations may 

change soil conditions to the advantage of this species

Cirsium arvense

(Canada thistle)

List B

Perennial forb 

reproducing by seed 

and shoots from

lateral roots (dormant

buried seed viable up 

to

26 years)

Prefers and is invasive in prairies and other grasslands and 

riparian areas with deep, well-aerated, mesic soils, but also 

occurs in almost every upland herbaceous community, 

especially roadsides, abandoned fields, and pastures.

Cirsium vulgare

(bull thistle)

List B

Biennial forb 

reproducing by seed 

(viable 3 years or

less)

Occurs in dry to moist habitat, fields, pastures,

grasslands, roadways, forest clearings, rock outcrops, and 

along waterways. Does best in areas with moderate slope. It 

is not shade tolerant.

Cytisus scoparius

(Scotch broom)

List B

Perennial shrub 

reproducing by seed 

that is long lived

Found in pastures, forest, and wastelands. This nitrogen fixer 

which has prolific and vigorous growth patterns may have the 

ability to alter native plant

Hypericum perforatum

(St. Johnswort)

List B

Perennial forb that 

reproduces by seed 

and short runners

Rangeland and pastures (especially when poorly

managed), fields, roadsides, forest clearings in temperate 

regions with cool, moist winters and dry summers. Grows best 

in open, disturbed sites and on slightly acidic to neutral soils. 

Does not tolerate saturated soils.

Lathyrus latifolius Perennial Occupies a wide range of climactic conditions thriving in the 

7 Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

http://www.oregon.gov/ODA/PLANT/WEEDS/pages/profile_perennialpeavine.aspx

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Species

ODA Noxious Weed 

Designation*

Life Cycle Habitat Preference

(perennial peavine)

List B

vine/subshrub/

forb/herb reproducing 

by seed and rhizome

warm wet environment of the Pacific Northwest to the cold dry 

conditions of the Rocky Mountain States. Little information 

has been published on this species and it is often overlooked 

as an invader.

Leucanthemum vulgare

(oxeye daisy)

Not on List

Perennial forb that 

reproduces by seed 

and rhizome

Fields, pastures, waste places, roadsides, railroads,

prairies, slopes, disturbed sites.

Linaria vulare

(yellow toadflax)

List B

Perennial forb that 

reproduces by seed 

and rhizome

Found along roadsides, waste places, and cultivated fields.

Senecio jacobaea

(tansy ragwort)

List B

Perennial forb that 

reproduces by seed

Invades cut-over forest lands, irrigated and non-irrigated 

pastures, woodland pastures, and fallow lands. Although it 

prefers light, well-drained soils in cool, moist climates and 

rarely is tolerant of high water tables or acidic soils, it can

grow in most soil moisture regimes, even where there are hot, 

dry summers. It can over-winter in areas where temperatures 

reach -20°F or lower if there is good snow cover.

Melilotus officinalis 

(sweetclover)

Not on list

Biennial forb that 

reproduces by seed

Sweetclover plants inhabit open fields, roadsides, riparian 

zones, disturbed sites and other communities from low to 

middle elevations.

*ODA Designations

“A” Designated Weed – a weed of known economic importance which occurs in the state in small enough infestations to 

make eradication or containment possible; or is not known to occur, but its presence in neighboring states make future 

occurrence in Oregon seem imminent Recommended action: Infestations are subject to eradication or intensive control 

when and where found.

“B” Designated Weed – a weed of economic importance which is regionally abundant, but which may have limited 

distribution in some counties (Table 2). Recommended action: Limited to intensive control at the state, county or regional 

level as determined on a site specific, case-by-case basis. Where implementation of a fully integrated statewide 

management plan is not feasible, biological control (when available) shall be the primary control method.

“T” Designated Weed – a priority noxious weed designated by the Oregon State Weed Board as a target for which the 

ODA will develop and implement a statewide management plan. “T” designated noxious weeds are species selected from 

either the “A” or “B”

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Figure 11. Locations of invasive plants found in the Sucker Creek Legacy Roads Project area

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Environmental Consequences

For any ground disturbing activity on RRSNF it is required to determine the risk of introducing 

and/or spreading invasive plant species. If it is determined that a project has a moderate to high 

risk of introducing invasive plant species, the project decision document must identify invasive 

plant species control measures to be undertaken during project implementation (Forest Service 

Manual 2080, Amendment No. 2000-95-5, effective November 29, 1995).

Effects Mechanisms and Analysis Framework

Effects mechanisms serve as tools to quantify the effects and offer a basis for comparing the 

effects of management practices. There are native plant communities that would receive impacts 

from invasive plants within the project activity areas, possible effects of the proposed action to 

native plant communities by invasive plants are discussed qualitatively, and overall risk is 

reported in general terms.

There are many vectors that may influence the introduction and spread of invasive plants into the 

project area. Project vectors include but are not limited to: increased risk of noxious weed seed 

introduction from vehicles and machinery; the spread of existing infestations from vehicles and 

machinery; habitat alteration by the creation of new disturbed and open areas; compaction of 

soils; and the removal of canopy layers. Non-project dependent vectors that increase the risk of 

invasive plant establishment and spread include: recreational activities by hikers, bikers, and 

equestrians; vehicular use of trails and roads; and wind and water dissemination of invasive 

seeds. In addition, wildlife can spread invasive plants by disseminating seeds from transport on 

their bodies or through their digestive systems.

The analysis area to assess direct, indirect, and cumulative effects is confined to the road prisms 

of road segments proposed for treatment in the Sucker Creek watershed. This has been deemed 

appropriate since the level of risk to the area’s invasive plant infestations is directly tied to 

management practices proposed in this project.

Alternative 1 – No Action

Direct, Indirect and Cumulative Effects

Under the no-action alternative there would be no direct, indirect, or cumulative affects to native 

plant communities from invasive plants. The reason for this determination is: no project activities 

would occur and there would be no equipment or additional vectors present to establish or spread 

invasive plants and noxious weeds, their seeds, or vegetative material within the proposed project 

treatment area. 

Alternative 2 – Modified Proposed Action

Direct, Indirect and Cumulative Effects

Project activities include removing native vegetation with equipment. Contaminated equipment 

and vehicles could introduce invasive plants into the project area. Road work and 

decommissioning roads could create disturbed and compacted areas where invasive plants can 

spread and establish. The removal of canopy layers and the creation of open, disturbed, and bare 

soil areas could directly and indirectly adversely affect adjacent native plant communities. This 

could occur when introduced aggressive invasive species out-compete them. 

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Sucker Creek Legacy Roads and Trails Project

There would be minimal adverse cumulative effects from the proposed project. Many actions 

have previously taken place within the project area disturbing the landscape and allowing for 

invasive plant infestations to establish and spread. These include the establishment and 

maintenance of the road prisms, logging, fuel reduction, mining operations, recreation, grazing, 

and other activities. 

Project mitigations (pdc 28-39, chapter 2) would minimize adverse effects to native plant 

communities from the establishment and spread of invasive plants.

Risk Determination

The overall risk of noxious weed establishment as a result of the project is moderate. This 

determination is based on the following effects to the project area from the proposed treatments:

♦ There are existing RRSNF target invasive species and Oregon State listed noxious weed

infestations within the project area.

♦ There would be large areas of ground disturbance. 

♦ There would be large areas of soil compaction. 

♦ There would be decommissioning of infested roads. 

♦ Canopy cover and litter layer would be affected.

♦ Equipment used in the proposed project area may be exposed to and contaminated with 

invasive plant material.

♦ Mitigations and project design criteria (chapter 2) would be applied during 

implementation to prevent the establishment of invasive plant species, or spread of 

existing invasive plant infestations. 

Vegetation

Introduction

The vegetation analysis for the Sucker Creek Legacy Roads Project area focuses on access to 

existing managed stands located throughout the Sucker Grayback 5th field watershed. This section 

summarizes the existing conditions for managed stands and anticipated direct, indirect, and 

cumulative environmental effects that would result from the Sucker Creek Legacy Roads and 

Trails Project modified proposed action. It references and summarizes the vegetation analysis 

report. The analysis reviews transportation networks located throughout the project area and the 

land management allocation for each managed stand and corresponding road segment. It also

focuses on stands that have received vegetation treatment— young stand thinning, density 

management or fuels thinning— along with commercial thinning of intermediate age stands. This 

report also addresses the need for access of unmanaged stands with an emphasis on timber 

production within the project area.

Affected Environment

The Sucker Creek Legacy Roads Project area is a landscape of great vegetative diversity. Much of 

the terrain is covered by mixed conifer forests and broadleaf trees. At lower elevations, 

Douglas-fir (Pseudotsuga menziesii) dominates forest stands on most aspects but is frequently 

intermixed with other warm-site conifers as well as a number of hardwood trees and shrubs. In 

contrast, forests above 4,000 feet include a greater assortment of mesic conifers but fewer 

broadleaf trees. While Douglas-fir trees are likely to grow in upper elevation stands in moderate 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

numbers, white fir (Abies concolor)/grand fir (Abies grandis) trees typically comprise a sizeable 

or sometimes predominant proportion of all trees in a stand. Throughout the project area, and 

scattered among forest stands at both low and high elevations, are open areas that sustain a 

remarkable number of locally endemic plants. Each plant community growing within the project

area (whether human-shaped or natural) is segregated along gradients of elevation, aspect, soils 

and topography, and is directly affected by vital plant growth determinants such as temperature, 

effective precipitation and hydrologic regime.

Cover Types

A full description of all cover types for this project is in the vegetation analysis report. All of 

these descriptions have been created using the local knowledge of Forest Service personnel 

working in the area in combination with vegetation descriptions provided by Whittaker (1960). 

Stand information was gathered to include stand examination surveys completed as part of East 

Illinois Valley Managed Stand project 2006-2010. Information was also gathered from watershed 

analyses completed for the Sucker Creek drainage that encompasses the analysis area (USDA 

Forest Service 1998

Management Areas

Management area allocations from the Siskiyou LRMP are shown in figure 12. Late successional 

reserve comprises the majority of acres in the watershed with over 26,000 acres allocated. This 

designation exceeds all other management area allocations in the watershed combined.

Managed Stands

The Grayback/Sucker Watershed Analysis (1998) identified key recommendations regarding the 

overall health of the watershed and the surrounding community. The findings of the analysis show 

departures for historic stand structures shaped by natural process endemic to the watershed. These 

recommendations prioritized vegetation treatments into areas of managed stands that occur in 

interior habitat that has been fractured in the past. These areas fall under the late-successional 

reserve allocations within the watershed.

The access to the two vegetation cover types, young (immature) forests and intermediateage/closed canopy forests, are critical to ensure that both cover types can be managed in 

accordance to the stated land management direction. These management actions include but are 

not limited to vegetation treatments and are described below. The following table displays 

previous harvest activity within the Sucker Creek Legacy Roads analysis area. These managed 

stands have been classified first by decade of harvest and then grouped into stand types.

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Sucker Creek Legacy Roads and Trails Project

Figure 12. Land and Resource Management (1989) direction as amended by the Northwest Forest 

Plan (1994) for the Sucker Creek Legacy Roads and Trails analysis area

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Table 16. Managed stands in the Sucker Creek Legacy Roads and Trails analysis area

Intermediate-age/Closed Canopy 

Forests Young (Immature) Forests Total 

Acres in 

Managed 

Stands Harvest 

Year by 

Decade

1940 -

1950

1950-

1960

1960-

1970

1970-

1980

1980-

1990 1991 to Present

Acres 

Harvested 56 386 2492 2774 3773 1395 10,876

Young (immature) forest type vegetation treatments are described in the Plantation and 

Hazardous Fuels Treatment Environmental Analysis ROD (USDA Forest Service 2002). The 

analysis differentiated the young (immature) forest types into stands with three age classes: 0 

to10-year-old stands, 10- to 20-year-old stands and 20- to 30-year-old stands and activities that 

would occur in regards to allocation. Access is required for thinning operations into these stands

to accomplish the goals and objective of the land management allocation in which they reside 

(late-successional reserve, riparian reserve and matrix). Thinning and fuels treatments require 

access for contractors to enter these managed stands. Typical thinning operations in this forest 

type include a chain saw crew for thinning and pruning and a handpile crew that piles slash for 

burning after the wood cures (woody moisture levels are reduced to ensure consumption of the 

fuels).

Commercial thinning activities include utilizing Forest System roads to gain access to project 

sites for saw crews or machines (feller bunchers, harvesters and forewarders) to enter the stands 

and thin trees and yard saw timber (to include cable yarders) to landings that on occasion utilize 

existing roads. Road access is also required for hauling woody material (saw timber, post poles 

and firewood) that result from thinning operations that occur across land management allocations 

where wood products are a byproduct of thinning and are not needed for down woody debris, 

snag requirements or in-stream coarse woody debris. In land management allocations where 

wood production is the management emphasis, maximization of wood production the goal the 

allocation.

Effects on Vegetation

Chapter 2 details the vegetation mitigation measures and design criteria that would be 

implemented to avoid, eliminate, or reduce and minimize any potential adverse effects to 

vegetation resources from activities under the modified proposed action. All measures are 

effective and easily implementable. Design criteria support the Siskiyou Land and Resource 

Management Plan (1989) as well as other relevant laws, policies and regulations. 

Effects Mechanisms and Analysis Framework

The interdisciplinary team reviewed the road network in the Sucker Creek Legacy Road Project 

area. Alternative 2 (modified proposed action) was developed through an interdisciplinary process 

where a team of resource specialists reviewed every road segment on NFS lands in the Sucker 

Creek watershed to identify which segments would benefit the most from road treatment (e.g., to 

reduce sediment inputs into streams supporting Coho salmon), and which road segments need to 

be maintained for access (e.g., for land management, emergency access, and recreation). The 

following criteria were used to assess needs for road segments for land management:

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Sucker Creek Legacy Roads and Trails Project

♦ Is there evidence of past management along or at the end of road segment (managed 

stand that had a final removal prescription applied in the past (including clear cutting, 

shelterwood or seed-tree cuts)?

♦ Has the stand received thinning in the past 5 years and will not need additional entries 

within the next 20 years (could include young stand thinnings such as release treatments 

and/or timber stand improvement under the Plantation Thinning and Hazardous Fuels 

Treatment EA (2002)?

♦ Has the stand received a commercial thinning (East Illinois Managed Stand 

Environmental Analysis ROD 2007) within the last 5 years and will not need additional 

entries within the next 20 years? 

♦ Is there access to Matrix land that has not been managed in the past that could be 

programmed for harvest within the next 5 years?

♦ Are there roads that are needed for access to conduct thinning operations in managed 

stands to achieve Land and Resource Management objectives as amended by the NWFP?

Each road system was evaluated in the analysis regarding the access into areas of previous 

management. Some road systems were found to be redundant and could be removed from the 

network of system roads.

Roads that are main routes within the watershed are considered backbone road systems. These 

roads serve as multiple use roads that provide access to recreation, fires escape routes for the 

Oregon Caves National Monument, alternative route to the town of Williams and access to 

managed stands. These backbone road systems are listed in the transportation report.

Table 17. Road segments, acres of managed stands and land allocation proposed for storage under 

alternative 2-modified proposed action

Road Segment Acres of Managed Stands 

Accessed by Road Segment

Land Management Allocation Proposed Action

4609053 35 Partial Retention Visual Storage

20 Riparian Reserve Storage

4609056 82 Late Successional Reserves Storage

147 Matrix Storage

2 Partial Retention Visual Storage

3 Private Land Storage

6 Riparian Reserve Storage

2 Special Wildlife Site Storage

4609911 86 Matrix Storage

25 Partial Retention Visual Storage

7 Riparian Reserve Storage

4 Special Wildlife Site Storage

4609920 53 Matrix Storage

112 Partial Retention Visual Storage

17 Riparian Reserve Storage

4611078 68 Matrix Storage

5 Riparian Reserve Storage

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Road Segment Acres of Managed Stands 

Accessed by Road Segment

Land Management Allocation Proposed Action

4611910 105 Late Successional Reserves Storage

4611914 46 Late Successional Reserves Storage

4611955 22 Matrix Storage

4611968 25 Matrix Storage

1 Riparian Reserve Storage

4611988 14 Late Successional Reserves Storage

41 Matrix Storage

4612013 24 Late Successional Reserves Storage

4612541 19 Matrix Storage

4 Special Wildlife Site Storage

4614017 53 Late Successional Reserves Storage

4614024 107 Late Successional Reserves Storage

4614047 191 Late Successional Reserves Storage

4703100 6 Matrix Storage

20 Partial Retention Visual Storage

4 Riparian Reserve Storage

4703146 9 Late Successional Reserves Storage

4703433 66 Late Successional Reserves Storage

5 Matrix Storage

4703440 49 Partial Retention Visual Storage

8 Riparian Reserve Storage

4812575 11 Late Successional Reserves Storage

4812577 77 Late Successional Reserves Storage

Stands that require access within the next 5 years were identified through the analysis of the 

project. These stands could be entered within the next 5 years dependent on funding levels. The 

road systems in the table below include stands adjacent to backbone road systems. The acres 

listed include both young stands and intermediate/closed canopy types in managed stands. These 

stands would require access for timber haul routes and young stand thinning crews to conduct 

harvest and fuel reduction operations.

Table 18. Road segments, acres of managed stands and land allocation proposed for stormproofing 

under alternative 2-modified proposed action

Road 

Segment

Acres of Managed Stands 

Accessed by Road Segment

Land Management Allocation Proposed 

Action

4600000 214 Late Successional Reserves Stormproof

4600150 12 Late Successional Reserves Stormproof

4600180 179 Late Successional Reserves Stormproof

4609000 5 Matrix Stormproof

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Road 

Segment

Acres of Managed Stands 

Accessed by Road Segment

Land Management Allocation Proposed 

Action

301 Partial Retention Visual Stormproof

86 Riparian Reserve Stormproof

1 Special Wildlife Site Stormproof

4611000 343 Late Successional Reserves Stormproof

251 Matrix Stormproof

189 Riparian Reserve Stormproof

4 Special Wildlife Site Stormproof

4611019 283 Late Successional Reserves Stormproof

4611063 349 Matrix Stormproof

89 Riparian Reserve Stormproof

4611070 3 Backcountry Rec. Stormproof

1 Botanical Stormproof

159 Late Successional Reserves Stormproof

229 Matrix Stormproof

33 Partial Retention Visual Stormproof

25 Riparian Reserve Stormproof

6 Special Wildlife Site Stormproof

4611079 63 Late Successional Reserves Stormproof

80 Matrix Stormproof

22 Riparian Reserve Stormproof

4611952 118 Matrix Stormproof

1 Partial Retention Visual Stormproof

3 Riparian Reserve Stormproof

4611953 23 Matrix Stormproof

4611960 205 Late Successional Reserves Stormproof

4611970 41 Matrix Stormproof

14 Riparian Reserve Stormproof

4611973 34 Matrix Stormproof

3 Riparian Reserve Stormproof

4612000 452 Late Successional Reserves Stormproof

16 Matrix Stormproof

11 Riparian Reserve Stormproof

4612036 308 Late Successional Reserves Stormproof

4612080 429 Late Successional Reserves Stormproof

97 Matrix Stormproof

5 Riparian Reserve Stormproof

4 Special Wildlife Site Stormproof

4612098 164 Late Successional Reserves Stormproof

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Road 

Segment

Acres of Managed Stands 

Accessed by Road Segment

Land Management Allocation Proposed 

Action

67 Matrix Stormproof

46 Riparian Reserve Stormproof

4612430 37 Late Successional Reserves Stormproof

4612472 24 Late Successional Reserves Stormproof

189 Matrix Stormproof

6 Riparian Reserve Stormproof

1 Special Wildlife Site Stormproof

4612487 4 Matrix Stormproof

4613000 485 Late Successional Reserves Stormproof

16 Matrix Stormproof

78 Partial Retention Visual Stormproof

4613031 233 Late Successional Reserves Stormproof

4613067 59 Matrix Stormproof

29 Partial Retention Visual Stormproof

1 Special Wildlife Site Stormproof

4614000 653 Late Successional Reserves Stormproof

4614014 41 Late Successional Reserves Stormproof

4614046 139 Late Successional Reserves Stormproof

4614048 232 Late Successional Reserves Stormproof

4614449 54 Late Successional Reserves Stormproof

4703000 5 Late Successional Reserves Stormproof

225 Matrix Stormproof

247 Partial Retention Visual Stormproof

28 Retention Visual Stormproof

89 Riparian Reserve Stormproof

5 Special Wildlife Site Stormproof

4703051 121 Late Successional Reserves Stormproof

65 Matrix Stormproof

4703156 66 Matrix Stormproof

5 Riparian Reserve Stormproof

4703430 26 Matrix Stormproof

59 Partial Retention Visual Stormproof

8 Riparian Reserve Stormproof

4703445 1 Late Successional Reserves Stormproof

11 Matrix Stormproof

1 Riparian Reserve Stormproof

4703450 81 Partial Retention Visual Stormproof

14 Riparian Reserve Stormproof

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Sucker Creek Legacy Roads and Trails Project

Road 

Segment

Acres of Managed Stands 

Accessed by Road Segment

Land Management Allocation Proposed 

Action

4703458 15 Partial Retention Visual Stormproof

4812041 92 Late Successional Reserves Stormproof

4812538 23 Partial Retention Visual Stormproof

11 Retention Visual Stormproof

Roads not needed for 20 years or more access stands that in general either does not require 

thinning for 20 years or more to meet management objectives or already meet management 

objectives. Stands that fall under this category include stands that received overstory thinning that 

would not need additional thinning for in foreseeable future and or have roads that access the area 

in which the stand resides.

Table 19. Road segments, acres of managed stands and land allocation proposed for 

decommissioning under alternative 2-modified proposed action

Road 

Segment

Acres of Managed Stands Accessed 

by Road Segment

Land Management 

Allocation

Proposed Action

4600176 14 Late Successional Reserves Decommission

4609947 7 Matrix Decommission

2 Partial Retention Visual Decommission

4609955 16 Late Successional Reserves Decommission

1 Matrix Decommission

4611085 1 Matrix Decommission

4611950 43 Matrix Decommission

19 Riparian Reserve Decommission

4611969 49 Late Successional Reserves Decommission

4612069 107 Late Successional Reserves Decommission

4612435 17 Late Successional Reserves Decommission

4612461 61 Late Successional Reserves Decommission

4612467 50 Late Successional Reserves Decommission

4613066 6 Late Successional Reserves Decommission

4614015 17 Late Successional Reserves Decommission

4614040 129 Late Successional Reserves Decommission

4614422 8 Late Successional Reserves Decommission

4703426 6 Late Successional Reserves Decommission

4703455 6 Partial Retention Visual Decommission

4812539 2 Riparian Reserve Decommission

23 Partial Retention Visual Decommission

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Environmental Consequences

Alternative 1 – No Action

Direct and Indirect Effects

There are no direct effects of choosing the no-action alternative.

Indirect effects of the no-action alternative would maintain the current level of access in the short 

term. However in the long term roads that have issues with improper drainage or erosion would 

not receive treatment. The result of not treating these roads could be reduced access by road 

failure as observed in the 1997 flood, in which road segments were destroyed because drainage 

systems were not built to withstand flood events. 

Failed roads in need of repair would increase costs to enter the road system and make timber sales 

unfeasible. Failed roads would also have an effect on costs for treating (thinning, pruning) young 

stands due to high walk-in costs. Increased costs to enter stands due to needed road maintenance 

or road reconstruction, would translate to reducing the funding available for treatments and 

therefore, reducing the number of acres to be treated.

Alternative 2 – Modified Proposed Action

Direct and Indirect Effects

The direct effect of treating roads that access managed stands is maintaining the ability to manage 

vegetation as directed under the LRMP (1989) as amended by the NWFP (1994). The modified 

proposed action maintains access to managed stands and unmanaged matrix ground that may be 

included in the 5-year planning process for timber products. Maintaining access reduces access 

costs and allows more funding to be used to treat more acres of vegetation.

The modified proposed action would require removal of trees in areas around culverts that are 

stormproofed, removed for storage or removed during decommissioning. This vegetation would 

be utilized to meet coarse woody debris requirements within the allocation where the vegetation 

was removed (see hydrology and wildlife sections). Excess woody material remaining after the 

allocation requirements are met may be made available to the public under special forest products 

permits, and include but are not limited to: firewood, small saw timber, post and pole sales. 

Cumulative Effects

The cumulative effects of this analysis are based on road access for vegetation treatments within 

multiple land allocations. Activities proposed under the modified proposed action reduce road 

density in the analysis area while maintaining access to 8,443 acres of managed stands located 

throughout the watershed.

Roads that are proposed to be decommissioned (table 19) are in areas where there are multiple 

roads entering a single stand or roads that are not needed due to land allocation objectives.

Proposed stormproofing activities will provide access to not only to backbone road systems but 

also roads that accesses managed stands (table 18). Stormproofing roads reduces costs for road 

maintenance for timber sales and reduce costs for young stand treatments. 

This project will also provide access to future activities by placing roads into storage status (table 

17). Placing roads into storage status would alleviate the issue of back-logged road maintenance 

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that can cause roads to fail on their own or require maintenance or reconstruction to implement 

future treatments to managed stands. 

Proposed activities maintain access and decreasing future sediment delivery by reducing roads 

that would not be maintained and eventually fail on their own.

Port Orford Cedar

Introduction

This analysis will follow the process established by the ROD and FEIS for the Management of 

Port Orford cedar in Southwest Oregon May 2004 for identifying a project’s risk of spread of 

Phytophthora lateralis (P. lateralis) and provide management strategies for reducing risk of P. 

lateralis spread in the analysis area. Recommended management techniques for mitigation of the 

risk of spread will be identified. 

Affected Environment

Port Orford cedar (POC) (Chamaecyparis lawsoniana) is native to a limited area along the Pacific 

Coast. On the Rogue River-Siskiyou National Forest. Updated inventory data shows Port Orford

cedar occurs on approximately 133,000 acres on the Gold Beach, Powers, and Wild Rivers 

Ranger Districts. About 12,700 acres (8.7%) are infested with Phytophthora lateralis, the 

pathogen that causes POC root disease.

Many of the Port Orford cedar (POC) within the Wild Rivers Ranger District range in age from 

200 to 400 years and are 20 to 60 inches in diameter. POC root disease has been present along the 

Oregon side of the Grayback Road going toward Happy Camp, California, since about 1960. It

has infested the Grayback/Sucker Creek drainage near the Oregon Caves National Monument. 

POC are most often found in riparian areas within the Wild Rivers Ranger District. Generally, 

POC is within 100 feet of the stream; however, small groves of POC can be found on alluvial fans 

and benches along these streams (figure 13). Crown closure in the streamside areas are from 10 to 

50 percent (USDA Forest Service 2004).

Phytophthora lateralis (PL) is spread via water or soil. A typical spread scenario involves 

infested soil being transported into an uninfested area on a vehicle or piece of equipment or, 

potentially, in infested water being transported in the tanks of fire engines or helicopter buckets 

during fire suppression activities. The infested soil falls off of the vehicle or spores are delivered 

via water and the pathogen first infects POC near the site of introduction. New spores from that 

infection are then washed downhill in surface water infecting additional hosts. This is especially 

lethal along drainages and creeks where infested water is channeled and flows near 

concentrations of healthy POC.

Alternative 2 proposed to treat a total of 186 miles of road with a total of 89.5 acres of 

measurable contributing POC and 30 acres of PL infestation.

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Figure 13. Phytophthora lateralis Infested and uninfested sites in the analysis area

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Environmental Consequences

Effects Mechanisms and Analysis Framework

Port Orford cedar program objectives are to maintain POC as an ecologically and economically 

significant species on National Forest System lands. The objective is to provide cost-effective 

mitigation for controllable activities creating appreciable additional risk to important uninfected 

POC, not to reduce all risk to all trees at all cost (USDA Forest Service, USDI Bureau of Land 

Management 2004). Management slows the spread of the non-native pathogen Phytophthora 

lateralis enough to maintain POC’s significant ecological and economic functions, without the 

cost of the management strategy exceeding its effects on the value of these functions.

For the Wild Rivers Ranger District, POC canopy cover of 6 percent or greater is the threshold for 

POC that measurably contributes to meeting management objectives.

The mechanisms for additional spread of P. lateralis are the use of heavy equipment to access and 

remove culverts and to recontour slopes and stormproof roads. The unit of measure is risk of 

spread of P. lateralis in addition to existing uncontrollable risk (such as along a primary access 

road).

Factors Affecting Pathogen Spread - The following factors influence PL spread and 

establishment: Character of site, type of carrier, time of year of transport event, and distance 

traveled and associated time elapsed.

Factors Affecting Risk of Infection - Jules et al. (2002) showed that the incidence of new POC 

infection was positively associated with: (1) distance to the nearest POC, (2) host abundance, and 

(3) catchment area.

Risk Regions - The range of POC is divided up into three main risk regions. The Wild Rivers 

Ranger District is in the Siskiyou Risk Region (with 20 percent high risk sites) (USDA Forest 

Service, USDI Bureau of Land Management 2004).

♦ High risk sites are defined as streamside POC within 100 feet of a road and nonstreamside POC within 50 feet of a road.

♦ Low-risk sites are defined as streamside POC greater than 100 feet from a road and nonstreamside POC greater than 50 feet from a road.

♦ Uninfested 7th field watersheds are watersheds with greater than 50 percent Federal 

ownership and with greater than 100 federal acres in stands that include POC, where at 

least the Federal lands are uninfested or essentially uninfested with PL. A map of all 

uninfested seventh field watersheds identified in the POC FSEIS is at

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5316274.pdf

The Port Orford cedar risk key is used to clarify the environmental conditions that require 

implementation of one or more of the disease controlling management practices listed in the 

Record of Decision (ROD) and Land and Resource Management Plan Amendment for 

Management of Port Orford cedar in Southwest Oregon Siskiyou National Forest (USDA Forest 

Service 2004). Application of the risk key and application of resultant management practices 

makes this project consistent with the mid- and large-geographic and temporal-scale effects 

described by the POC FSEIS analysis, and permits the analysis to tier to the discussion of those 

effects (USDA Forest Service, USDI-Bureau of Land Management 2004).

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Short-term and Long-term Potential for Spread of P. lateralis

Potential for the spread of Phytophthora lateralis, the pathogen that causes Port Orford cedar root 

disease is not simply a function of how many acres are entered. Rather, it is a function of a 

number of factors including acres entered with healthy POC, acres entered with PL, and 

management on these acres. Employing a planned combination of treatments can reduce 

probability of PL spread more than a single treatment. An integrated treatment program that uses 

a combination of reducing access, project scheduling, unit scheduling, washing equipment 

utilizing treated water using Ultra Clorox©, resistant POC planting, routing recreation use, 

restrictions placed on operations during summer rain events, and public education reduces the 

potential for spreading PL.

The Wild Rivers Ranger District is within the Siskiyou Risk Regions for POC. Of the 116,376 

POC acres in the Siskiyou Risk Region 40 percent are considered to be high risk (46,549 acres).

At this time approximately 31 percent of the high-risk site in the region is considered infested 

(12,801 acres). In 100 years, the predicted amount of infested acres in the Siskiyou Risk Region 

is predicted to increase to 51 percent of high-risk sites (approximately 59,439 acres).

These estimates cover all management activity for the Forest Service and BLM. A more complete 

discussion of risk and rate of spread can be found in the POC FSEIS (USDA Forest Service,

USDI Bureau of Land Management 2004).

Alternative 1 – No Action

Direct and Indirect Effects

There would be no direct or indirect effects to the spread of P. lateralis in alternative 1. There 

would be no additional risk of spread of P. lateralis under alternative 1 because no project 

activities would occur within the Sucker Creek Legacy Roads Analysis area. Acres of PL 

infestation would continue to increase over time because of the presence of PL within upper 

portions of watersheds. Over the next 5 to 20 years, 4-5 acres of new root disease would be 

estimated to occur along streams that flow through areas of measurably contributing POC. Less 

than 1 acre of new root disease is expected annually where P. lateralis areas and healthy POC are 

adjacent to each other.

Alternative 2 – Modified Proposed Action

Direct and Indirect Effects

Project design criteria and mitigation measures to prevent or reduce the spread of P. lateralis are 

listed in chapter 2 and apply to all activities proposed for alternative 2 – modified proposed 

action. Therefore, under alternative 2, there would be a very low probability of additional risk of 

spread of P. lateralis (0 to 2 percent probability of occurring). Without project design criteria and 

mitigation applied, the relative probability would be very high (50.1 to 100 percent probability of 

occurring). 

The modified proposed action would reduce the risk of P. lateralis by reducing road densities 

with the Grayback Sucker 5th field watershed. Most importantly, road densities in the six 7th field 

uninfested watersheds would be reduced by 6.6 miles. Putting 7.5 miles of road into storage will 

also provide at least 10 years of reduced risk of new infestations of P. lateralis in the 7th field 

uninfected watersheds. Total reduction of access through decommissioning and storage would 

involve 40 percent of roads in the 7th field uninfested watersheds.

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The reduction of road densities will have indirect effects that would reduce risk of new P. 

lateralis infestations. This reduction of risk would help to preserve the POC cores in the 

watersheds.

Cumulative Effects

The effects of management prior to the 2004 POC Record of Decision are described as alternative

1 in the Final Supplemental Environmental Impact Statement Management of Port Orford cedar 

in Southwest Oregon (USDA Forest Service, USDI Bureau of Land Management 2004) and are 

incorporated by reference.

The 4611 road is an alternative route to the Williams area and serves as part of the Oregon Caves 

National Monument escape route. This road is heavily infested with PL. The 4600 is the main 

route to the Oregon Caves National Monument. This paved route has PL located in Grayback

Campground and on a tributary just west of Caves Creek Campground. The 4612 is the main 

route to the Red Buttes Wilderness from the Illinois Valley. The vast majority of recreational 

traffic is during dry weather conditions, when the spread of P. lateralis is less likely (as discussed 

in detail in the POC FSEIS).

Other projects considered in cumulative effects analysis are vegetation activities as part of the 

East Illinois Managed Stand Environmental Analysis ROD 2007, Plantation and Hazardous Fuels 

Treatment Environmental Analysis ROD 2002 and Sucker Creek Channel and Floodplain 

Restoration Project. All projects utilize an integrated approach to management practices regarding 

reduction of risk of spread of P lateralis. Each projects risk of spread was 0 to 2 percent risk of 

spread therefore the total risk of spread of P. lateralis including this project is 0 to 8 percent.

Application of the risk key found in the POC report and the resultant management practices 

makes the action alternative for this project consistent with the mid- and large-scale geographic

and temporal-scale effects described by the analysis in the POC FSEIS. These estimates cover all 

management activity for the Forest Service and BLM. A more complete discussion of risk and 

rate of spread can be found in the POC FSEIS (USDA Forest Service, USDI Bureau of Land 

Management 2004).

Conclusion

The Sucker Creek Legacy roads modified proposed action would utilize an integrated 

management approach to mitigate the spread of P. lateralis. The combination of project 

scheduling, unit scheduling, control of access, washing, utilizing uninfested water or treated water 

for operations, planting resistant POC, routing recreation use, and applying restrictions during 

summer rain events incorporates key recommendations to reduce the risk of P. lateralis spread or 

introduction of new infestations. This integrated management approach would reduce the risk of 

spread of P. lateralis to 0 to 2 percent POC ROD, Reference 2 (USDA Forest Service 2004).

Wildlife

Introduction

This section discloses the existing conditions for late-successional reserve and special status 

wildlife species and anticipated direct, indirect, and cumulative environmental effects that would 

result from the Sucker Creek Legacy Roads and Trails Project modified proposed action, based 

on the wildlife biological evaluation and specialist report. 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Mitigation Measures and Project Design Criteria

Chapter 2 details the wildlife mitigation measures and design criteria that would be implemented 

to avoid, eliminate, or reduce and minimize any potential adverse effects to wildlife from 

activities under the modified proposed action. All measures are effective and easily 

implementable. Design criteria that support the Siskiyou Land and Resource Management Plan 

(1989) as well as other relevant laws, policies and regulations are available for review in the 

wildlife biological evaluation.

ESA Consultation to Date

To meet ESA Section 7 consultation requirements, road treatments proposed by alternative 2 for 

this project are included in the Forest Programmatic Consultation for Miscellaneous Projects. The 

Biological Assessment for this consultation is currently being developed by the Level 1 Team. 

This consultation with the US Fish and Wildlife Service is expected to be completed by October 

1, 2014. 

Scope of Analysis

Analyses for all wildlife species associated with this project are in the Wildlife Biological 

Evaluation and Specialist Report. Only those species affected or potentially affected by this 

project, as well as late-successional reserve habitat, are discussed in more detail in this EA. 

Special Status Species 

A variety of species and potential habitats occur within in the project area. Table 20 lists all 

federally listed species, Forest Service Region 6 sensitive, management indicator species and 

Northwest Forest Plan Survey and Manage species for the Rogue River –Siskiyou National 

Forest, and known presence of the species or suitable habitat in the project area. Species listed in 

table 22 where column 3 = “Yes” are either present or have habitat present in the Sucker Creek 

Legacy Roads Project area.

The project area is out of the range of species where column 3 = “No”. Therefore the project 

would have no impact on marbled murrelet, California slender salamander, Siskiyou salamander, 

Oregon spotted frog, northern waterthrush, evening fieldslug, Klamath rim pebblesnail, green 

sideband, traveling sideband, Crater Lake tightcoil, Siskiyou Hesperian, seaside hoary elfin, and 

coastal greenish blue butterfly. There is no habitat for these species in the project area and they

will not be addressed further in this report. 

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Table 20. Terrestrial wildlife special status species presence in the Sucker Creek watershed

Wildlife Species (Common Name) Scientific Name Habitat or 

Species 

Present

Federally Threatened Species

Northern spotted owl1 (NSO) Strix occidentalis caurina Yes 

NSO Designated Critical Habitat Yes

Marbled Murrelet (MAMU) Brachyramphus marmoratus No

MAMU Designated Critical Habitat No

Forest Service Sensitive Species 

Pacific Fisher Pekania pennanti (formerly Martes 

pennanti)

Yes

Black Salamander Aneides flavipunctatus Yes

California Slender Salamander Batrachoseps attenuates No

Siskiyou Mtn. Salamander2 Plethodon stormi No

Foothill yellow-legged frog Rana boylii Yes

Oregon Spotted Frog Rana pretiosa No

Northwestern Pond Turtle Actinemys marmorata marmorata Yes

Northern Bald Eagle1 Haliaeetus leucocephalus Yes

American Peregrine Falcon Falco peregrinus anatum Yes

Harlequin Duck Histrionicus histrionicus Yes

Lewis’ Woodpecker Melanerpes lewis Yes

White-headed Woodpecker2 Picoides albolarvatus Yes

Northern Waterthrush Seiurus noveboracensis No

Pallid Bat Antrozous pallidus Yes

Townsend’s Big-Eared Bat Corynorhinus townsendii Yes

Fringed Myotis Myotis thysanodes Yes

California Wolverine Gulo gulo luteus Yes

Evening Fieldslug2 Deroceras hesperium No

Klamath Rim Pebblesnail2 Fluminicola sp. nov. No

Oregon Shoulderband2 Helminthoglypta hertleini Yes

Chace Sideband2 Monadenia chaceana Yes

Green Sideband Monadenia fidelis beryllica No

Traveling Sideband Monadenia fidelis celeuthia No

Crater Lake Tightcoil2 Pristiloma arcticum crateris No

Siskiyou Hesperian Vespericola sierranus No

Johnson's Hairstreak Callophrys johnsoni Yes

Seaside Hoary Elfin Callophrys polios maritime No

Coastal Greenish Blue Butterfly (formerly insular 

blue)

Plebejus saepiolus littoralis No

Gray Blue Butterfly Plebejus podarce Klamathensis Yes

Mardon Skipper Polites mardon Yes

Coronis Fritillary Speyeria coronis coronis Yes

Franklin's Bumblebee Bombus franklini Yes

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Wildlife Species (Common Name) Scientific Name Habitat or 

Species 

Present

Western Bumblebee Bombus occidentalis Yes

California Shield-backed Bug Vanduzeeina borealis californica Yes

Siskiyou Short-horned Grasshopper Chloealtis aspasma Yes

Management Indicator Species

Black-tailed deer Odocoileus hemionus colubianus Yes

Roosevelt elk Cervus elephus roosevelti Yes

American marten Martes americana Yes

Osprey Pandion haliaetus Yes

Pileated woodpecker and other woodpeckers Dryocopus pileatus Yes

Survey and Manage, Protection Buffer and 

Other NWFP special status

Oregon red tree vole (Xeric zone) Arborimus longicaudus Yes

Del Norte Salamander Plethodon elongatus Yes

Flammulated owl Otus flammeolus Yes

Great gray owl Strix nebulosa Yes

Bats (fringed, long-eared, and long-legged myotis; silverhaired, pallid, and Townsend’s big-eared bats)

Yes

1 Also a Forest management indicator species

2 Also a survey and manage species

Additional Species Associated with the Project Area

This project would not impact the following additional species because although they are 

associated with habitats that are present in the project area, they would be unaffected by project

activities. These species will not be analyzed further in this report. 

♦ California wolverine

♦ Peregrine falcon

♦ Harlequin duck

♦ California shield-backed bug

♦ Coronis fritillary

♦ Siskiyou short-horned grasshopper

Effects Common to Both Alternatives

Disturbance to terrestrial wildlife caused by roads and motorized use of roads can be classified 

into three general categories (Gaines et al. 2003). First is the change in habitat caused by the 

physical location of the road where vegetation is cleared and the soil surface covered or 

compacted. Vegetation is diminished or converted to different vegetation types and litter or trash 

may be present. Roadways are also susceptible to the establishment and spread of invasive plant 

species. The second type of disturbance is the physiological reaction (increased stress, alertness, 

flight) to the animals’ perception of traffic or human presence on roads. This seems to depend on 

the individual’s familiarity with the location and frequency of road use. An animal’s response to 

this type of disturbance is usually avoidance of the roadway and sometimes a change in use of 

otherwise suitable habitat in the vicinity of the roadway. The degree of disturbance response 

varies for different species and is the topic of many studies, particularly elk, deer, and many 

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carnivores. This type of disturbance has also been documented to disrupt animal breeding and 

bird nesting. (MacAurthur et al. 1982; Gabrielson and Smith 1995; Wasser et al. 1997 as cited in 

Gaines et al. 2003; Taylor and Knight 2003; Wisdom et al. 2004; George and Crooks 2006; Riley 

2006).

Considerations for Cumulative Effects

Cumulative effects are evaluated based on direct and indirect effects of proposed project activities 

in conjunction with similar effects of other past, present or foreseeable future activities within a 

common area of influence or occurring in a similar timeframe. For this project, effects such as 

localized, short-term disturbance of aquatic habitat at culvert locations during low summer flows 

would be considered with other projects that may impact aquatic habitat in the same stream 

within the same timeframe. For wildlife, the area considered for cumulative effects varies by 

species based on habitat requirements, mobility of the animals, and the level of effects evaluation 

based on status. For example, effects to management indicator species are considered for the 

population and habitat distribution at the forest level.

Other Federal actions considered within the Sucker Creek Legacy Roads project area that would 

result in similar impacts to wildlife include the 5-acre Cedar Gulch Placer Mining project in 

Sucker Creek and the Sucker Creek Channel and Floodplain Restoration project. In addition, 

ongoing regulated placer mining and suction dredging, and manual gold panning occurs in 

streams throughout the project area.

Removal of hazard trees at developed recreation sites and along roads open for public use occur 

annually with applied design criteria and mitigations for resource impacts. Additional road 

maintenance activities such as culvert cleaning, removal of fallen trees, brushing and surface 

grading also occur on open roads annually as needed. These activities also require design criteria 

to minimize or avoid resource impacts.

Approximately 480 acres of the Sucker Creek watershed is the Oregon Caves National 

Monument. For this analysis, it is assumed that management of these lands would continue to 

serve public recreation and resource conservation objectives designed to minimize impacts to 

wildlife species. Existing road use is expected to continue with no anticipated new road 

construction.

Approximately 2,890 acres within the Sucker Creek watershed are privately owned. It is assumed 

that timber harvest activity and mining have occurred on most of these lands in the past and will 

continue indefinitely. It is also assumed that existing roads on these lands will continue to be used 

and contribute to road related impacts at existing levels.

Effects on Late-Successional Reserves (LSR)

East IV/Williams-Deer LSR

The East IV/Williams-Deer LSR spans National Forest and BLM lands from the headwaters of 

the West Fork and East Fork of the Illinois River in Del Norte County, California just east of 

Oregon Mountain, eastward to the ridgeline dividing the Sucker Creek watershed from Carberry 

Creek watershed on the Siskiyou Mountains Ranger District, then northward onto BLM lands in 

the Williams Creek, Murphy Creek and Deer Creek watersheds. The East IV portion of this LSR 

is approximately 62,809 acres of federal lands and the Williams-Deer portion is 59,717 acres.

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The East IV portion of this LSR is within the Sucker Creek watershed analysis area and supports 

northern spotted owls, fishers, marten, bats, goshawks, mollusks and other species associated 

with late successional habitat.

The Southwest Oregon Late Successional Reserve Assessment (USDA Forest Service, 1995) 

estimated that the LSR is 35 percent managed stands and approximately 36 percent 

late-successional forest, of which 7 percent is interior late-successional habitat. This LSR 

provides high elevation true fir forest connectivity between the mountains of the eastern Illinois 

Valley and the coastal part of the Siskiyou Mountains. It also provides connectivity between the 

Rogue and Illinois River Valleys and between the BLM, Klamath National Forest, and Six Rivers 

National Forest. According to the LEMMA Gradient Nearest Neighbor method (GNN) vegetation 

2000 dataset developed by Oregon State University for the Klamath Province, 

(http://www.fsl.orst.edu/lemma/), approximately 19,375 acres of this LSR within the Sucker 

Creek /Grayback subwatersheds is identified as late successional and old growth habitat (LSOG = 

‘Y’).

In the Sucker Creek watershed, this LSR serves an “elevator effect” through corridors of latesuccessional forest habitat from lower elevations near the Illinois Valley floor to the ridgelines of 

these watersheds at over 5000 feet. These habitat corridors allow species to respond to seasonal 

temperature changes, precipitation and food availability.

According to current Forest GIS data, there are approximately 216 miles of roads in the entire 

East IV LSR. Approximately 113 of these miles are within the Sucker Creek Legacy Roads 

project area. The East IV LSR comprises approximately 29,450 acres (46 square miles) of the 

project area with an existing road density of approximately 2.5 miles/square mile.

The Grayback/Sucker Pilot Watershed Analysis (USDA Forest Service 1995) compared the 

structure and connectivity of older forest habitat in these watersheds between 1948 and 1995. By 

1995, the forest was much more fragmented with fewer large patches of older forest habitat than 

in 1948. In fact, the analysis found virtually no contiguous patches of this habitat greater than 500 

acres in these watersheds attributed to past timber harvest and road building. The majority of 

existing large patches older forest habitat in these subwatersheds is at higher elevations in the 

white fir forest types. LSR management objectives emphasize maintenance and development of 

late successional habitat. Because the East IV LSR has a history of extensive timber production 

and fire exclusion, there is a need to retain adequate road access to areas that require intentional 

vegetation management in order to restore and enhance forest succession and retain special 

habitats such as hardwoods and meadows (NFWP ROD, 1994 pp B-4 thru B-9). Silvicultural 

treatments in LSR may occur in stands up to 80 years old regardless of the origin of the stands 

(human or natural) and include thinning and prescribed burning. The purpose of these treatments 

must benefit the creation or maintenance of late successional habitat (NFWP ROD, 1994 p C-12).

In addition, existing roads in this LSR provide access to existing developed recreation 

opportunities, administrative facilities and the Oregon Caves National Monument, mining claims, 

and private timber lands.

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Alternative 1 – No Acton

Direct, Indirect and Cumulative Effects

There are no direct or indirect effects on late-successional habitat from taking no action. There 

would be no project activities additive to effects of ongoing mining or road maintenance that 

would cumulatively impact late-successional habitat within the East IV LSR.

Alternative 2 – Modified Proposed Action

Direct and Indirect Effects

Proposed stormproofing would have no direct effects on late-successional habitat and may 

indirectly have beneficial effects where drainage problems are repaired and prevent or minimize 

potential storm damage to riparian habitat within the LSR. Road storage, decommissioning and 

conversion of roads to trails would remove 39 miles of open roads from the East IV LSR which 

would reduce road density from 2.5 to 1.6 miles per square mile within this LSR in the project

area. However, road density would slightly increase in the future were roads in storage to be 

reopened for project work, but it is not likely that they would all be reopened at the same time.

Furthermore, proposed road storage and decommissioning under alternative 2 would result in a 

reduction of the influence of roads on habitat quality within LSR in the analysis area from the 

existing 14 percent to 12 percent though some of this influence would also return in the future 

where stored roads would be opened for projects. Proposed storage, decommissioning and 

conversion of roads to trails would reduce acres of potential habitat avoidance in the LSR from 44

percent to approximately 31 percent again with the caveat that some would return where roads in 

storage are reopened for future projects. 

Implementation of Sucker Creek Legacy Roads Project alternative 2 would benefit the East IV 

LSR by reducing road density and habitat disturbance and degradation caused by roads while 

retaining adequate access for existing resource use, administrative sites, and vegetation 

management that would also benefit LSR in the future as described in the vegetation management 

section of this EA.

Cumulative Effects

There are no direct or indirect effects to LSR from alternative 2 that would be additive to 

cumulative effects to late-successional habitat from other projects such as mining and annual road 

and recreation site maintenance.

Conclusion

Implementation of alternative 1 would be neutral to late-successional reserve values while 

implementation of alternative 2 would be beneficial to LSR values as a result of reducing roadrelated effects to late-successional habitat while retaining adequate access for future LSR habitat 

enhancement and protection from wildland fire.

Effects for Northern Spotted Owl (Federally Listed Species) and 

Habitat

Northern Spotted Owl 

Status: Federal – Threatened; State of Oregon – Threatened

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Northern Spotted Owl Sites within the Sucker Creek Legacy Roads Project Area

The Forest northern spotted owl database identifies 20 spotted owl sites within the project area, 

14 of which are in the East IV LSR. The 1.3 mile home ranges for 5 additional sites overlap roads 

proposed for treatment by this project. Together, these 25 sites are locations with evidence of 

continued use by spotted owls, including breeding, repeated location of a pair or single birds 

during a single season or over several years, presence of young before dispersal, or some other 

strong indication of continued occupation. The majority of these sites were established through 

protocol surveys completed in the late 1980s and early 1990s. There have been no protocol 

surveys completed for the Sucker Creek Legacy Roads project. As a consequence, unsurveyed 

suitable nesting, roosting and foraging (NRF) habitat in the analysis area is considered occupied 

by spotted owls for the purposes of this analysis.

Northern Spotted Owl Habitat in the Project Area

For this analysis, the area used to evaluate effects to northern spotted owl habitat is within a 1.3 

mile buffer of roads proposed for treatments under alternative 2. This buffer distance represents 

the estimated home range size for northern spotted owls in the Oregon Klamath Province and 

extends beyond the boundary of the Sucker Creek watershed. The total analysis area is 72,710 

acres. Approximately 76 percent of it is Rogue River-Siskiyou National Forest System lands.

Table 21 displays owl habitat acreages on NFS lands within this analysis area by land allocation 

and designated critical habitat for spotted owls.

Table 21. Acres of northern spotted owl habitat within the spotted owl analysis area and designated 

critical habitat

Sucker Creek Legacy Roads Project 

Spotted Owl Analysis Area

Total

Acres*

NRF 

Habitat

Acres*

(% total)

Total 

Capable 

Habitat

Acres*

(% total)

Dispersal 

Only

(% total)*

All Ownerships 72,710 46,798 (64) 10,160 (14) 12,246 (17)

Rogue River-Siskiyou NF 51,770 35,395 (68) 6,464 (12) 7,410 (14)

RRSNF Land Management Allocations 

Late-Successional Reserves 26,286 17,248 (66) 3,593 (14) 4,248 (16)

Riparian Reserves (within Matrix only) 2,481 1,739 (70) 239 (10) 400 (16)

Matrix 6,252 3,698 (59) 1,071 (17) 1,084 (17)

Designated Critical Habitat for Northern Spotted Owl within Sucker Creek 5th field watershed

Critical Habitat Subunit 9 KLW-4 24,927 16,967 (68) 3,094 (12) 3,623 (14)

*(Source: Interagency Regional Monitoring Program owl habitat relative habitat suitability model and habitat classification 

“owlhabrhs1”).

Nesting, Roosting and Foraging Habitat

Nesting, roosting and foraging habitat for northern spotted owls is used for nesting, roosting, and 

foraging and may also function as dispersal habitat. Generally, this habitat is multistoried, 80 

years old or more with at least 60 percent canopy closure; a high incidence of large trees with 

various deformities (e.g., large cavities, broken tops, mistletoe infestations, and other evidence of 

decadence); large snags; large accumulations of fallen trees and other woody debris on the 

ground; and sufficient open space below the canopy for owls to fly (Thomas et al. 1990).

Nesting, roosting and foraging habitat in southwest Oregon is typically mixed-conifer habitat 

with recurrent fire history, patchy habitat components, and a high incidence of wood rats or red 

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tree voles, which are high quality spotted owl prey species in the area. It may consist of 

somewhat smaller tree sizes and more tree species diversity within each stand than NRF habitat 

northwestern Oregon. One or more important habitat components, such as dead down wood, 

snags, dense canopy, multistoried stands, or mid-canopy habitat, might be lacking or even absent, 

however, southwest Oregon NRF can support nesting owls if those components are available 

across the immediate landscape.

The Forest generally defines spotted owl NRF habitat in the Oregon Klamath Province as stands 

with an average of 21 inches DBH with a minimum canopy closure of 60 percent. For this 

analysis, a habitat layer from the Pacific Northwest Interagency Regional Monitoring Program 

derived from the LEMMA Gradient Nearest Neighbor method (GNN) vegetation 2000 dataset 

developed by Oregon State University (http://www.fsl.orst.edu/lemma/) was used. 

Capable habitat for the northern spotted owl is forest land that is currently not habitat but can 

become NRF or dispersal in the future, as trees mature and canopy fills in.

Dispersal is a subcategory of “all dispersal” habitat for northern spotted owls. Dispersal habitat is 

forested habitat with canopy closure more than 40 percent, average diameter greater than 11 

inches, and flying space for owls in the understory but does not provide the components found in 

NRF. It provides temporary shelter for owls moving through the area between NRF habitat and 

some opportunity for owls to find prey, but does not provide all requirements to support an owl 

throughout its life (Thomas et al. 1990). Owls also disperse through NRF habitat, but the term 

“dispersal-only” is used to refer to habitat that does not meet NRF habitat criteria, but has 

adequate cover to facilitate movement between areas of NRF habitat.

Designated Critical Habitat 

Designation of critical habitat serves to identify lands considered essential for the conservation 

and recovery of listed species. The functional value of critical habitat is to preserve options for 

the species’ eventual recovery. Critical habitat for the northern spotted owl was first designated in 

1992 with the most recent revision finalized on December 4, 2012 which became effective 

January 3, 2013 (77 FR 233: 71876-72068).

Critical habitat is defined as (1) specific areas within the geographical area occupied by the 

species at the time it is listed, on which are found those physical or biological features that are 

essential to the conservation of the listed species and may require special management 

considerations or protection, and (2) specific areas outside the geographical area occupied by the 

species at the time it is listed that are essential for the conservation of a listed species. Regulations 

focus on the “primary constituent elements,” or PCEs, in identifying these physical or biological 

features. The PCEs essential to the conservation of the northern spotted owl are forested lands 

that are used or likely to be used for nesting, roosting, foraging, or dispersing. 

The Sucker Creek Legacy Roads Project is located within proposed Critical Habitat Unit (CHU) 9 

subunit 4, referred to as “Klamath West 4” ( KLW-4). CHU 9 contains 1,290,687 ac (522,322 ha) 

of the western portion of the Klamath Mountains Ecological Section M261A, based on section 

descriptions of forest types from Ecological Subregions of the United States (McNab and Avers 

1994c, Section M261A). A long north-south trending system of mountains (particularly South 

Fork Mountain) creates a rainshadow effect that separates this region from more mesic conditions 

to the west. This region is characterized by very high climatic and vegetative diversity resulting 

from steep gradients of elevation, dissected topography, and the influence of marine air (relatively 

high potential precipitation). 

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The KLW-4 subunit consists of approximately 158,402 acres in Josephine and Jackson Counties, 

Oregon, and Del Norte and Siskiyou Counties, California and includes lands managed by the 

Forest Service, BLM and the National Park Service managed as directed by the NWFP (1994).

Special management considerations or protection are required in this subunit to address threats 

from current and past timber harvest, losses due to wildfire, effects on vegetation from fire 

exclusion, and competition with barred owls. This subunit is expected to function for 

demographic support to the overall spotted owl population and provide north-south and east-west 

connectivity between subunits and critical habitat units.

The Service has determined that all unoccupied and likely occupied areas in this subunit are 

essential for conservation of the species to meet the recovery criterion that calls for continued 

maintenance and recruitment of spotted owl habitat (USFWS 2011, RA-32). The increase and 

enhancement of spotted owl habitat is necessary to provide long-term viability of populations of 

spotted owls by supporting population expansion, successful dispersal, and buffering from 

competition with barred owls. More detailed information about critical habitat is described in the 

BE.

Alternative 1 – No Action

Direct, Indirect and Cumulative Effects

There would be no effects on spotted owls from taking no action. If occurring, disturbance would 

continue at existing levels. Existing use of open roads for recreation, mining access, private land 

access, and administrative purposes within the spotted owl analysis area is expected to continue 

indefinitely. Federal activities that require use of these roads would continue to implement 

measures to minimize effects to spotted owls. There are no direct or indirect effects to spotted 

owls from alternative 1 that would be additive to cumulative effects when combined with past, 

present or foreseeable activities in the Sucker Creek spotted owl analysis area.

Alternative 2 – Modified Proposed Action

Direct and Indirect Effects

Potential direct effects to spotted owls under alternative 2 include short-term vegetation removal 

and noise and visual disturbance.

In summary, vegetation removal would be limited to trees less than 80 years in age from culvert 

locations where drainage improvements are needed, or small trees growing in roads proposed for 

decommissioning or storage that may be cut to access culverts and other treatments locations on 

the road in order to restore drainage and soil productivity. Short-term impacts of the 

decommissioning and storage activities include removal of vegetation and trees less than 80 years 

that occur within the roadbed or fill that would be treated to improve drainage and soil 

productivity. The total direct impacts of vegetation removal from proposed road treatments would 

affect less than 4 acres of vegetation less than 80 years in age that may provide dispersal or 

foraging habitat throughout the project area. This acreage is spread throughout the project area 

among small sites along existing roads, and therefore would not measurably impact the 

functionality of surrounding NRF or dispersal owl habitat. Impacts to primary prey such as wood 

rats and red tree voles from vegetation clearing for road and culvert treatments and associated 

noise are anticipated to be minimal because these species are expected to use better quality 

habitat away from roads.

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Activities that produce noise above ambient levels during the spotted owl breeding season may 

cause owls to abandon a nest site or flush from a nest and result in reproductive failure if the 

noise occurs within the disturbance distances during the critical breeding period. Use of heavy 

equipment or chainsaws and other mechanized equipment that produce noise above ambient 

levels for project activities would be restricted between March 1 and June 30 unless the district 

biologist or designee determines that a particular project site is not within the disturbance distance 

of NRF habitat or protocol surveys determine that NRF habitat next to a site is not occupied. This 

seasonal restriction would minimize impacts to spotted owls from noise and visual disturbance.

Cumulative Effects

Ongoing Forest implemented and permitted road maintenance, mining access, recreation and 

existing levels of road use in the project area are expected to continue with design criteria where 

applicable to minimize impacts to spotted owls and their habitat.

Alternative 2 would implement a seasonal restriction on noise producing activities during the 

critical breeding season for owls. Vegetation removal for culvert and drainage improvements and 

road decommissioning and storage activities are expected to maintain the functionality of existing 

owl habitat. Implementation of alternative 2 would benefit owls and prey species where roads are 

decommissioned or put into storage thereby reducing the amount of habitat potentially avoided by 

these animals. There are no direct or indirect effects of the project that would be additive to past, 

present or foreseeable activities that would contribute to cumulative effects to spotted owls.

Determination for Spotted Owls 

The Forest expects no appreciable effects from implementation of the Sucker Creek Legacy 

Roads Project alternative 2 and makes the determination of “May Affect, Not Likely to 

Adversely Affect” northern spotted owls or their habitat with the following rationale:

1. Vegetation removal for culvert and road decommissioning work may occur at the edges of 

existing NRF and dispersal habitats, but would not result in a measurable change to the 

functionality or reduce the canopy cover of these habitat types where they exist next to roads.

2. Project activities that produce noise above ambient levels within disturbance distances would 

be restricted between March 1 and June 30, the critical breeding season for spotted owls. This 

means no operation of chainsaws or other mechanized equipment within 65 yards of 

unsurveyed NRF habitat or operation of heavy equipment within 35 yards of NRF habitat 

unless protocol surveys determine the habitat to be unoccupied by spotted owls.

3. Proposed road decommissioning and storage would benefit owls and their prey in the long 

term where road impacts such as loss of snags and large down wood, potential habitat 

avoidance due to disturbance would diminish and habitat quality would improve. 

Designated Critical Habitat

Alternative 1 – No Action

Direct, Indirect and Cumulative Effects

Potential direct effects to designated critical habitat for spotted owls would include any 

disturbance or removal of primary constituent elements described in the BE.

Under alternative 1, designated critical habitat within 164 feet of currently open roads would 

continue to experience existing road influence on habitat quality. The impacts of hazard tree 

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removal, permitted firewood gathering, mining access, road maintenance activities and general 

use of open roads are evaluated and designed to minimize or avoid effects to critical habitat under 

separate consultation with the USFWS. Some roads may be closed in the future under the Forest 

travel management plan or smaller projects which would improve local habitat quality. 

There are no direct or indirect effects from alternative 1 that would be additive to cumulative 

effects to designated critical habitat when combined with past, present or foreseeable activities in 

the Sucker Creek spotted owl analysis area.

Alternative 2 – Modified Proposed Action

Direct and Indirect Effects

Potential direct effects of alternative 2 to designated critical habitat for spotted owls would be any 

impacts from vegetation removal for culvert work and road decommissioning or storage to 

primary constituent elements described in the BE.

In summary, vegetation removal would be limited to trees less than 80 years in age from culvert 

locations where drainage improvements are needed, or small trees growing in roads proposed for 

decommissioning or storage that may be cut or removed for surface ripping to restore drainage 

and soil productivity. Removal of vegetation for culvert work is not expected to appreciably 

impact primary constituent elements or the functionality of critical habitat because these are trees 

that have grown in the road fill since road construction, and the clearings would be small and 

scattered throughout the project area. This would be vegetation that provides marginal dispersal 

or forage habitat due to the influence of roads. Trees that are removed at these locations would be 

distributed to provide woody debris in riparian areas, critical owl habitat and late successional 

habitat. Because this acreage is spread throughout the project area into small sites along roads and 

not all of the culverts would require this amount of vegetation removal, the functionality of 

critical habitat is expected to be maintained after project implementation. 

Cumulative Effects

Ongoing Forest implemented and permitted road maintenance, mining access, recreation and 

existing levels of road use in the project area are expected to continue with design criteria where 

applicable to minimize impacts to designated critical habitat for spotted owls. 

Alternative 2 would include placement of any excess large woody material from vegetation 

removal from culvert and drainage improvements within critical habitat to supplement primary 

constituent elements. Implementation of alternative 2 would benefit critical habitat where roads 

are decommissioned or put into storage thereby increasing the amount of quality habitat available 

for owls over the long term. There are no direct or indirect effects of the project that would be 

additive to past, present or foreseeable activities and contribute to cumulative effects to

designated critical habitat for spotted owls.

Determination for Designated Critical Habitat

The Forest expects no appreciable effects from implementation of the Sucker Creek Legacy 

Roads Project alternative 2 and makes the determination of “May Affect, Not Likely to 

Adversely Affect” designated critical habitat for northern spotted owls with the following 

rationale:

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1. Vegetation removal for culvert and road decommissioning work would occur at small 

locations spread throughout critical habitat unit KLW-4 for a maximum of 4 acres and the 

functionality of this critical habitat unit would be maintained.

2. Trees removed from culvert work locations within KLW-4 would be placed for woody debris 

within the unit to supplement primary constituent elements of critical habitat. 

3. Proposed road decommissioning and storage would benefit critical habitat in the long term 

where road impacts such as loss of snags and large down wood, potential habitat avoidance 

due to disturbance would diminish and habitat quality would improve. 

Effects on Region 6 Sensitive Species

Background information about species listed below is primarily from the Region 6 Interagency 

Special Status and Sensitive Species Program website: http://www.fs.fed.us/r6/sfpnw/issssp/ , 

USFWS Species Fact Sheets, and Species Conservation Assessments on file in the project record.

Black Salamander

Status: USDA Forest Service Region 6 – Sensitive; U.S.D.I. Bureau of Land Management, 

Oregon – Bureau Sensitive; Oregon State Sensitive - Peripheral; Oregon State imperiled 

(S2), list 2 – taxa that are threatened with extirpation or presumed to be extirpated from the 

state of Oregon.

The species complex occurs from southwestern Oregon to northwestern California, with several 

disjunct populations including one as far south as Santa Cruz, California, although a potential to 

describe 2-4 species across this area is currently being considered. In Oregon, the current known 

range of the species is about 187,400 ha (463,075 acres), primarily in the Applegate watershed of 

Jackson County, Oregon, adjacent to the east of Sucker Creek watershed. However, a portion of 

this range is uncertain at this time. The five site records nearest Cave Junction are uncertain (R.B. 

Bury, R.S. Nauman, D.R. Clayton, pers. comm.). These localities and this portion of the potential 

species range warrant confirmation; black salamanders can be confused with other species, such 

as its congener the clouded salamander, A. ferreus, which is thought to occur at these locations.

One of these unconfirmed locations is along Sucker Creek.

Surveys for black salamanders were not conducted for the Sucker Creek Legacy Roads Project. 

Potential habitat for the black salamander in the project area occurs in riparian vegetation, rocks 

and litter at culvert locations, and in moist, rocky road cuts. As mentioned previously, there is one 

unconfirmed black salamander location in the Sucker Creek drainage.

Alternative 1 

Direct and Indirect Effects

Implementation of alternative 1 would result in continued use of all roads currently open unless 

otherwise closed by the Forest Travel Management process or other smaller projects. Direct 

effects to salamanders include potential harm or mortality if salamanders are on the road during 

traffic, and reduction of habitat quality adjacent to roads associated with pollution from road use.

NWFP standards and guidelines for riparian reserves prohibit removal of down woody debris 

from riparian reserves unless it is excessive and Aquatic Conservation Strategy objectives would 

not be adversely affected (USDA and USDI 1994). The impacts of hazard tree removal, permitted 

firewood gathering, road maintenance activities and general use of open roads are evaluated and 

designed to minimize or avoid effects to riparian habitat in order to comply with the NWFP 

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Aquatic Conservation Strategy and because it is important to numerous special status species.

Indirect effects of taking no action to improve drainage problems such as undersized culverts may 

result in disruption of riparian habitat if culverts become clogged or overwhelmed during storm 

events, and possible mortality of salamander eggs or larvae from fast-flowing water or sediment 

delivery associated with drainage problems.

Cumulative Effects

Forest-implemented projects in riparian habitat would include measures to protect and minimize 

impacts to riparian habitat and associated species. Ongoing mining, recreation and existing levels 

of road use in the project area are expected to continue and may have negative impacts on 

riparian habitat. Indirect effects that result in disruption of riparian habitat or increased sediment 

delivery from taking no action under alternative 1 may be additive to cumulative effects to black 

salamanders in the Sucker Creek Legacy Roads Project area.

Conclusion

Implementation of Sucker Creek Legacy Roads Project alternative 1 “May Impact Individuals 

and or Habitat but not likely to cause a trend to federal listing or a loss of viability to the 

population or species” of black salamanders.

Alternative 2

Direct and Indirect Effects

Black salamander adults and young may be found in culverts during proposed culvert treatments.

It has been found that salamanders often utilize pipe culverts with large debris in them and open 

bottom (arch) culverts which are believed to facilitate movement of these animals through culvert 

structures better than culverts with overhang or lack of debris or streambed substrate which is 

often a problem in undersized culverts (Sagar 2004, White 2004, Ward 2005, Arizona Game and 

Fish 2006).

Any salamanders present in the culverts, vegetation, down wood or other surface substrate could 

be harmed or harassed during proposed activities such as culvert removal, replacement, and 

cleaning, and ditch cleaning and road fill clearing for drainage improvement. In addition, 

vegetation clearing for culvert work would remove potential habitat such as down woody debris 

from these sites and possibly change the site microclimate by increasing exposure sunlight and 

reducing moisture. This may impact individuals or habitat present at numerous culvert locations 

in the project area (potentially 465 sites). It is not expected that all of these sites provide suitable 

habitat conditions, especially where these activities would occur in the late summer before 

substantial fall rains. The estimated maximum amount of vegetation clearing for culvert work is 4 

acres distributed throughout the project area. Using the forest riparian reserve GIS data for all 

streams and waterbodies as a proxy for riparian habitat, there are approximately 10,662 acres of 

riparian habitat within the forest boundary in the project area. Potential impacts on up to 4 acres 

of riparian habitat at culvert locations within the project area would affect less than 0.5 percent of 

the available riparian habitat in the project area. The presence of black salamanders has not been 

confirmed in this project area, so there is a low likelihood that individuals of this species would 

be directly impacted by project activities. Any salamanders found during culvert work would 

either be left unharmed or moved to suitable moist, shaded habitat adjacent to but undisturbed by 

the work site if there is potential for harm.

Long-term potential beneficial effects of alternative 2 to black salamanders is that proposed 

culvert replacements will ensure right-sized culverts that minimize potential for disruption of 

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stream habitat conditions, high flow velocities through the culverts and will be designed to 

maintain stream habitat connectivity. Road decommissioning and storage would improve riparian 

habitat quality and availability by removing the effects of roads. Culvert removal associated with 

proposed road decommissioning would result in long-term restoration of natural stream habitat 

structure and riparian habitat quality.

Cumulative effects

Forest implemented projects in riparian habitat would include measures to protect the quality of 

the habitat and minimize impacts to associated species. Ongoing mining, recreation and existing 

levels of road use in the project area are expected to continue and may have negative impacts on 

riparian habitat. Potential impacts to salamanders from removal of riparian vegetation and 

disturbance of culvert locations in the project area under alternative 2 may be additive to 

cumulative effects to black salamander habitat in the Sucker Creek watershed. 

Conclusion

Considering the direct, indirect and cumulative effects and long-term beneficial effects of 

alternative 2 and the lack of confirmed occurrence of black salamanders in the project area, 

implementation of Sucker Creek Legacy Roads alternative 2 “May Impact Individuals and or 

Habitat but not likely to cause a trend to federal listing or a loss of viability to the 

population or species” of black salamanders.

Foothill yellow-legged frog

Status: Federal - USDA FS Sensitive (Region 6); State of Oregon – Vulnerable

The Forest NRIS database contains no records of foothill yellow-legged frogs in the Sucker Creek 

watershed. Stream surveys of Sucker Creek in 2007 did not locate any yellow-legged frogs, but 

did identify suitable frog habitat along Sucker Creek. It is assumed that much of the riparian 

habitat in the project area would be suitable for these frogs.

Alternative 1

Direct and Indirect Effects

Implementation of alternative 1 would result in continued use of all roads currently open unless 

otherwise closed by the Forest Travel Management process or other smaller projects. Direct 

effects to foothill yellow-legged frogs include potential harm or mortality if frogs are on roads 

during traffic, and reduction of riparian habitat quality adjacent to roads associated with pollution 

from road use. As mentioned previously, NWFP standards and guidelines for riparian reserves 

emphasize maintaining habitat quality in riparian reserves to meet Aquatic Conservation Strategy 

objectives. The impacts of ongoing hazard tree removal, permitted firewood gathering, road 

maintenance activities and general use of open roads are evaluated and designed to minimize or 

avoid effects to riparian habitat in compliance with the NWFP Aquatic Conservation Strategy 

(chapter 4) and because it important to numerous special status species. Indirect effects of taking 

no action to improve drainage problems such as undersized culverts may result in disruption of 

riparian habitat if culverts become clogged or overwhelmed during storm events, and possible 

mortality of frog eggs or larvae from fast-flowing water or increased sediment delivery associated 

with drainage problems.

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Cumulative Effects

Forest-implemented projects in riparian habitat would include measures to protect and minimize 

impacts to riparian habitat and associated species. Ongoing mining, recreation and existing levels 

of road use in the project area are expected to continue and may have negative impacts on 

riparian habitat. Indirect effects that result in disruption of riparian habitat or increased sediment 

delivery from taking no action under alternative 1 may be additive to cumulative effects to 

foothill yellow-legged frogs in the Sucker Creek Legacy Roads project area.

Conclusion

Implementation of Sucker Creek Legacy Roads Project alternative 1 “May Impact Individuals 

and or Habitat but not likely to cause a trend to federal listing or a loss of viability to the 

population or species” of foothill yellow-legged frogs.

Alternative 2

Direct and Indirect Effects

Adult frogs including foothill yellow-legged frogs are often found in and around culverts of all 

types as they move through riparian habitat corridors (Yanes 1995, Peek and Kahndwala 

2006,Garcia and Associates 2008). Culverts can impede passage of frogs through riparian habitat 

if they are installed with a steep gradient or if their outlet overhangs the stream.

Any frogs, larvae or egg masses present in or around culverts proposed for treatment, could be 

harmed or killed during activities such as culvert removal, replacement, and cleaning, and ditch 

cleaning and road fill clearing for drainage improvement. Any frogs seen on-site during proposed 

treatment activities will be moved to suitable adjacent habitat to avoid direct harm. In addition, 

vegetation clearing for culvert work may remove or disturb riparian vegetation and possibly 

change the site microclimate by increasing exposure sunlight and reducing moisture. Frogs do 

bask in sunlight so the change in microclimate may or may not be a negative impact for frogs. 

The estimated maximum amount of vegetation clearing for culvert work is 4 acres distributed 

throughout the project area. Using the forest riparian reserve GIS data for all streams and 

waterbodies as a proxy for riparian habitat, there are approximately 10,662 acres of riparian 

habitat within the forest boundary in the project area. Potential impacts on up to 4 acres of 

riparian habitat at culvert locations within the project area would affect less than 0.5 percent of 

the available riparian habitat in the project area.

Long-term potential beneficial effects of alternative 2 to foothill yellow-legged frogs is that 

proposed culvert replacements will ensure right-sized culverts that minimize potential for 

disruption of stream habitat conditions, high flow velocities through the culverts and will be 

designed to maintain stream habitat connectivity. Road decommissioning and storage would 

improve riparian habitat quality and availability by removing the effects of roads. Culvert 

removal associated with proposed road decommissioning would result in long-term restoration of 

natural stream habitat structure and riparian habitat quality.

Cumulative Effects

Forest implemented projects in riparian habitat would include measures to protect the quality of 

the habitat and minimize impacts to associated species. Ongoing mining, recreation and existing 

levels of road use in the project area are expected to continue and may have negative impacts on 

riparian habitat and frogs. Potential direct impacts to foothill yellow-legged frogs from proposed 

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culvert work alternative 2 may be additive to cumulative effects to foothill yellow-legged frogs in 

the Sucker Creek watershed.

Conclusion

Considering the direct, indirect and cumulative effects and long-term beneficial effects of 

alternative 2 to riparian habitat, implementation of Sucker Creek Legacy Roads alternative 2

“May Impact Individuals and or Habitat but not likely to cause a trend to federal listing or 

a loss of viability to the population or species” of foothill yellow-legged frogs.

Northwestern Pond Turtle

Status: Federal - USDA FS Sensitive (Region 6); State of Oregon – Critical

The Forest NRIS wildlife database has no records of northwestern pond turtles in the project area. 

The nearest recorded locations are approximately 11 miles northwest of the project area in 

Josephine Creek. Potential suitable habitat in the project area for this species is present in eddies 

and backwater areas of the larger creeks such as Sucker Creek where sand bars and soft substrate 

is available in the creek channels. Other small wet or ponded areas and lakes in the project area 

also provide potential habitat.

Alternative 1

Direct and Indirect Effects

Implementation of alternative 1 would result in continued use of all roads currently open unless 

otherwise closed by the Forest Travel Management process or other smaller projects. Direct 

effects to the northwestern pond turtle include potential harm or mortality if turtles are on roads 

during traffic, and reduction of riparian habitat quality adjacent to roads associated with pollution 

from road use. As mentioned previously, NWFP standards and guidelines for riparian reserves 

emphasize maintaining habitat quality in riparian reserves to meet Aquatic Conservation Strategy 

objectives. The impacts of ongoing hazard tree removal, permitted firewood gathering, road 

maintenance activities and general use of open roads are evaluated and designed to minimize or 

avoid effects to riparian habitat in compliance with the NWFP Aquatic Conservation Strategy and 

because it important to numerous special status species. Indirect effects of taking no action to 

improve drainage problems such as undersized culverts may result in disruption of riparian 

habitat if culverts become clogged or overwhelmed during storm events and wash out or modify 

existing sand bars or pools that provide suitable turtle habitat.

Cumulative Effects

Forest-implemented projects in riparian habitat would include measures to protect and minimize 

impacts to riparian habitat and associated species. Ongoing mining, recreation and existing levels 

of road use in the project area are expected to continue and may have negative impacts on 

riparian habitat. Indirect effects that result in disruption of riparian habitat or increased sediment 

delivery from taking no action under alternative 1 may be additive to cumulative effects to 

northwestern pond turtles in the Sucker Creek Legacy Roads project area.

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Conclusion

Implementation of Sucker Creek Legacy Roads Project alternative 1 “May Impact Individuals 

and or Habitat but not likely to cause a trend to federal listing or a loss of viability to the 

population or species” of northwestern pond turtles.

Alternative 2

Direct and Indirect Effects

As with amphibians, turtles are known to pass through culverts as they move through riparian 

habitat corridors. However, culverts in the Sucker Creek Legacy Roads project area do not 

provide the typical habitat that northwestern pond turtle’s use, except where there may be pools of 

water next to the culverts. 

Any turtles, eggs or young present in or around culverts proposed for treatment, could be harmed

or killed during activities such as culvert removal, replacement, and cleaning, and ditch cleaning 

for drainage improvement. Any turtles found in culverts during culvert work would be moved to 

suitable adjacent habitat to avoid harm. In addition, vegetation clearing for culvert work may 

remove or disturb riparian vegetation and possibly change the site microclimate by increasing 

exposure sunlight and reducing moisture. Turtles bask in sunlight so the change in microclimate 

may not be a negative impact. The estimated maximum amount of vegetation clearing for culvert 

work is 4 acres distributed throughout the project area. Not all of the culvert sites provide suitable 

habitat for these turtles. Using the forest riparian reserve GIS data for all streams and waterbodies 

as a proxy for riparian habitat, there are approximately 10,662 acres of riparian habitat within the 

forest boundary in the project area. Potential impacts on up to 4 acres of riparian habitat at culvert 

locations within the project area would affect less than 0.5% of the available riparian habitat in 

the project area.

Long-term potential beneficial effects of alternative 2 to western pond turtles is that proposed 

culvert replacements will ensure right-sized culverts that minimize potential for disruption of 

stream habitat conditions, high flow velocities through the culverts and will be designed to 

maintain stream habitat connectivity. Road decommissioning and storage would improve riparian 

habitat quality and availability by removing the effects of roads. Culvert removal associated with 

proposed road decommissioning would result in long-term restoration of natural stream habitat 

structure and riparian habitat quality.

Cumulative effects

Forest implemented projects in riparian habitat would include measures to protect the quality of 

the habitat and minimize impacts to associated species. Ongoing mining, recreation and existing 

levels of road use in the project area are expected to continue and may have negative impacts on 

riparian habitat and turtles. Potential direct impacts to western pond turtles from proposed culvert 

work alternative 2 may be additive to cumulative effects in the Sucker Creek watershed though 

not all the culvert locations or affected riparian habitat is suitable for these turtles.

Conclusion

Considering the direct, indirect and cumulative effects and long-term beneficial effects of 

alternative 2 to riparian habitat, implementation of Sucker Creek Legacy Roads alternative 2

“May Impact Individuals and or Habitat but not likely to cause a trend to federal listing or 

a loss of viability to the population or species” of northwestern pond turtles.

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Pacific Fisher

Status: Federal – Candidate; USDA FS Sensitive (Region 6); State of Oregon – Critical

The Pacific fisher was petitioned for federal listing by the Center for Biological Diversity and 

several other environmental organizations in November 2000. After a 12-month review, the U.S. 

Fish and Wildlife Service (USFWS) classified Pacific fishers in the Cascade Range and all areas 

west, to the coast in Oregon and Washington; and in California, the North Coast from Mendocino 

County north to Oregon, east across the Klamath Mountains, across the southern Cascade Range 

and south through the Sierra Nevada as the West Coast Distinct Population Segment. As a result 

the USFWS gave a “warranted but precluded” decision to the petition, designating the West Coast 

DPS a federal candidate species (USFWS 2004).

Currently, there are two documented populations in southern Oregon which appear to be 

genetically isolated from each other (Aubry et al. 2004). This is considered to be due to the 

presence of potentially strong ecological and anthropogenic barriers including the white oak 

savanna habitat of the Rogue Valley and Interstate 5. Based on DNA analyses, individuals in the 

southern Oregon Cascades appear to be descendants of animals re-introduced from British 

Columbia and Minnesota during the late 1970s and early 1980s by the Oregon Department of 

Fish and Wildlife (Drew et al. 2003). Animals in the eastern Siskiyou Mountains of Oregon are 

genetically related to individuals in the northwestern California population, which is indigenous 

(Wisely et al. 2004, Farber and Franklin 2005). For information on fisher habitat and life history 

needs see the wildlife report.

Surveys and Presence in the Project Area

No surveys have been conducted for fisher in the Sucker Creek Legacy Roads project area. There 

is one 1994 record of a fisher observation in the project area. There are known and historic sites 

near HWY 199 at the Oregon/California border, and one in the Headwaters Applegate River 

watershed east of the project area.

The Sucker Creek watershed (the project area) is used as the analysis area for Pacific fishers. 

Suitable habitat for fishers is present throughout the project area. Potential denning and resting 

habitat for this analysis was defined as predominantly conifer forest with greater than or equal to

60 percent canopy closure, and a diameter of greater than or equal to 20 inches d.b.h. The 2000 

LEMMA GNN data estimate 10,323 acres of denning/resting habitat in the project area. Dispersal

and foraging habitat is sapling/pole conifer forest ( 9-19.9 inches d.b.h.) with at least 60 percent

canopy closure. The 2000 LEMMA GNN data estimate 25,711 acres of dispersal/foraging habitat 

mapped within the project area, though practically the entire project area may provide foraging 

opportunities given the general nature of their food habits.

Alternative 1

Direct and Indirect Effects

Implementation of alternative 1 would result in continued use of all roads currently open unless 

otherwise closed by the Forest Travel Management process or other smaller projects. Potential 

direct effects to Pacific fishers would include any disturbance or removal of trees and down wood 

that could potentially serve as denning or resting sites and direct injury or mortality of fishers 

from collision with vehicles. According to the GNN data, approximately 758 acres of potential 

denning/resting habitat and 2,385 acres of potential dispersal/foraging habitat are within 164 feet

of roads proposed for treatment. This represents 7 percent and 9 percent of these habitats 

respectively within the project area. These habitats within 164 feet of currently open roads would 

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continue to experience existing road influence and considered to be of lower quality than the 

same habitat located farther from the roads. Important habitat features for fishers such as trees 

with cavities, snags and down wood are often removed as public hazards or for firewood. The 

impacts of hazard tree removal, permitted firewood gathering, mining access, road maintenance 

activities and general use of open roads are evaluated and designed to minimize or avoid effects 

because these features are important to numerous special status species.

Furthermore, approximately 3,200 acres of potential denning/resting habitat and 8,709 acres of 

potential dispersal/foraging habitat are within 656 feet of roads proposed for treatment which is 

31 percent and 34 percent of these habitats respectively in the analysis area. These habitats within 

200m of open roads may be avoided by fishers, particularly roads that have heavier traffic.

Cumulative Effects

Ongoing Forest implemented and permitted road maintenance, mining access, recreation and 

existing levels of road use in the project area are expected to continue with design criteria where 

applicable to minimize impacts to habitat features important to fishers.

There are no direct or indirect effects from alternative 1 that would be additive to cumulative 

effects to Pacific fishers when combined with past, present or foreseeable activities in the Sucker 

Creek Legacy Roads project area.

Alternative 2

Direct and Indirect Effects

Potential direct effects to Pacific fishers under alternative 2 would include disturbance or removal 

of trees and down wood that could potentially serve as denning or resting sites within the 

footprint of culvert work locations where vegetation in the road fill would be cleared. This would 

include down logs, trees with mistletoe or other platform structures, snags or trees with cavities.

As estimated earlier, if all of the culvert locations were cleared of vegetation to improve drainage 

using a 20-foot by 20-foot footprint, a total of 4 acres of vegetation would be cleared in the entire 

project area. This would be a very small amount of the specific habitats available for fishers in the 

watershed which is considered lower in quality due proximity to open roads. Trees that are cut in 

at these locations would be left in the riparian reserve to provide sufficient coarse woody debris. 

Excess trees would be either placed in LSR habitat to provide sufficient coarse woody debris or if 

the location is in matrix, they may be offered to the public for firewood.

Proposed road decommissioning and storage would remove approximately 212 acres of 

denning/resting habitat and 746 acres of dispersal/foraging habitat from the influences of roads on 

habitat quality. This represents 28 percent and 31 percent reduction of the amounts of these 

habitats respectively, currently within 164 feet of open roads in the project area.

Additionally, this proposed road decommissioning and storage would remove approximately 722 

acres of denning/resting habitat and 2,032 acres of dispersal/foraging habitat within 656 feet of 

roads from potential avoidance by fishers and prey species due to use of roads. This represents 23

percent reduction of both habitats currently within 656 feet of open roads in the project area.

Conversion of roads to trails would reduce road impacts on both habitat quality and avoidance, 

though some avoidance of habitat next to trails would be expected if they are frequently used.

Aside from the direct impacts of culvert work on roads proposed for stormproofing, there are no 

anticipated direct or indirect effects to fishers from road stormproofing. 

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Cumulative Effects

Ongoing Forest implemented and permitted road maintenance, mining access, recreation and 

existing levels of road use in the project area are expected to continue with design criteria that 

minimize impacts to fishers. Alternative 2 would be beneficial to fishers where roads are 

decommissioned or put into storage and thus reduce the effects of roads on habitat quality and 

avoidance.

There are no direct or indirect effects from alternative 2 that would be additive to cumulative 

effects to Pacific fishers when combined with past, present or foreseeable activities in the Sucker 

Creek Legacy Roads project area.

Conclusion

Implementation of the Sucker Creek Legacy Roads alternative 1 or 2 “May Impact Individuals 

and or Habitat but not likely to cause a trend to federal listing or a loss of viability to the 

population or species.” for Pacific fisher because open roads generally reduce the quality and 

availability of adjacent habitat. Alternative 2 would result in beneficial impacts where roads are 

decommissioned or put into storage and therefore improve habitat quality and availability to 

fishers within the project area.

Pallid Bat, Townsend’s Big-eared Bat, Fringed Myotis

Status: USDA FS Region 6 Sensitive 

Pallid Bat

Pallid bats are known to occur throughout SW Oregon and NW California. Suitable roost habitat 

types include buildings, bridges, rock outcrops, and large decadent snags with loose bark. Pallid 

bats have been captured from several sites on the RRSNF, including some locations on the 

Siskiyou Mountains Ranger District. They have also been observed roosting under bridges on the 

Applegate River.

Pallid bats have not been documented in the Sucker Creek Legacy Roads project area, though the 

presence of bridges, abandoned buildings and large decadent snags in the project area provide 

potential roosting habitat for pallid bats.

Townsend’s Big-Eared Bat

Townsend’s big-eared bats occur in a wide variety of habitats, its distribution tends to be

geomorphically determined and is strongly correlated with the availability of caves or cave-like

roosting habitat (e.g., old mines) (Pierson et al. 1999). The species may also use hollow trees for 

roosting. Suitable roosts sites and hibernacula fall within a specific range of temperature and 

moisture conditions. Moths make up the majority of the diet for C. townsendii.

Currently, the Oregon Caves National Monument and abandoned buildings and mine adits within 

the project area provide potential roost or maternity sites for Townsend’s big-eared bats. These 

bats are documented to occur within the Oregon Caves National Monument in the project area.

Fringed Myotis

Fringed Myotis (M. thysanodes) bats range through much of western North America from 

southern British Columbia, Canada, south to Chiapas, Mexico and from Santa Cruz Island in 

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California, east to the Black Hills of South Dakota. M. thysanodes occurs from sea-level to 

approximately 9,300 feet, but is most common at middle elevations approximately 6,500 feet. 

Distribution is patchy. It appears to be most common in drier woodlands (oak, pinyon-juniper, 

ponderosa pine) but is found in a wide variety of habitats including desert scrub, mesic coniferous 

forest, grassland, and sage-grass steppe.

M. thysanodes roost in crevices in buildings, underground mines, rocks, cliff faces, and bridges. 

Roosting in decadent trees and snags, particularly large ones, is common throughout its range in 

western U. S. and Canada. M. thysanodes roosts have been documented in a large variety of tree 

species and it is likely that structural characteristics (e.g. height, decay stage) rather than tree 

species play a greater role in selection of a snag or tree as a roost. Information available on 

hibernation is largely limited to an accounting of the types of structures used as hibernacula 

including: caves, mines and buildings.

Potential habitat exists in the project area although there are no known occurrences documented 

for this species. The nearest documented locations of these bats to the project area are to the east 

in the Thompson Creek and Applegate River Watersheds.

Alternative 1

Direct and Indirect Effects

Implementation of alternative 1 would result in continued use of all roads currently open unless 

otherwise closed by the Forest Travel Management process or other smaller projects. Potential 

direct effects to these bat species from routine road and recreation site maintenance would include 

disturbance or removal of large snags as roadside or recreation hazard trees. Removal snags for 

these purposes are limited annually under Forest Miscellaneous Projects Programmatic Section 7

Consultation for the northern spotted owl.

Cumulative Effects

There are no direct or indirect effects from alternative 1 that would be additive to cumulative 

effects to pallid bats, Townsend’s big-eared bats or fringed myotis when combined with past, 

present or foreseeable activities in the Sucker Creek Legacy Roads project area.

Conclusion

Implementation of Sucker Creek Legacy Roads Project alternative 1 would have no impact on 

pallid bats, Townsend’s big-eared bats or fringed myotis

Alternative 2

Direct and Indirect Effects

Potential direct effects to these bats under alternative 2 would include disturbance or removal of 

trees with cavities or large snags that provide potential habitat within the footprint of culvert work 

locations where vegetation would be cleared, and roadside hazard trees that may be felled during 

road treatment activities. As estimated earlier, if all of the culvert locations were cleared of 

vegetation to improve drainage using a 20-foot by 20-foot footprint, a total of 4 acres of 

vegetation would be cleared in the entire project area. Because trees to be removed would be less 

than 80 years in age, it is not likely that it would include many large trees with cavities or snags 

and would represent a small amount of these habitat features available in the project area.

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Proposed road decommissioning, roads converted to trails and roads put into storage would 

improve habitat conditions for these bats in the long-term where road-related disturbance and 

hazard tree removal would be reduced.

Cumulative Effects

Ongoing Forest implemented and permitted road maintenance, mining access, recreation and 

existing levels of road use in the project area are expected to continue. The Forest limits the 

number of hazard trees removed along roads and within recreation sites annually under the 

Miscellaneous Projects Programmatic Section 7 Consultation for spotted owls. Hazard tree and 

vegetation removal under alternative 2 may be additive to cumulative effects to bats when 

combined with past, present or foreseeable activities in the Sucker Creek Legacy Roads project 

area.

Conclusion

Implementation of the Sucker Creek Legacy Roads Project alternative 2 “May Impact 

Individuals and or Habitat but not likely to cause a trend to federal listing or a loss of 

viability to the population or species.” of pallid bats, Townsend’s big-eared bats or fringed 

myotis due to potential removal of suitable snag habitat.

Lewis’ Woodpecker and White-headed Woodpecker

Status: UDA FS Region 6 Sensitive 

Lewis’ Woodpecker

Lewis’ woodpeckers are migratory in southwestern Oregon, with sporadically large populations 

in the winter and scattered breeding pairs in the summer reported. Gilligan et al. (1994) reports 

that they are common breeders in summer in Jackson and Josephine Counties but in the last 10 

years they have not been documented (N. Barrett 2008, pers. com.) and there are few recent 

breeding records (Janes et al. 2002). The population of Lewis’ woodpeckers has fallen 

dramatically across Oregon as pine–oak woodlands are lost (Gilligan et al. 1994). A contributing 

factor in the decline has been the spread of the European Starling, which aggressively outcompetes this species for available cavities. Habitat loss is due to a wide variety of concerns that 

include urbanization of valley floors, fire suppression and encroachment of conifer forests, timber 

harvest of pine components in the oak forests, etc.

This species is closely tied to the ponderosa pine/oak savannah habitats of eastern and southwest 

Oregon. Nests are often in the large Ponderosa Pine snags or mature oaks while the birds forage 

on insects and acorn meat. In winter they store acorn meat in crevices in trees and power poles.

Because this woodpecker does not usually excavate its own cavity, they have a close tie to older 

snags within the forest that are likely to contain cavities and have crevices for food storage.

Potential habitat does exist for this species in the lower elevations of the Sucker Creek Legacy 

Roads project area, though there are no known records of this species occurring in the project 

area.

White-headed woodpecker

White-headed woodpeckers have been confirmed breeding along the California border into 

Josephine County. There are 8 confirmed observations of this species in the Sucker Creek Legacy 

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Roads project area. These woodpeckers breed in pine and mixed conifer forests. This species is 

not migratory and can be found on the forest year round (Janes et al. 2002).

Thinned stands with large remnant trees provide suitable habitat, as well as old growth forests. 

Nest predation by small mammals has been found to be a common cause of nest failure for whiteheaded woodpeckers and they have been found to have better nesting success in pine stands with 

lower shrub cover (Mellen-McLean et al. 2013). On the Rogue River–Siskiyou National Forest 

any dry, open forest stands with large trees and snags may serve as suitable foraging and breeding 

habitat for the species.

Alternative 1

Direct and Indirect Effects

Implementation of alternative 1 would result in continued use of all roads currently open unless 

otherwise closed by the Forest Travel Management process or other smaller projects. Potential 

direct effects to these woodpecker species would include any disturbance or removal of large 

trees or snags and direct injury or mortality from collision with vehicles. Potential habitat within 

164 feet of currently open roads would continue to experience existing road influence and 

considered to be of lower quality than the same habitat located farther from the roads. Edge 

effects and road-related disturbance may affect the availability of suitable habitat within 656 feet

of open roads. Important habitat features for woodpeckers such as trees with cavities and snags 

may be removed where they are considered roadside or recreation site hazard trees.

Cumulative Effects

There are no direct or indirect effects from alternative 1 that would be additive to cumulative 

effects to Lewis’ or white-headed woodpeckers when combined with past, present or foreseeable 

activities in the Sucker Creek Legacy Roads project area.

Alternative 2

Direct and Indirect Effects

Potential direct effects to these woodpeckers under alternative 2 would include disturbance or 

removal of trees with cavities, snags or oak trees that provide potential habitat within the footprint 

of culvert work locations where vegetation in the road fill would be cleared and roadside hazard 

trees that may be felled during road treatment activities. As estimated earlier, if all of the culvert 

locations were cleared of vegetation to improve drainage using a 20-foot by 20-foot footprint, a 

total of 4 acres of vegetation would be cleared in the entire project area. Because trees to be 

removed would be less than 80 years in age, it is not likely that it would include many large pine 

or oak and would represent a small amount of these habitat features available in the project area.

Proposed road decommissioning, roads converted to trails and roads put into storage would 

improve habitat conditions for these woodpeckers in the long term where road-related disturbance 

and hazard tree removal would be reduced.

Cumulative Effects

Ongoing Forest implemented and permitted road maintenance, mining access, recreation and

existing levels of road use in the project area are expected to continue. The Forest limits the 

number of hazard trees removed along roads and within recreation sites annually under the 

Miscellaneous Projects Programmatic Consultation. Alternative 2 would have long-term benefits 

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to these woodpeckers where roads are decommissioned or put into storage and thus reduce snag 

removal and road-related disturbance. 

Hazard tree and vegetation removal under alternative 2 may be additive to cumulative effects to 

Lewis’ and white-headed woodpeckers when combined with past, present or foreseeable activities 

in the Sucker Creek Legacy Roads project area.

Conclusion

Implementation of the Sucker Creek Legacy Roads Project alternative 1 or 2 “May Impact 

Individuals and or Habitat but not likely to cause a trend to federal listing or a loss of 

viability to the population or species.” for Lewis’ woodpeckers or white-headed woodpeckers 

due to potential removal of suitable snag habitat. Alternative 2 may result in more suitable habitat 

removal for proposed culvert work, but would have long-term beneficial impacts where roads are 

decommissioned or put into storage and improve habitat quality and availability for these 

woodpeckers within the project area.

Chace Sideband Snail

Status: USDA Forest Service – Sensitive, Survey and Manage

This species is endemic to northern California and southwest Oregon. In California, this species 

has been reported mainly from the Klamath Basin in northern Siskiyou County, from the vicinity 

of Happy Camp east to the Shasta and Little Shasta River Drainages, in the Goosenest Ranger 

District of the Klamath National Forest, with a few locations reported as far south and west as 

Trinity County, on the eastern slopes of the Trinity Mountains in the Weaverville Ranger District 

of Shasta-Trinity National Forest. In Oregon, sites occur in southern and eastern Jackson and 

Douglas Counties, in the Klamath-Siskiyou Mountains and the west slopes of the Cascades, north 

to the Umpqua River basin. One site has been reported from the Klamath River Basin in 

southwestern Klamath County, Oregon. 

Forested areas along roadsides and culvert locations with rocky habitat, herbaceous vegetation,

deciduous leaf litter and coarse woody debris, provide potential habitat for this species. It is 

assumed that any snails present along roadsides or around culverts would not be there if not for 

the suitability of the forested habitat around these locations. Road prism and culvert locations 

proposed for treatment have been disturbed within the last 80 years and are not considered to be 

contributing significantly to habitat that provides a reasonable assurance of persistence for this 

species. For these reasons, surveys for this species were not conducted for this project. There are 

no records of this species occurring in the Sucker Creek Legacy Roads project area.

Alternative 1

Direct and Indirect Effects 

Implementation of alternative 1 would result in routine maintenance and continued use of all 

roads currently open unless otherwise closed by the Forest Travel Management process or other 

smaller projects. Ongoing mining and recreation use would continue. Routine maintenance of 

culverts and ditches, mining and recreation activities may result in harm or mortality of Chace 

sideband snails if they are present where these occur, but this is expected to be uncommon. 

Because this species is not restricted to aquatic or riparian habitats, there are no anticipated 

indirect effects of taking no action that would impact this species.

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Cumulative Effects

There are no direct or indirect effects from taking no action under alternative 1 that would be 

additive to cumulative effects to Chace sideband snails in the Sucker Creek Legacy Roads project 

area.

Conclusion

Implementation of Sucker Creek Legacy Roads Project alternative 1 would have no impact to the 

Chace sideband snail.

Alternative 2

Direct and Indirect Effects 

Proposed ditch cleaning and culvert improvements under alternative 2 would disturb potential 

habitat for this species. Vegetation and woody debris removal, within the culvert work footprint 

may cause direct harm or mortality to any Chace sideband snails that may be present. Vegetation 

removal may change the microclimate at the culvert work locations. Vegetation that is cut for 

drainage improvement would be left within riparian reserve or late successional reserve as 

required for large woody material. Any snails present at these locations are more likely associated 

with surrounding habitat that would remain undisturbed. Proposed road decommissioning and 

storage treatments would improve habitat for this species in the long term where natural habitat 

conditions would be restored and road-related disturbance would be reduced. Proposed road and 

culvert treatments under alternative 2 are not expected to have a significant negative effect on the 

species habitat or persistence of this species if they are present at or near any proposed work 

locations.

Cumulative Effects

The potential for direct harm to this species at proposed work locations may be cumulative to 

ongoing potential caused by routine road maintenance, ongoing mining and recreations activities.

This species has not been found in the project area and is not expected to be commonly affected 

by any of these activities. 

Conclusion

Implementation of the Sucker Creek Legacy Roads Project alternative 2 “May Impact 

Individuals and or Habitat but not likely to cause a trend to federal listing or a loss of 

viability to the population or species.” of the Chace sideband snail due to low potential for 

direct mortality or harm from culvert and ditch treatments and a small amount of potential habitat 

disturbance or removal at culvert work locations.

Oregon Shoulderband 

Status: USDA Forest Service Region 6 – Sensitive, Survey and Manage 

This terrestrial snail is endemic to northern California and southwest Oregon. In California, this 

species has been reported in Siskiyou County, in the Klamath River Basin from the vicinity of 

Happy Camp east to the Shasta and Little Shasta River Drainages in the Klamath National Forest.

The range extends south into Trinity County, with the westernmost edge of the range on the 

eastern slopes of the Trinity Mountains in the Weaverville Ranger District of Trinity National 

Forest. Additional sites occur to the east in Shasta County, within the Shasta National Forest. In 

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Oregon, the range includes Jackson, Josephine, and Douglas Counties, with verified locations in 

Roseburg and Medford BLM Districts and the Umpqua National Forest.

Surveys and Field Reconnaissance

Forested areas along roadsides and culvert locations with rocky habitat, herbaceous vegetation,

deciduous trees and leaf litter and coarse woody debris, provide potential habitat for this species. 

However, the distribution of these snails is not restricted to roadsides or culvert locations. The 

project area contains suitable rocky, talus areas in stream drainages with hardwood and 

herbaceous components that also provide potential habitat. Road prism and culvert locations 

proposed for treatment have been disturbed within the last 80 years. For these reasons, surveys 

for this species were not conducted for this project. There are no records of this species occurring 

in the Sucker Creek Legacy Roads project area.

Alternative 1

Direct and Indirect Effects

Implementation of alternative 1 would result in routine maintenance and continued use of all 

roads currently open unless otherwise closed by the Forest Travel Management process or other 

smaller projects. Ongoing mining and recreation use would continue. Routine maintenance of 

culverts and ditches, mining and recreation activities may result in harm or mortality of Oregon 

shoulderband snails if they are present where these occur, but this is expected to be uncommon. 

Because this species is not restricted to aquatic or riparian habitats, there are no anticipated 

indirect effects of taking no action that would impact this species.

Cumulative Effects

There are no direct or indirect effects from taking no action under alternative 1 that would be 

additive to cumulative effects to Oregon shoulderband snails in the Sucker Creek Legacy Roads 

project area.

Conclusion

Implementation of Sucker Creek Legacy Roads Project alternative 1 would have no impact to the 

Oregon shoulderband snail.

Alternative 2

Direct and Indirect Effects

Proposed ditch cleaning and culvert improvements under alternative 2 would disturb potential 

habitat for this species. Vegetation and woody debris removal, within the culvert work footprint 

may cause direct harm or mortality to any Oregon shoulderband snails that may be present.

Vegetation removal may change the microclimate at the culvert work locations. Vegetation that is 

cut for drainage improvement would be left within riparian reserve or late successional reserve as 

required for large woody material. Any snails present at these locations are more likely associated 

with surrounding habitat that would remain undisturbed. Proposed road decommissioning and 

storage treatments would improve habitat for this species in the long term where natural habitat 

conditions would be restored and road-related disturbance would be reduced. Therefore, proposed 

road and culvert treatments under alternative 2 are not expected to have a significant negative 

effect on the species habitat or persistence of this species if they are present at or near any 

proposed work locations.

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Cumulative Effects

The potential for direct harm to this species at proposed culvert and roadside work locations may 

be cumulative to ongoing potential caused by routine road maintenance, ongoing mining and 

recreation activities. This species has not been found in the project area and is not expected to be 

commonly affected by any of these activities. 

Conclusion

Implementation of the Sucker Creek Legacy Roads Project alternative 2 “May Impact 

Individuals and or Habitat but not likely to cause a trend to federal listing or a loss of 

viability to the population or species.” of the Oregon shoulderband snail due to potential for 

direct mortality or harm from culvert and ditch treatments and a small amount of potential habitat 

disturbance or removal at culvert work locations.

Franklin’s Bumblebee and Western Bumblebee 

Status: USDA Forest Service Region 6 – Sensitive

Franklin’s Bumblebee

Franklin’s bumblebee is known from Douglas, Jackson, and Josephine counties in Oregon and 

Siskiyou and Trinity counties in California. Elevations of localities where it has been found range 

from 540 feet in the north to above 7,800 feet in the south of its historic range.

There is a historic location near Bigelow Lakes in the Sucker Creek Legacy Roads project area 

(Thorp, pers. com.). The project area includes many areas of potential habitat for these bees.

Western Bumblebee

The western bumblebee (Bombus occidentalis) was widespread and common throughout the 

western United States and western Canada before 1998 (Xerces Society 2009). Unfortunately, 

since 1998 populations of this bumblebee have declined drastically throughout parts of its former 

range. Populations of the western bumblebee in central California, Oregon, Washington and 

southern British Columbia have mostly disappeared. It is difficult to accurately assess the 

magnitude of these declines since most of this bee’s historic range has not been sampled 

systematically.

There are no known occurrences of this bee in the Sucker Creek Legacy Roads project area 

though potential habitat is present throughout the project area.

Alternative 1

Direct and Indirect Effects

Implementation of alternative 1 would result in routine maintenance and continued use of all 

roads currently open unless otherwise closed by the Forest Travel Management process or other 

smaller projects. Ongoing mining and recreation use would continue. Because bees are very 

mobile and able to quickly perceive and avoid harm, direct mortality or harm from impact with 

vehicles on open roads is the most likely negative impact of existing road use. Because this 

species is not restricted to aquatic or riparian habitats, there are no anticipated indirect effects of 

taking no action that would impact these bee species.

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Cumulative Effects

There are no direct or indirect effects from taking no action under alternative 1 that would be 

additive to cumulative effects to the Franklin’s or western bumblebee in the Sucker Creek Legacy 

Roads project area.

Conclusion

Implementation of Sucker Creek Legacy Roads Project Alternative 1 would have no impact to 

the Franklin’s or western bumblebee.

Alternative 2

Direct and Indirect Effects 

Proposed ditch cleaning and culvert improvements under alternative 2 would disturb potential 

nectar and pollen producing plants for these species. Vegetation removal from culvert work 

footprints or roadsides may harass any foraging bees present at these locations. The potential for 

either of these two species to be present at any proposed work sites is low and they would be 

expected to move away from the site to avoid harm. Proposed culvert improvements may remove 

up to 4 acres of vegetation distributed in small areas (about 20 feet by 20 feet) which is less than 

0.5% of the entire project area. These sites would be re-vegetated within a year of treatments. 

Proposed road decommissioning and storage treatments would improve habitat for this species in 

the long term where natural habitat conditions would be restored and road-related disturbance 

would be reduced. Proposed road and culvert treatments under alternative 2 are not expected to 

have appreciable direct or indirect effects on these bee species.

Cumulative Effects

There are no anticipated direct or indirect effects from alternative 2 that would appreciably 

contribute to cumulative effects of past, present or foreseeable activities in the project area. 

Conclusion

Implementation of the Sucker Creek Legacy Roads Project alternative 2 “May Impact 

Individuals and or Habitat but not likely to cause a trend to federal listing or a loss of 

viability to the population or species.” of the Franklin’s bumblebee or western bumblebee due 

to low potential for harassment of individuals and short-term removal of a small amount of forage 

habitat from culvert and roadside treatments.

Johnson’s Hairstreak 

Status: USDA Forest Service – Sensitive

This small brown butterfly occurs in isolated pockets in the western mountains of California up 

into British Columbia. On the Rogue River-Siskiyou, range maps indicate a population in the 

coastal mountains of Coos, Curry and Josephine counties. A second population is in northern 

Jackson County around Crater Lake National Park.

Some surveys have been carried out for this species on the Rogue River-Siskiyou National Forest

in the Southern Cascade Mountains and some individuals have been detected. One detection is 

located along the 4611079 road proposed for stormproofing. A few additional locations are 

adjacent to the project area in the south and one location to the east of the project area. 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Alternative 1

Direct and Indirect Effects

Implementation of alternative 1 would result in routine maintenance and continued use of all 

roads currently open unless otherwise closed by the Forest Travel Management process or other 

smaller projects. Ongoing road maintenance including hazard tree removal and mining and 

recreation use would continue. These butterflies spend most of their time in mature forest canopy, 

but may infrequently collide with vehicles using open roads. There are no appreciable direct or 

indirect effects of taking no action that would impact Johnson’s hairstreak butterflies.

Cumulative Effects

There are no direct or indirect effects from implementation of alternative 1 that would be additive 

to cumulative effects to Johnson’s hairstreak butterflies in the Sucker Creek Legacy Roads project 

area.

Conclusion

Implementation of Sucker Creek Legacy Roads Project alternative 1 would have no impact on 

the Johnson’s hairstreak.

Alternative 2

Direct and Indirect Effects 

Vegetation removal associated with proposed culvert improvements under alternative 2 may 

remove fir trees with mistletoe that provide potential habitat for this species. Any eggs or larvae 

present in mistletoe in this vegetation may be harmed. A maximum of 4 acres of vegetation 

removal is estimated which represents less than 0.5 percent of the project area and would be 

distributed in small areas (about 20 feet by 20 feet) throughout the project area. True fir with 

mistletoe is common throughout the project area. Proposed road decommissioning and storage 

treatments would improve habitat for this species in the long term where natural habitat 

conditions would be restored and road-related disturbance such as hazard tree removal would be 

reduced. Proposed road and culvert treatments under alternative 2 are not expected to have 

appreciable direct or indirect effects to Johnson’s hairstreak butterflies.

Cumulative Effects

There are no anticipated direct or indirect effects from alternative 2 that would appreciably 

contribute to cumulative effects of past, present or foreseeable activities to this species in the 

project area. 

Conclusion

Implementation of the Sucker Creek Legacy Roads Project alternative 2 “May Impact 

Individuals and or Habitat but not likely to cause a trend to federal listing or a loss of 

viability to the population or species.” for the Johnson’s hairstreak because of potential 

disturbance to individuals and limited removal of mistletoe habitat from culvert treatments. With 

the large amount of true fir in the project area, it is likely that mistletoe will remain widely 

available for this species.

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Gray Blue Butterfly and Mardon Skipper

Status: USDA Forest Service Region 6 – Sensitive

Gray Blue Butterfly

This butterfly is found in the southern Cascade Mountains and eastern Siskiyou Mountains in 

Douglas, Jackson, and Klamath counties, including Mount Ashland, Diamond Lake, and Crater 

Lake. Adults can be abundant where they occur but populations are locally distributed (Warren 

2005). This species was very common and reliable just east of the Grouse Gap Shelter on the 

south side of Mount Ashland in the 1990s and early 2000s (Runquist 2009, pers. comm.), but 

additional localities in the Siskiyou Mountains and northern Klamath Mountains are not known 

(Runquist 2009, pers. comm., Pyle 2009, pers. comm.). 

In 2013 this butterfly was identified by BLM biologist Jason Riley and Forest Service biologist 

Bonnie Allison in the meadows around Bigelow Lakes in the project area. Additional suitable 

habitat for this species is expected to occur in the wet meadows at higher elevations in the project 

area.

Mardon Skipper

Mardon skippers use a variety of early successional meadow habitats which appear to vary by 

region (Kerwin and Huff 2007). Populations in southern Oregon occupy small (less than 0.5 to 10

acres), high-elevation (4,500 to 5,100 feet) grassy meadows within mixed conifer forests 

(USFWS 2010).

Seven or eight locations are known from the Cascade Mountains in southwest Oregon, most 

bordering the Cascade-Siskiyou National Monument, with populations ranging from a few to 

approximately 200 individuals (Kerwin and Huff 2007). In 2005, searches and surveys of 

populations on BLM and Forest Service lands in southern Oregon discovered several new sites. 

There are now a total of 23 known sites in southern Oregon. One site is on the RRSNF and is 

approximately 5 miles north of the nearest site on BLM lands. Another locality is a complex of 

sites on both BLM and Forest Service lands north of Dead Indian Memorial Road. Several more 

sites were located adjacent to known sites on BLM lands. One day counts at sites ranged from 

one butterfly to over 70 butterflies (Kerwin and Huff 2007). 

Though potential habitat is available in the Sucker Creek Legacy Roads project area, there are no 

known occurrences of mardon skipper in the project area.

Alternative 1

Direct and Indirect Effects

Implementation of alternative 1 would result in continued routine maintenance and use of all 

roads currently open unless otherwise closed by the Forest Travel Management process or other 

smaller projects. Ongoing mining and recreation use would continue. Both species of these 

butterflies tend to remain close to their natal sites, though male mardon skippers have been found 

to use road corridors with nectar sources. Roads and trails also provide mud puddles where 

butterflies are known to congregate for moisture and minerals. It’s possible that adults of either 

species may infrequently collide with vehicles or be crushed by vehicles using open roads. There 

are no appreciable direct or indirect effects of taking no action that would impact gray blue or 

mardon skipper butterflies.

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Cumulative Effects

There are no anticipated direct or indirect effects from implementation of alternative 1 that would 

be additive to cumulative effects to gray blue or mardon skipper butterflies in the Sucker Creek 

Legacy Roads project area.

Conclusion

Implementation of Sucker Creek Legacy Roads Project alternative 1 would have no impact on 

the gray blue butterfly or mardon skipper.

Alternative 2

Direct and Indirect Effects 

Vegetation removal associated with proposed culvert improvements under alternative 2 may 

remove plants that provide potential habitat, particularly nectar sources for these species. These 

locations are not likely to be used by these species for breeding since they are small disturbed 

areas that typically lack appropriate host plants. Any butterflies present at culvert work sites 

would be expected to fly and avoid harm unless adults puddling on roadways get run over. A 

maximum of 4 acres of vegetation removal is estimated which represents less than 0.5% of the 

project area and would be distributed in small areas (about 20 feet by 20 feet) throughout the 

project area. These sites would be re-vegetated within a year. Suitable meadow habitat with 

appropriate host plants for these species in the project area would not be affected by proposed 

road and culvert treatments. Proposed road decommissioning and storage treatments would 

improve habitat for these species in the long term where natural habitat conditions would be 

restored and road-related disturbance and traffic reduced. Direct and indirect effects of alternative

2 are not expected to appreciably impact gray blue or mardon skipper butterflies.

Cumulative Effects

Anticipated direct or indirect effects from alternative 2 would not appreciably contribute to 

cumulative effects of past, present or foreseeable activities to gray blue or mardon skipper 

butterflies in the project area. 

Conclusion

Implementation of the Sucker Creek Legacy Roads Project alternative 2 “May Impact 

Individuals and or Habitat but not likely to cause a trend to federal listing or a loss of 

viability to the population or species.” for the gray blue butterfly or mardon skipper because of 

low potential for mortality of individuals and limited removal of nectar sources from culvert 

treatments.

Effects on Management Indicator Species

Management indicator species (MIS) associated with the Siskiyou NF LRMP (USDA Forest 

Service 1989) represent the issues, concerns, and opportunities to support recovery of federally 

listed species, provide continued viability of sensitive species, and enhance management of 

wildlife and fish for commercial, recreational, scientific, subsistence, or aesthetic values or uses.

Management indicators representing overall objectives for wildlife, fish, and plants may include 

species, groups of species with similar habitat relationships, or habitats that are of high concern 

(FSM 2621.1). The current condition of habitat and trends for all MIS species is discussed in the 

Rogue River-Siskiyou National Forest MIS Forestwide Analysis (USDA Forest Service 2012).

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An indicator species represents all other wildlife species which utilize a similar habitat type.

Indicator species act as a barometer for the health of various habitats and will be monitored to 

quantify habitat changes predicted by implementation of the Forest Plan (1989 pages IV-10 and 

11, FEIS page III-102). MIS and habitats include bald eagle (habitat along major rivers), osprey 

(habitat along large rivers), spotted owl (late-successional forest), pileated woodpecker and 

American marten (mature/interior forest), black-tailed deer and Roosevelt elk (early successional 

forest stages, and woodpeckers/cavity nesters (wildlife trees [snags]). Table 22 identifies 

Management Indicator Species and their habitat represented within the project areas. Northern

spotted owls were discussed previously.

Table 22. Wildlife management indicator species and habitat in the analysis area

Species Habitat Represented Habitat Present in 

Analysis Area

Species Present in 

Analysis Area

Bald Eagle Habitat corridors along 

major rivers

Yes Documented

Osprey Habitat corridors along large 

creeks and rivers

Yes Documented

Spotted owl Old-growth forest Yes Documented

Pileated woodpecker Mature forest Yes Documented

American marten Mature forest Yes Documented

Woodpeckers Snags (standing dead trees) Yes Documented

Black-tailed deer, 

Roosevelt elk

Early successional forest 

stages

Yes Deer Documented, 

Elk not likely

Northern Bald Eagle

Bald eagle habitat on the Rogue River-Siskiyou N.F. is protected and managed in accordance 

with the Pacific Bald Eagle Recovery Plan (USFWS 1986), and Standards and Guidelines 4-3 and 

4-4 of the Siskiyou National Forest Land and Resource Management Plan (USDA 1989). As part 

of the recovery plan, key nesting habitat areas have been identified on the Rogue River-Siskiyou 

N.F. along the Rogue, Illinois, and Sixes Rivers (USFWS 1986). In 2011, an estimated 39,536 

acres of prime bald eagle habitat (within 1 mile of the Rogue and portions of the Illinois and 

Chetco rivers) is available on the Siskiyou National Forest. The Sucker Creek Legacy Roads 

Project is not within this prime habitat. 

There is one sighting of a bald eagle in the Forest NRIS database at Bolan Lake in the southern 

boundary of the project area. There are no known bald eagle nests or roosts within the project 

area; the project is beyond the distance where the most suitable nesting structure occurs along the 

Rogue and Illinois Rivers outside of the project area.

Direct, Indirect and Cumulative Effects

Proposed road stormproofing, decommissioning, road storage activities, or conversion of roads to 

trails would not modify or remove potential nesting, roosting or foraging habitat for bald eagles. 

Conclusion

The Sucker Creek Legacy Roads project would have no impact on the bald eagle and may 

benefit habitat for eagles where road treatments are needed to improve riparian habitat for 

anadromous fisheries. Furthermore, because the project will have no impact to the bald eagle, it

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

will not contribute toward a negative trend in viability on the Siskiyou portion of the Rogue River 

National Forest for the bald eagles as management indicator species.

Osprey

Osprey (Pandion haliaetus) are commonly observed along the Rogue River, and in the Chetco 

Illinois, and Coquille fifth-field watersheds. This species is closely associated with open water 

(lakes, rivers, and streams). It breeds in the major habitat types but only when adjoining open 

water. Ospreys arrive during early spring (March), nest, and then leave for wintering grounds by 

October. Their primary diet includes fish and eels, which they hunt while in flight. Osprey 

monitoring from 1992 to 2001 on the lower Rogue River detected an increase in active osprey 

nests. Osprey nests have also recently been monitored on the South Fork Coquille and Elk Rivers.

In 2011, approximately 39,563 acres of prime habitat for osprey were identified within 1 mile of 

the Rogue River and sections of the Illinois and Chetco Rivers. The Sucker Creek Legacy Roads 

project is not within this prime habitat. However, ospreys have been observed flying over Sucker 

Creek in the project area. The lower, wider part of Sucker Creek and the lakes in the project area 

provide potential foraging habitat for osprey.

Alternative 1

Direct and Indirect Effects

Implementation of alternative 1 would result in continued use of all roads currently open unless 

otherwise closed by the Forest Travel Management process or other smaller projects. Potential 

direct effects to osprey would include any disturbance or removal of large trees or snags 

considered as roadside or developed recreation site hazards situated next to wide streams or lakes 

that may be used by osprey as perches. This is expected to be a small percentage of suitable perch 

trees available in the project area. There are no known osprey nests in the project area.

Cumulative Effects

There are no appreciable direct or indirect effects from alternative 1 that would be additive to 

cumulative effects to osprey habitat when combined with past, present or foreseeable activities in 

the Sucker Creek Legacy Roads project area.

Alternative 2

Direct and Indirect Effects

Potential direct effects to osprey under alternative 2 would include disturbance or removal of 

snags within the footprint of culvert work locations where vegetation would be cleared and 

roadside hazard trees that may be felled during road treatment activities that are situated next 

wide streams. This is anticipated to be a very unlikely impact. As estimated earlier, if all of the 

culvert locations were cleared of vegetation to improve drainage using a 20-foot by 20-foot 

footprint, a total of 4 acres of vegetation would be cleared in the entire project area. Because trees 

to be removed would be less than 80 years in age, it is not likely that it would include many large 

snags next to open water that would be used by osprey and therefore would represent a small 

amount of these habitat features available in the project area.

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Proposed road decommissioning, roads converted to trails and roads put into storage may 

improve habitat potential for osprey in the long-term where road-related disturbance and hazard 

tree removal would be reduced.

Cumulative Effects

Ongoing Forest implemented and permitted road maintenance, mining access, recreation and 

existing levels of road use in the project area are expected to continue. The Forest limits the 

number of hazard trees removed along roads and within recreation sites annually under the 

Miscellaneous Projects Programmatic Consultation. Hazard tree and vegetation removal under 

alternative 2 would have a minor contribution to cumulative effects to osprey habitat when 

combined with past, present or foreseeable activities in the Sucker Creek Legacy Roads project 

area.

Conclusion

Implementation of alternative 1 or 2 for the Sucker Creek Legacy Roads Project would not 

impact prime habitat available on the Forest for osprey, and continued viability of osprey on the 

Siskiyou portion of the Rogue River-Siskiyou National Forest would be expected.

Pileated Woodpecker

Pileated woodpecker (Dryocopus pileatus) is generally associated (feeds and breeds) with the 

mixed forest habitat type, and present in the oak habitat type. This species feeds and breeds in a 

variety of structural conditions especially in a landscape mosaic of habitat types. Decadent wood 

and snags are essential habitat components and are available throughout the Sucker Creek Legacy 

Roads project area.

Pileated woodpecker habitat has decreased from 41% of the Forest in 1989 to 34 percent (368,428 

acres) in 2011. The total amount of habitat protected has increased from 179,737 acres with the 

1989 Siskiyou NF LRMP to 315,231 acres in 2011 with the added NWFP direction. Currently 

86% of pileated woodpecker habitat is in protected land allocations on the Siskiyou side of the 

Forest. Recovery Action 32 for the northern spotted owl retains high quality nesting, roosting and 

foraging habitat in the remaining land allocations. Eighty-three percent of the Forest is in an 

unmanaged condition and providing snags at natural levels. The amount of available habitat for 

this species on the Forest is above 1989 Forest Plan projections and is consistent with Forest Plan 

direction, thus continued viability of the pileated woodpecker is expected on the Siskiyou 

National Forest (USDA Forest Service 2012).

Alternative 1

Direct and Indirect Effects

Implementation of alternative 1 would result in continued use of all roads currently open unless 

otherwise closed by the Forest Travel Management process or other smaller projects. Potential 

direct effects to pileated woodpeckers would include any disturbance or removal of large snags 

considered as roadside or developed recreation site hazards situated in late successional habitat.

This is expected to be a minor impact to late successional habitat available in the project area.

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Cumulative Effects

There are no appreciable direct or indirect effects from alternative 1 that would be additive to 

cumulative effects to pileated woodpecker habitat when combined with past, present or 

foreseeable activities in the Sucker Creek Legacy Roads project area.

Conclusion

In 2011, approximately 368,428 acres of late-successional habitat which provides foraging and 

nesting habitat is distributed across the Siskiyou National Forest. Implementation of Sucker 

Creek Legacy Roads Project alternative 1 would not result in detectable impacts to available 

habitat for pileated woodpeckers at the forest scale, and continued viability of pileated 

woodpeckers on the Siskiyou portion of the Rogue River-Siskiyou National Forest would be 

expected.

Alternative 2

Direct and Indirect Effects

Potential direct effects to pileated woodpecker habitat under alternative 2 would include 

disturbance or removal of snags within the footprint of culvert work locations where vegetation 

would be cleared and roadside hazard trees that may be felled during road treatment activities that 

are situated within late successional habitat. This is anticipated to be a minor impact due to the 

effect roads have on habitat quality. As estimated earlier, if all of the culvert locations were 

cleared of vegetation to improve drainage using a 20-foot by 20-foot footprint, a total of 4 acres 

of vegetation would be cleared in the entire project area. Because trees to be removed would be 

less than 80 years in age, it is not likely that clearing would include many large snags that 

contribute to late successional habitat structure.

Proposed road decommissioning, roads converted to trails and roads put into storage may 

improve habitat potential for pileated woodpeckers in the long-term where road-related 

disturbance and hazard tree removal would be reduced.

Cumulative Effects

Ongoing Forest implemented and permitted road maintenance, mining access, recreation and 

existing levels of road use in the project area are expected to continue. The Forest limits the 

number of hazard trees removed along roads and within recreation sites annually under the 

Miscellaneous Projects Programmatic Section 7 Consultation. Hazard tree and vegetation 

removal at culverts under alternative 2 would have a minor contribution to cumulative effects to 

pileated woodpecker habitat when combined with past, present or foreseeable activities in the 

Sucker Creek Legacy Roads project area.

Conclusion

In 2011, approximately 368,428 acres of late-successional habitat which provides foraging and 

nesting habitat is distributed across the Siskiyou National Forest. Up to 4 acres of vegetation 

removal at culvert locations under alternative 2 for the Sucker Creek Legacy Roads Project would 

not result in detectable impacts to available habitat for pileated woodpeckers at the forest scale, 

and continued viability of pileated woodpeckers on the Siskiyou portion of the Rogue RiverSiskiyou National Forest would be expected.

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American Marten

American marten (Martes americana) are strongly associated with mature conifer forest 

(Zielinski et al, 2001). They may den in snags, down logs, and rock outcrops. The Pacific 

Southwest Research Station (PSW) conducted a smoke-plate track survey in 1997 (following 

Zielinski and Kucera 1995) for marten and fisher across the Gold Beach and Chetco Ranger 

Districts. Marten were detected in the Lower Rogue, Hunter Creek, Pistol River and Chetco 

watersheds. Fisher was detected in the North Fork Smith watershed. Spotted skunk, gray fox, 

ringtail, and northern flying squirrel were also detected. Remote camera sets were installed at four 

locations along Agness Road in 1993 (1 station) and 1996 (3 stations). Spotted skunk, gray fox 

and turkey vultures were captured on film, no martens. 

There have been two marten detections within the Sucker Creek Legacy Roads project area. One 

near Pepper Camp and one in the Red Buttes Wilderness.

Marten habitat at the Siskiyou National Forest scale is estimated to be between 34-36 percent The 

American marten model (USDA Forest Service 2011a) estimates that 36 percent of the Siskiyou 

National Forest currently provides suitable habitat. Marten habitat has decreased from 41 percent

of the Forest in 1989 to 34 percent in 2011. The total amount of habitat protected has increased 

from 179,737 acres with the 1989 SNFP to 315,231 acres in 2011with the SNFP/NWFP direction.

Currently 86 percent of marten habitat is in protected land allocations. Spotted Owl Recovery 

Action 32 retains high quality nesting, roosting and foraging habitat in the remaining land 

allocations. Eighty-three percent of the Forest is in an unmanaged condition and providing snags 

and down wood at natural levels. The amount of available habitat for this species on the Forest is 

above 1989 Forest Plan projections and is consistent with Forest Plan direction, thus continued 

viability of the American marten is expected on the Siskiyou National Forest.

Alternative 1

Direct and Indirect Effects

Implementation of alternative 1 would result in continued use of all roads currently open unless 

otherwise closed by the Forest travel management process or other smaller projects. Potential 

direct effects to American marten would include any disturbance or removal of large snags 

considered as roadside or developed recreation site hazards situated in late successional habitat.

This is expected to be a minor impact to late successional habitat available in the project area.

Cumulative Effects

There are no appreciable direct or indirect effects from alternative 1 that would be additive to 

cumulative effects to American marten habitat when combined with past, present or foreseeable 

activities in the Sucker Creek Legacy Roads project area.

Conclusion

In 2011, approximately 368,428 acres of late-successional habitat which provides foraging and 

nesting habitat is distributed across the Siskiyou National Forest. Implementation of Sucker 

Creek Legacy Roads Project alternative 1 would not result in detectable impacts to available 

habitat for American marten at the forest scale, and continued viability would be expected for this 

species on the Siskiyou portion of the Rogue River-Siskiyou National Forest.

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Alternative 2

Direct and Indirect Effects

Potential direct effects to American marten habitat under alternative 2 would include disturbance 

or removal of snags or large down wood within the footprint of culvert work locations where 

vegetation would be cleared and roadside hazard trees that may be felled during road treatment 

activities that are situated within late successional habitat. This is anticipated to be a minor impact 

due to the effect roads have on habitat quality. As estimated earlier, if all of the culvert locations 

were cleared of vegetation to improve drainage using a 20-foot by 20-foot footprint, a total of 4 

acres of vegetation would be cleared in the entire project area. Because trees to be removed 

would be less than 80 years in age, it is not likely that clearing would include many large trees or 

snags that contribute to late successional habitat structure. Adequate large down wood to meet 

habitat requirements would be retained near culvert locations in riparian reserves, late 

successional habitat or critical habitat for spotted owls.

Proposed road decommissioning, roads converted to trails and roads put into storage may 

improve habitat potential for American marten in the long-term where road-related disturbance 

and hazard tree removal would be reduced.

Cumulative Effects

Ongoing Forest-implemented and permitted road maintenance, mining access, recreation and 

existing levels of road use in the project area are expected to continue. These projects implement 

measures to minimize impacts to late successional habitat. Hazard tree and vegetation removal at 

culverts under alternative 2 would have a minor contribution to cumulative effects to American 

marten habitat when combined with past, present or foreseeable activities in the Sucker Creek 

Legacy Roads Project area.

Conclusion

In 2011, approximately 368,428 acres of late-successional habitat which provides foraging and 

nesting habitat is distributed across the Siskiyou National Forest. Up to 4 acres of vegetation 

removal at culvert locations under alternative 2 for the Sucker Creek Legacy Roads Project would 

not result in detectable impacts to available habitat for American marten at the forest scale, and 

continued viability of American marten would be expected on the Siskiyou portion of the Rogue 

River-Siskiyou National Forest.

The Woodpecker Group (acorn, pileated, downy, hairy, and white-headed 

woodpeckers, northern flickers and red-breasted sapsuckers)

The woodpecker group includes acorn, pileated, downy, hairy, and white-headed woodpeckers, as 

well as northern flickers and red-breasted sapsuckers. These species are generally associated with 

oak woodland, mixed forest, and/or grassland habitat types. Woodpeckers excavate nests in snags 

and trees. They also forage in decayed wood.

Currently there is far more habitat available on the Forest for woodpeckers than was planned for 

in the original LRMP. It is very likely that the forest is providing habitat for far more woodpecker 

pairs than originally thought to be needed across the Forest to provide for long-term viability for 

this species (USDA Forest Service 2012). In addition to the reserve land allocations on the Forest, 

the Forest has specific snag and down wood requirements using local long-term eco-plot data that 

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the Forest believes contributes to maintaining woodpecker viability across all land allocations 

better than the original snag habitat capability requirement under the LRMP (USDA Forest 

Service 2001). The Biscuit Fire burned through 467,702 acres within the Siskiyou National Forest 

and provides areas with high amounts of snags.

The Forest NRIS wildlife database documents 50 observations of the five different species of 

woodpeckers and multiple undocumented observations of most of these species are known 

throughout the Sucker Creek Legacy Roads project area. 

Alternative 1

Direct and Indirect Effects

Implementation of alternative 1 would result in continued use of all roads currently open unless 

otherwise closed by the Forest travel management process or other smaller projects. Potential 

direct effects to this group of woodpeckers would include any disturbance or removal of conifer 

or hardwood snags considered as roadside or developed recreation site hazards particularly in oak 

woodland habitat. This is expected to be a minor impact to the total amount of these habitat 

elements available in the project area.

Cumulative Effects

There are no appreciable direct or indirect effects from alternative 1 that would be additive to 

cumulative effects to habitat for this woodpecker group when combined with past, present or 

foreseeable activities in the Sucker Creek Legacy Roads project area.

Conclusion

The Biscuit Fire burned through 467,702 acres within the Siskiyou National Forest and provides 

diverse forested areas with high amounts of conifer and hardwood snags. Implementation of 

Sucker Creek Legacy Roads Project alternative 1 would not result in detectable impacts to 

available habitat for this woodpecker group at the forest scale, and continued viability would be 

expected for these species on the Siskiyou portion of the Rogue River-Siskiyou National Forest.

Alternative 2

Direct and Indirect Effects

Potential direct effects to habitat for this group of woodpeckers under alternative 2 would include 

disturbance or removal of conifer or hardwoods snags within the footprint of culvert work 

locations where vegetation would be cleared and roadside hazard trees that may be felled during 

road treatment activities particularly within oak woodland habitat. As estimated earlier, if all of 

the culvert locations were cleared of vegetation to improve drainage using a 20-foot by 20-foot 

footprint, a total of 4 acres of vegetation would be cleared in the entire project area and a small 

amount of it would be within oak woodland habitat. 

Proposed road decommissioning, roads converted to trails and roads put into storage may 

improve habitat potential for this woodpecker group in the long term where road-related 

disturbance and hazard tree removal would be reduced.

Cumulative Effects

Ongoing Forest-implemented and permitted road maintenance, mining access, recreation and 

existing levels of road use in the project area are expected to continue. Hazard tree and vegetation 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

removal at culverts under alternative 2 would have a minor contribution to cumulative effects to 

available woodpecker habitat when combined with past, present or foreseeable activities in the 

Sucker Creek Legacy Roads project area.

Conclusion

The Biscuit Fire burned through 467,702 acres within the Siskiyou National Forest and provides a 

diversity of forested areas with high amounts of conifer and hardwood snags. Up to 4 acres of 

vegetation removal at culvert locations under alternative 2 for the Sucker Creek Legacy Roads 

Project would not result in detectable impacts to available snag habitat for this woodpecker group

at the forest scale, and continued viability of these woodpeckers would be expected on the 

Siskiyou portion of the Rogue River-Siskiyou National Forest.

Blacktail Deer and Roosevelt Elk

Blacktail deer (Odocoileus hemionus columbianus) and Roosevelt elk (Cervus elaphus roosevelti) 

use all successional stages to meet their habitat needs for cover, forage and reproduction. Natural 

or created openings provide the majority of foraging habitat, which is assumed to be the most 

restrictive habitat component in this region (Forest Plan FEIS, III-106-107). Deer and elk 

represent more than 180 wildlife species that need early successional stages to meet some or all of 

their requirements (Brown 1985). Forage habitat is available within existing meadows, harvest 

units less than 10 years old and open canopy forested areas.

The amount of area with programmed timber harvest, expected to provide a sustainable forage 

base, on the Forest has declined from 505,000 acres (46%) to 78,713 acres (7%). The amount of 

forage available from timber harvest activities has declined from 48,785 acres in 1989 to 9,132 in 

2011. The amount of forage available from fires has increased from 103,646 in 1989 to 471,176 

in 2011. Forage created from regeneration harvest and fires are transitory, which generally has a 

benefit for deer and elk for 5-10 years until canopy closure resumes. The amount and quality of 

forage provided by the Biscuit Fire is beginning to decline as tree canopies begin to close.

Current elk and deer populations are below Oregon Department of Fish and Wildlife management 

objectives. Populations are stable within the Biscuit Fire perimeter. Outside the Biscuit Fire, 

populations are showing a downward trend due to loss of early seral habitat and other factors 

including disease, parasites and predation (personal communication with Curtis Edwards,

Wildlife Biologist, Oregon Department of Fish & Wildlife, January 2010 as cited in the ROR-SIS 

NF Briggs Valley Vegetation Management Project BE, February 2012).

Forested conditions provide hiding (vegetation capable of hiding 90 percent of a standing adult 

deer or elk at 200 feet or less), thermal cover (a forest stand greater than 40 feet tall with greater 

than 70 percent canopy cover) and optimal cover (a forest stand with overstory, sub-canopy, 

shrub, and herbaceous strata and greater than 70 percent canopy). The 2000 LEMMA GNN 

vegetation mapping indicates approximately 23,314 acres of thermal cover on National Forest 

System lands within the Sucker Creek Legacy Roads project area.

Alternative 1

Direct and Indirect Effects

Implementation of alternative 1 would result in continued use of all roads currently open unless 

otherwise closed by the Forest travel management process or other smaller projects. Existing 

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mining and recreation access including hunting would continue. Roosevelt elk are unlikely to 

occur in the project area, however blacktail deer are common. Potential direct effects include 

mortality related to vehicle collisions and hunting. Deer are often seen traveling and foraging 

along roadsides, but habitat within 656 feet of roads is generally not considered quality hiding 

cover or secure habitat for these species.

Cumulative Effects

There are no appreciable direct or indirect effects from alternative 1 that would be additive to 

cumulative effects to habitat for deer and elk when combined with past, present or foreseeable 

activities in the Sucker Creek Legacy Roads project area.

Conclusion

Implementation of the Sucker Creek Legacy Roads Project alternative 1 would not result in 

detectable impacts to available habitat for blacktail deer or Roosevelt elk at the forest scale, and 

continued viability would be expected for these species on the Siskiyou portion of the Rogue 

River-Siskiyou National Forest.

Alternative 2

Direct and Indirect Effects

Foraging habitat is experiencing the most decline of the required habitats for these species across 

the Forest as forested areas that have been harvested or burned in the last 20 years are maturing. 

Implementation of alternative 2 would have no anticipated negative direct or indirect impacts 

because vegetation cleared within the footprint of culvert work locations would provide small 

areas of early seral vegetation within a growing season following the work. As estimated earlier, 

if all of the culvert locations were cleared of vegetation to improve drainage using a 20-foot by 

20-foot footprint, a total of 4 acres of vegetation would be cleared in the entire project area. 

Proposed road decommissioning, roads converted to trails and roads put into storage are expected 

to benefit habitat for blacktail deer and Roosevelt elk by improving habitat quality and reducing 

road-related disturbance.

Cumulative Effects

There are no direct or indirect effects of alternative 2 that would contribute to cumulative effects 

to available deer and elk habitat when combined with past, present or foreseeable activities in the 

Sucker Creek Legacy Roads project area.

Conclusion

Implementation of alternative 2 for the Sucker Creek Legacy Roads Project would not result in 

negative impacts to habitat for black tailed deer or Roosevelt elk at the Forest scale, and 

continued viability of these species would be expected on the Siskiyou portion of the Rogue 

River-Siskiyou National Forest.

Effects for Neo-tropical Migratory Birds and Landbirds

Within the National Forest System, conservation of migratory birds focuses on providing a 

diversity of habitat conditions at multiple spatial scales. The Rogue River-Siskiyou NF is within 

Bird Conservation Region 5 (Northern Pacific Forest).

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

This analysis is based on neo-tropical migratory birds/landbird focal species identified by 

Partners in Flight (PIF): Conservation Strategy for Landbirds in Coniferous Forest of Western 

Oregon and Washington (2012). As per the Partners In Flight Bird Conservation Plan “... if you 

provide all of the habitats to some degree over some landscape, then you will probably be taking 

care of most if not all of the landbirds in that habitat. The conservation emphasis is on 

ecosystems, habitats, and habitat conditions, not species.” Priority bird species for varying 

habitats within the Sucker Creek watershed are summarized in table 23.

Bird conservation objectives are tied to focal species that represent habitat attributes and/or 

ecological functions of various forest age classes. For example, Vaux’s Swifts use large snags in 

old-growth systems, olive-sided flycatchers use residual canopy trees in early seral stages, and 

hermit warblers use the closed canopy in young to mature-aged forests. These habitats and their 

attributes, in certain quantities and combinations, should be maintained on landscapes in a 

shifting mosaic of conditions. The Sucker Creek watershed provides potential nesting, dispersal, 

foraging, and cover habitat for variety of bird species.

Table 23. Habitat condition and attributes associated with Birds of Conservation Concern (2008) and 

Partners in Flight focal migrant species

Habitat Condition Habitat Attribute Bird Species

Coniferous 

forest

Old-growth / 

Mature Large snags Vaux’s swift, pileated woodpecker

Coniferous 

forest

Old-growth / 

Mature

Large trees; conifer cones; 

mid-story tree layers

Brown creeper; red crossbill; varied 

thrush

Coniferous 

forest

Mature / 

Young

Varied canopy closure; 

deciduous canopy & 

understory; complex forest 

floor

Hermit warbler, Hammond’s 

flycatcher; Pacific-slope flycatcher; 

Wilson’s warbler; winter wren, 

Northern goshawk, purple finch

Coniferous 

forest

Young / 

Pole Deciduous canopy Black-throated gray warbler

Coniferous 

forest Pole Deciduous subcanopy / 

understory Hutton’s vireo

Coniferous 

forest Early-seral

Residual canopy trees, snags, 

deciduous vegetation; nectarproducing plants

Olive-sided flycatcher; western 

bluebird; orange-crowned warbler; 

rufous hummingbird

Coniferous 

forest Unique Mineral springs Band-tailed pigeon

Oak woodlands 

(including nonforested prairie)Unique

California quail, western screech-owl, 

Nutall’s woodpecker, oak titmouse, 

wrentit, California thrasher, blackchinned sparrow, Oregon vesper 

sparrow, horned lark

Cliffs, waterfalls 

& forest Unique Cliffs near waterfalls within 

forested habitat. Black swift

Riparian Riparian Large trees adjacent to major 

rivers. Dense shrub habitat. Bald eagle, willow flycatcher

Large cliffs Unique Peregrine falcon

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Sucker Creek Legacy Roads and Trails Project

Alternative 1

Direct and Indirect Effects

Implementation of alternative 1 would result in continued use of all roads currently open unless 

otherwise closed by the Forest travel management process or other smaller projects. Road 

maintenance and use for mining and recreation access and administrative use would continue. 

Direct and indirect impacts to migratory birds from road use are mortality or harm from collision 

with vehicles and reduced habitat quality from road influence.

Cumulative Effects

Road-related impacts to migratory birds are inherent to most activities in the watershed. Taking 

no action under alternative 1 would not be additive to cumulative effects to migratory birds when 

combined with past, present or foreseeable activities in the Sucker Creek Legacy Roads project 

area.

Alternative 2

Direct and Indirect Effects

Effects to neo-tropical migratory birds/landbirds under alternative 2 are variable depending on the 

habitat associations of the individual species.

Vegetation cleared within the footprint of culvert work locations would provide small areas of 

early seral vegetation within a growing season following project implementation. As estimated 

earlier, if all of the culvert locations were cleared of vegetation to improve drainage using a 20-

foot by 20-foot footprint, a total of 4 acres of vegetation would be cleared in the entire project 

area. 

Proposed activities that remove vegetation would have the potential to disturb nesting birds that 

use edge habitats for nesting. However, the seasonal restriction on vegetation cutting activities to 

reduce disturbance to nesting spotted owls would also benefit any nesting birds where these 

activities may take place. Any active bird nests found during proposed activities would be 

avoided for up to 100m where possible, until fledglings have left the nest. No impacts are 

expected to bald eagles or peregrine falcons, or old-growth/mature obligate species such as brown 

creeper, red crossbill and varied thrush because these species would not likely use this edge 

habitat.

The diversity of riparian shrubs, forbs and hardwoods in culvert locations may provide suitable 

foraging habitat for many species. Hermit warblers, Hammond’s flycatcher; Pacific-slope 

flycatcher, Wilson’s warbler, winter wren, Northern goshawk and purple finch are most closely 

tied to deciduous canopy and complex forest floor/understory habitat of which a small amount 

would be disturbed or removed by this project.

The majority of the vegetation removal would be seedling/sapling/pole conifer or riparian 

hardwood such as alder. Impacts to species such as Olive-sided flycatcher; western bluebird; 

orange-crowned warbler; Rufous hummingbird that use this type of habitat would be minimal 

considering the limited area affected at any one location when compared to the amount of habitat 

available in the watershed.

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Proposed road decommissioning, roads converted to trails and roads put into storage are expected 

to benefit migratory bird habitat by restoring natural habitat conditions and reducing road-related 

disturbance.

Cumulative Effects

With measures to avoid harming any active bird nests and the small amount (4 acres) of edge 

habitat that would be disturbed or cleared for culvert work, the contribution of direct and indirect 

effects alternative 2 would be minor to cumulative effects to migratory birds in the Sucker Creek 

Legacy Roads project area.

Conclusion

Implementation of alternative 1 would have no measurable effects to migratory birds considering 

the past and existing use of roads for various activities in the Sucker Creek watershed. The effects 

from implementation of alternative 2 would mostly affect species associated with early forest 

successional stages and edge habitat, with no more than minimal (M) impacts for any species

considering the small amount of vegetation that would be affected at the watershed scale.

Seasonal disturbance restrictions for spotted owls under alternative 2 would also benefit nesting 

neo-tropical birds in the area and proposed road decommissioning and storage would benefit 

birds by restoring natural habitat and reducing road-related disturbance.

Migratory Bird Treaty Compliance: Alternative 1 would have no measureable impacts to 

migratory birds. Alternative 2 would include seasonal restrictions on activities to protect nesting 

spotted owls which would also benefit nesting birds. Any active bird nests would be avoided to 

the extent practicable. Vegetation removal or disturbance under alternative 2 is expected to have 

minimal impacts to species that use edge habitats and proposed decomissioning would benefit 

migratory birds. Therefore, implementation of alternative 2 would meet compliance with the 

Migratory Bird Treaty Act because measures would be taken to minimize short-term impacts and 

enhance habitat for these birds in the long term.

Of the two alternatives evaluated for impacts to wildlife, alternative 2 best meets Forest Plan 

Standards and Guidelines for wildlife and management allocations while meeting the purpose and 

need of restoring watershed health and habitat quality by reducing risk of National Forest System 

road-caused sediment delivery to streams in the 5th field Sucker Creek watershed while retaining 

roads needed for management, special uses, recreation, and fire suppression and other emergency 

needs.

Effects to Northwest Forest Plan Species

Survey and Manage Compliance

The Sucker Creek Legacy Roads project lies within the range of certain Survey and Manage 

species listed in the 2001 NWFP Record of Decision displayed in table 24.

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Table 24. Survey and manage species ranging within the Sucker Creek Legacy Roads project area

Species S&M 

Category

Survey

Triggers

Survey

Results

Within 

Species 

Range?

Contains 

Suitable 

Habitat?

Habitat 

Disturbing?

Surveys 

Required

Survey 

Date 

(MM/YYYY)

Sites 

Known 

or 

Found

Vertebrates

Great Gray 

Owl C Yes Yes No No N/A No

Oregon Red 

Tree Vole C

Yes

(Xeric 

Zone)

Yes No No N/A No

Del Norte 

Salamander

D Yes Yes Yes No N/A Yes

(Known)

Invertebrates

Chase 

sideband B4 Yes Yes Yes No N/A No

Oregon 

shoulderband B4 Yes Yes Yes No N/A No

Del Norte Salamander (Plethodon elongatus)

Reference: http://www.californiaherps.com/salamanders/pages/p.elongatus.html

Found along the coast in far northwest California from near Orick, Humboldt County, east to near 

the Seiad Valley, Siskiyou County and Salyer, Trinity County, and north into southwestern 

Oregon where they have been found inland along West Cow Creek in Douglas County. 

These are Survey and Manage Category D species. They do not require pre-disturbance surveys 

to meet objectives for species persistence because inadvertent loss of some undiscovered sites 

would not change their level of rarity (USDA Forest Service, USDI Bureau of Land Management

2001: Standards and Guidelines 11).

The Forest NRIS Wildlife database documents 146 Del Norte salamander observations mostly 

detected in surveys conducted between 1990 and 2000. These locations are primarily in late 

successional mixed-conifer forested stands and none coincide with any of the proposed culvert 

removal locations.

Alternative 1

Direct, Indirect and Cumulative Effects

There are no anticipated direct, indirect or cumulative effects to Del Norte salamanders from 

taking no action under alternative 1. 

Alternative 2

Direct and Indirect Effects

It is possible that these salamanders may be present in culvert locations which provide cool, moist 

refugia during summer in dry ephemeral draws. Direct impacts include potential harm or 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

mortality of individuals during proposed culvert removal activities. Any salamanders found 

during culvert work would either be left unharmed or moved to suitable moist, shaded habitat 

adjacent to but undisturbed by the work site if there is potential for harm. Vegetation clearing at 

culvert sites may change the microclimate by increasing temperature and decreasing humidity to 

be unsuitable for these species, though any surrounding suitable habitat would not be changed.

Proposed road decommissioning would be beneficial in the long-term where natural habitat 

conditions are restored and road-related disturbance would be reduced.

Cumulative Effects

Ongoing road maintenance, firewood gathering and mining activities would have the most 

potential for direct or indirect disturbance of this species. The contribution of direct and indirect 

effects of alternative 2 to cumulative effects to Del Norte salamanders would be minor.

Conclusion

Implementation of Sucker Creek Legacy Roads Project Alternative 2 may unintentionally harm 

individual Del Norte Salamanders that may be present at culvert replacement sites. Measures 

would be taken to move any observed salamanders from the work site to suitable habitat. Other 

road treatments and vegetation clearance for culverts are not expected to change the suitability of 

any known Del Norte salamander sites because they beyond 100 feet of any known site. This 

Project is expected to maintain existing Del Norte salamander sites and sufficient habitat for these 

salamanders within the entire project area.

Oregon Red Tree Vole (Arborimus longicaudus)

Surveys efforts for red tree voles conducted within the Sucker Creek Legacy Roads project for

several years between 1990 and 2011 have identified 118 red tree vole observations. These 

surveys included the climbing and investigation of trees with suitable habitat characteristics. 

Red tree vole surveys specific to proposed road and culvert treatment activities under alternative

2 of the Sucker Creek Legacy Roads project were not triggered as habitat-disturbing activity. The 

2001 ROD Standards and Guidelines specifically state: “Routine maintenance of improvements 

and existing structures is not considered a habitat-disturbing activity. Examples of routine 

maintenance include pulling ditches, clearing encroaching vegetation, managing existing seed 

orchards, and falling hazard trees” (USDA Forest Service, USDI Bureau of Land Management 

2001: Standards and Guidelines 11: S&G 22). Any trees to be removed from culvert locations 

have grown on the site since the culvert was installed. These trees are on roadside edges and 

would not likely be the largest trees in a stand occupied by red tree voles. The areas that would be 

cleared of vegetation at culvert locations are not considered to be “suitable habitat that may 

potentially contribute to a reasonable assurance of persistence” for red tree voles and therefore do 

not require pre-disturbance surveys (USDA Forest Service, USDI Bureau of Land Management

2001: S&G 23, Huff et al., 2012)

Direct and Indirect Effects

Proposed road treatments and culvert work under alternative 2 are not expected to directly or 

indirectly affect red tree voles because any trees to be removed as hazards or encroachment in the 

fill at culvert locations do not likely have the structure that red tree voles use for nesting or 

contribute to habitat that provides a reasonable assurance of persistence of red tree voles sites in 

the Sucker Creek Legacy Roads project area. Proposed road decommissioning is expected to be 

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Sucker Creek Legacy Roads and Trails Project

beneficial to late successional habitat in the long-term where natural habitat conditions would be 

restored and road-related disturbance removed.

Cumulative Effects

There are no direct or indirect effects of Sucker Creek Legacy Roads Project alternative 1 or 2 

that would contribute to cumulative effects to red tree voles.

Conclusion

Implementation of Sucker Creek Legacy Roads Project is not expected to change the suitability of 

any known red tree vole sites in the project area and is expected to maintain sufficient habitat for 

this species within the entire project area.

Great Gray Owl

The NRIS Wildlife database contains only one incidental sighting of a great gray owl within the 

Siskiyou portion of the Rogue River-Siskiyou National Forest, at Eden Valley on the Powers 

Ranger District. There are no records of great gray owls in the Sucker Creek Legacy Roads 

project area; however there are areas of open meadow habitat greater than 10 acres within the 

project area. Proposed road and culvert treatment activities would occur within the road prism 

and culvert locations that have been previously disturbed. The proposed project would not have 

any significant negative impact on potential habitat in the project area for great gray owls, 

therefore, surveys are not triggered.

Direct, Indirect and Cumulative Effects

For reasons explained above, implementation of Sucker Creek Legacy Roads Project alternative 1 

or 2 would not result in direct or indirect effects to great gray owls, or contribute to cumulative 

effects to this species.

Conclusion

Implementation of Sucker Creek Legacy Roads Project is expected to maintain the suitability of 

potential great gray owl habitat the project area.

Chace Sideband and Oregon Shoulderband

These terrestrial snails have been previously described and evaluated for projects effects in this 

document as USFS Region 6 Sensitive Species. There are no known locations of these species in

the Sucker Creek Legacy Roads project area. 

Survey and Manage Compliance Statement: The Sucker Creek Legacy Roads Project is 

consistent with the Siskiyou National 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 (2001 

ROD). The Project applies the survey and manage species list in the 2001 Record of Decision 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, and survey requirements described in the most recent survey protocols 

for each species.

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Bat Roosts

Fringed, long-eared, and long-legged myotis; silver-haired, pallid, and 

Townsend’s big-eared bats

Five of these species – fringed myotis (Myotis thysanodes), long-eared myotis (M. evotis) , longlegged myotis (M. volans), silver-haired bat (Lasionycteris noctivagans), and pallid bats 

(Antrozous pallidus) – rely on standing snags and large mature trees with crevices for roosting 

habitat. There is strong association with ridges and roosting sites. Four species (fringed myotis, 

long-eared myotis, long-legged myotis and Townsend’s big-eared bats) use mines and caves for 

breeding, roosting and winter hibernacula. Another important habitat component for all bat 

species is the availability of open water for drinking which is abundant in the streams and lakes 

present in the project area. The Forest NRIS Wildlife database documents three observations of 

each long-eared myotis and silver-haired bats and one observations of Townsend’s big-eared bat.

Direct and Indirect Effects

Potential direct effects to these bats under alternative 2 would include disturbance or removal of 

trees with cavities or large snags that provide potential roost habitat within the footprint of culvert 

work locations where vegetation would be cleared, and roadside hazard trees that may be felled 

during road treatment activities. A maximum estimate of 4 acres of vegetation clearance 

distributed among hundreds of culvert locations is not expected to remove a considerable number 

of large trees with cavities or snags when compared to the amount of these features available in 

the entire project area. Furthermore, proposed road decommissioning, roads converted to trails 

and roads put into storage would improve habitat conditions for these bats in the long-term where 

road-related disturbance and hazard tree removal would be reduced.

Cumulative Effects

Ongoing Forest implemented and permitted road maintenance, mining access, recreation and 

existing levels of road use in the project area are expected to continue. The Forest limits the 

number of hazard trees removed along roads and within recreation sites annually under the 

Miscellaneous Projects Programmatic Section 7 Consultation for spotted owls. Potential large 

snag removal under alternative 2 may be additive to cumulative effects to bat roosts when 

combined with past, present or foreseeable activities in the Sucker Creek Legacy Roads project 

area.

Conclusion

This project would not impact existing caves, bridges, mines or abandoned buildings suitable for 

these bat species. Implementation of Sucker Creek Legacy Roads Project alternative 2 may 

remove individual suitable large snags from the road prism or culvert locations throughout the 

project area however, either alternative for this project is expected to maintain sufficient roost

habitat for bats within the entire project area.

Cavity Nesting Birds

Flammulated Owl and White-headed Woodpecker

The flammulated owl (Otus flammeolus) and white-headed woodpecker (Picoides albolarvatus)

are closely associated with the mixed-forest habitat type but require a ponderosa pine component. 

These species are associated with multi-story, moderate-closed canopy closure structural 

conditions. Trees with cavities are an important habitat element for these species. The Sucker 

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Sucker Creek Legacy Roads and Trails Project

Creek Legacy Roads Project area provides suitable habitat for these species. The Forest NRIS 

Wildlife database contains 1 flammulated owl observation and 7 white-headed woodpecker 

observations at the throughout the mid and higher elevations of the project area.

Direct and Indirect Effects

Proposed road and culvert treatments may remove some trees with cavities. The estimated 

maximum area of vegetation removal for culvert work in the project area is 4 acres. It is not 

expected that there would be a substantial number of trees with cavities removed from these sites 

when compared to the habitat available for these species in the Sucker Creek Legacy Roads 

project area. 

Cumulative Effects

Ongoing road maintenance, mining access, recreation and existing levels of road use in the 

project area are expected to continue. The Forest limits the number of hazard trees removed along 

roads and within recreation sites annually under the Miscellaneous Projects Programmatic 

Section 7 Consultation for spotted owls. Hazard tree and vegetation removal under alternative 2 

may be additive to cumulative effects to cavity nesting birds when combined with past, present or 

foreseeable activities in the Sucker Creek Legacy Roads project area.

Conclusion

Although implementation of Sucker Creek Legacy Roads Project alternative 2 may remove 

individual suitable trees with cavities from the road prism or culvert locations throughout the 

project area, either alternative for this project is expected to maintain sufficient habitat for cavity 

nesting birds within the entire project area.

Aquatic Biota

Introduction

This section describes the current condition of fish species and habitat within the affected 

watershed and the effects of project activities (identified in chapter 2) on those resources. Nonfish aquatic resources are discussed as well. Information and analyses are based on the fish eries 

report and the aquatic biota biological evaluation. Mitigation measures and project design criteria

to minimize or prevent effects to fish and non-fish species are listed in chapter 2. 

A pilot inventory, covering the Sucker Creek watershed, was conducted in 1995 and resulted in 

the Grayback/Sucker Key Watershed Analysis. The pilot analysis was supplemented with the 

Grayback-Sucker Watershed Analysis in 1998. In 2011 the area was analyzed using the Watershed 

Condition Framework process (USDA Forest Service 2010). This analysis found that the 

Grayback Creek, Middle Sucker Creek, and Lower Sucker Creek watersheds are in Watershed 

Condition Class II, functioning at risk (FSM 2521.1). This rating is due largely to road density, 

fine sediment in stream channels, high summer water temperature, simplification of in-stream 

channel habitat, and lack of off-channel habitat. The Upper Sucker Creek watershed was found to 

be in Condition Class I, functioning properly. In response to these ratings a Watershed 

Restoration Action Plan (WRAP) for the Sucker Creek watershed was completed in 2011 and 

identified both Grayback Creek and Middle Sucker Creek as priority subwatersheds. The Sucker 

Creek watershed is also considered a Tier 1 Key Watershed under the Northwest Forest Plan 

(USDA, USDI 1994). 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Proposed activities for the Sucker Creek Legacy Roads and Trails Project are identified in chapter 

2, alternative 2-modified proposed action. Watershed analyses for the affected watersheds were 

used to help develop the proposed activities. None of the proposed activities are inconsistent with 

the findings and recommendations of the Watershed Analyses.

Affected Environment

Endangered Species Act (ESA) Action Area

The action area, as defined by the ESA, is all areas to be affected directly or indirectly by the 

federal action and not merely the immediate area involved in the action [50 CFR § 402.02]. The 

action area not only includes the immediate footprint of the road-related activities, but any 

downstream reaches which may be affected indirectly.

The action area for this project is defined as the Sucker Creek 5th field watershed. The action area 

is defined this way because it is possible sediment changes resulting from this project could be 

observed in the mainstem of Sucker Creek. Sucker Creek is a Northwest Forest Plan Key 

Watershed and one of the highest priority restoration watersheds on the Rogue River-Siskiyou 

National Forest. In addition, Sucker Creek is designated Essential Salmonid Habitat by the 

Oregon Division of State Lands, and a Core Salmonid Area by Oregon Department of Fish and 

Wildlife. Further, the Sucker Creek watershed is a stronghold for threatened Southern Oregon 

Northern California Coast (SONCC) Coho Salmon and contains high intrinsic potential Coho 

habitat. The “Overview of ESA listed species and ESA and MSA (Magnuson-Stevens Fishery 

Conservation Act) Habitat” is available for review in the project files.

ESA listed species and MSA species & habitat - watershed scale

The Illinois River 4th field subbasin is one of the most important subbasins of the Rogue River 

for naturally produced Coho Salmon with perhaps half the wild Rogue Coho Salmon population 

residing here. This subbasin also has large populations of fall Chinook and winter Steelhead Trout 

in addition to resident Cutthroat and Rainbow Trout and other species. The Illinois River subbasin 

was identified as a focal basin and salmon stronghold by the non-profit Wild Salmon Center. The 

upper Illinois River tributaries, including Sucker Creek, produce about 33 percent of the wild 

Coho Salmon in the entire Rogue basin. Sucker Creek watershed is a high value spawning and 

rearing tributary for all anadromous fish species in the Illinois River subbasin. There is no 

hatchery supplementation in the Illinois River subbasin as it is managed exclusively for wild fish. 

Four anadromous fish species occur in the Sucker Creek 5th field watershed (Coho Salmon, 

Chinook Salmon, winter Steelhead Trout and Pacific Lamprey); two native resident salmonids 

(Coastal Cutthroat Trout and Rainbow Trout); and Reticulate Sculpin as well as Klamath Smallscale Suckers. Redside Shiners and other fishes have been introduced. Steelhead trout in the 

Sucker Creek watershed contribute to a valuable recreational fishery in the Illinois and Rogue 

Rivers. Within the Sucker Creek watershed, the Lower Sucker Creek subwatershed has the most 

miles of occupied anadromous fish habitat and Upper Sucker Creek subwatershed the least. Fish 

species and miles of presence are depicted in table 25. Fish distribution for Sucker Creek 

watershed is shown in figure 14.

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Sucker Creek Legacy Roads and Trails Project

Figure 14. Fish distribution in the Sucker Creek watershed

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Table 25. Fish species and presence within Sucker Creek 5th field watershed

Anadromous Resident

6th Field Subwatershed 

*Priority Subwatershed

Coho 

Salmon

(miles)

Chinook 

Salmon

(miles)

Winter 

Steelhead

(miles)

Resident Trout

(cutthroat &

rainbow) (miles)

Upper Sucker Creek 2.2 0 2.2 8.7 

*Middle Sucker Creek 9.1 0.4 9.7 20.1 

*Grayback Creek 3.4 1.5 4.1 17.0 

Lower Sucker Creek 13.4 11.2 13.5 15.8 

Total – 5th Field 28.1 13.1 29.5 61.6 

Grayback Creek subwatershed has one of the highest density spawning streams (Grayback Creek) 

in southwest Oregon. While over 70 percent of the low-gradient high and very high potential 

Coho Salmon habitat is found on private lands in Lower Sucker Creek subwatershed, Grayback 

Creek and Middle Sucker Creek subwatersheds support moderate populations of Coho Salmon. 

Grayback Creek is the largest fish-bearing tributary in the Sucker Creek watershed central to the 

range of migrating salmon and an important Coho Salmon and Steelhead stream containing cool 

summer water flows. The lower 3 miles of this stream serves as an anchor point for salmon 

recovery and repopulation of adjacent habitats. This stream reach is important refugia during 

extreme climate conditions, particularly warming periods, and supports core populations of 

salmon. 

The Middle Sucker Creek subwatershed has some of the highest potential for salmon production 

in the Illinois River sub-basin and serves as a biological node for recovery and repopulation of 

Coho Salmon in adjacent habitats. Coho Salmon use the full suite of habitats available and any 

improvement in fish habitat directed at Coho will benefit Chinook, Steelhead and Lamprey. The 

habitat in this subwatershed complements salmon habitat use in the downstream wide valley 

stream segments on private lands. Egg incubation and first summer juvenile rearing occurs here 

and over-wintering and early spring habitat for juvenile salmon occurs in the downstream 

segment on private lands. 

The Lower Sucker Creek subwatershed, despite human pressures, remains a primary salmonproducing area in southwest Oregon; fall Chinook Salmon, Coho Salmon, winter Steelhead and 

Pacific Lamprey all spawn and rear here. Annually, hundreds of salmon and steelhead spawn 

from Grayback Creek downstream to the confluence with the East Fork Illinois River, a distance 

of about 12 miles. 

Special status for fishes in the watershed is stated below: 

♦ Endangered Species Act: Southern Oregon Northern California Coasts (SONCC) Coho 

Salmon and its critical habitat are listed as federally-threatened 

♦ Magnuson-Stevens Fishery Conservation Act: Coho and Chinook Salmon Essential Fish 

Habitat 

♦ R6 Sensitive Species List: Southern Oregon Northern California Coastal (SONCC) 

Chinook Salmon 

The most important anadromous fish-bearing streams in the 6th field subwatersheds are: 

♦ Upper Sucker Creek: Sucker Creek and Left Fork Sucker Creek 

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Sucker Creek Legacy Roads and Trails Project

♦ Middle Sucker Creek: Sucker Creek and lower Cave Creek 

♦ Grayback Creek: Grayback Creek 

♦ Lower Sucker Creek: Sucker Creek and Bear Creek 

Invasive species are not currently a major threat to native fishes in the Sucker Creek watershed. 

Exotic brook trout are present within Tannen and Bolan lakes and in the outflows only. Exotic 

Umpqua pike minnow and red side shiner have not become established in Sucker Creek on Forest 

Service lands, although they are expanding their range in lower Sucker Creek. Climate change 

and subsequent warming of surface waters during summer months may cause upstream migration 

of these exotic species and increased competition with trout and salmon. Other invasive aquatic 

and riparian species such as New Zealand mudsnails, Japanese knotweed and purple loosestrife 

have not currently invaded Sucker Creek (USDA Forest Service 2007).

Other Aquatic Biota

The other three anadromous fish species that occur in the Sucker Creek 5th field watershed 

(Chinook Salmon, winter Steelhead Trout and Pacific Lamprey); two native resident salmonids 

(Coastal Cutthroat Trout and Rainbow Trout); and Reticulate Sculpin as well as Klamath Smallscale Sucker are subjected to the same conditions as Coho within the watershed. The magnitude 

of effect to each of these species is variable, yet similar to those disclosed within this document 

for Coho Salmon.

Other aquatic biota potentially found on or downstream of the Rogue River-Siskiyou National 

Forest, were not addressed in this biological evaluation because they do not occur in the action 

area based on Forest Service surveys and professional knowledge.

Aquatic Habitat

The Sucker Creek watershed is located near the geographic center of the Klamath Mountains 

geologic province. The watershed is unusual for its limited amount of serpentine geology 

(compared to other Illinois River watersheds), and the presence of marble caves. 

The stream channels along the mainstem of Sucker Creek and lower reaches of Grayback and 

Caves Creeks are “C” channel types (sinuous, low gradient channels; Rosgen 1994). Tributary 

streams and upper reaches of mainstem creeks are mainly “B” (low sinuosity, moderate gradient) 

and “A” (low sinuosity, high gradient) channel types per the Rosgen classification system. 

Sediment and large wood, which have a synchronous relationship in creating fish habitat, can 

move quickly during storms to the “C” depositional stream reaches in mainstem Sucker Creek 

and lower Grayback Creek, which are important to salmon. Generally there is a surplus of 

sediment and a dearth of large wood that limits the creation of complexes that could form pools 

and sort substrate particles for a diversity of stream bed habitats. The lower Sucker Creek 

subwatershed is a wide alluvial valley that is primarily in agricultural use. Public and private 

lands managed for timber production also occur in the northern portions of the subwatershed in 

several drainages. 

The location of the proposed, endangered, threatened, or sensitive (PETS) aquatic biota essential 

fish habitat (EFH), and critical habitat (CH) within the project area was determined using current 

Forest Service GIS and field data. In general, aquatic habitats in the action area have been 

modified and simplified, water quality and riparian vegetation within this watershed are reflective 

of past stream cleanout, past hydraulic and placer mining activities, logging and roads in the 

riparian area. The stream channel in some of the areas within the watershed has been straightened 

and realigned, causing the channel to be wide, shallow, of steeper gradient and simplified 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

compared to the natural potential which has reduced viable habitat for Coho Salmon. In some 

locations, mine tailing piles confine the channel and channel instability has caused excessive 

erosion and steep cutbanks. 

There are no water quality limited streams within the Sucker Creek watershed (Oregon DEQ 

2014). Though there is substantial evidence of past and current sediment loading in associated 

streams and the sediment influx is an existing and persistent concern (USDA Forest Service

2014). The most direct impact found within the watershed for aquatic species is the input of 

sediment in Grayback Creek. This sediment input is a plausible explanation for low smolt output 

in 2006. In late December 2005, a landslide and associated culvert failures sent a debris torrent 

down the White Rock Creek drainage. This debris torrent resulted in deposition of several 

thousand cubic yards of coarse sand and other sediments in lower Grayback Creek, scouring 

Coho Salmon redds and filling in side channels and off-channel habitat used for juvenile Coho 

rearing. The relatively high number of Coho parr in summer 2005, low number of Coho smolts in 

2006, and observed redd scouring (Reid unpublished monitoring report) suggests the winter high 

flows and associated debris torrent significantly impacted at least one, if not two, year classes of 

Coho Salmon. Surprisingly, the December 2005 flows that triggered the landslides and associated 

debris torrent were far below flood stage at the sub-basin level and barely exceeded average 

bankfull levels.

For more specific descriptions of aquatic habitat quality and quantity of streams in the action area 

refer to the aquatic biota biological evaluation, the hydrology section in this EA and the 

hydrology report in the project record, the Sucker Creek Aquatic Restoration Plan (USDA Forest 

Service 2011), the Sucker Creek watershed Analyses (USDA Forest Service 1998), and stream 

inventories of pertinent streams (available from the Rogue River-Siskiyou National Forest).

Environmental Consequences

This analysis evaluates the potential direct, indirect and cumulative effects of the proposed action 

on species and habitat for: SONCC Coho, CH, EFH and R6 sensitive species. Critical habitat and 

essential fish habitat are the same in the action area, so any potential effect to one (i.e., CH) 

would obviously result in an effect to the other (i.e., EFH). This analysis will discuss affects to 

CH for feasibility and readability, recognizing that the same effect would apply to EFH.

Effects of alternatives on primary constituent elements (PCEs)

The activities for the modified proposed action under the Sucker Legacy Roads and Trails Project 

were split into four project elements: (1) stormproofing, (2) road storage, (3) road 

decommissioning, and (4) road to non-motorized trail conversion. Table 26 displays proximity of 

project activities in relation to critical habitat.

Table 26. Proximity of project elements to critical habitat within Sucker Creek 5th field watershed

Project Elements (PE) Distance to Critical Habitat

Stormproofing 0.01 - 3.5 miles

Road Storing 0.01 - 3.5 miles

Road Decommissioning 0.01 - 3.0 miles

Road to Non-Motorized Trail Conversion 3.0 - 4.0 miles

The following PCE habitat and watershed condition indicators have been reviewed for possible 

effects:

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Habitat Indicators (includes all indicators): Water quality (temperature, chemical 

contaminants/nutrients, sediment & pool character & quality), large wood, off-channel 

habitat, width/depth ratio by channel type, streambank condition, floodplain connectivity, and 

changes in peak and base flows

Watershed Condition Indicators (includes all indicators): Road density/location, human 

disturbance history, riparian reserves, and landslide and erosion rates

The small trees that would be removed within the riparian area are not providing stream shading 

for the river systems, nor are the trees a size in which they would act as large wood. If any large 

trees need to be removed at the sites they would be placed directly into the stream channel above 

bankfull flow levels as large wood where they would interact with the stream and help create 

habitat.

Alternative 1 – No Action

Direct Effects

Under alternative 1 – no action, the existing environmental condition would remain the same and 

would not change any of the above habitat indicators or watershed conditions.

Indirect Effects

Road Decommissioning/Storage/Stormproofing

Indirect effects could occur to sediment and pool character and quality because general road 

maintenance as funding allows and environmental conditions warrant would continue. All other 

PCEs would remain the same.

Sediment and Pool Character and Quality Effects

No road decommissioning or storage treatments would occur; however, stormproofing could still 

be done on level 2 and 3 roads. Level 2 roads are considered a low priority and the likelihood of 

road maintenance occurring on these roads is very low. Therefore, this analysis assumed that 

stormproofing would only occur on level 3 roads. The existing roads would be managed in their 

current state, and would continue to affect hillslope hydrology, act as connected disturbed areas, 

and degrade water quality because of the high potential sediment yield especially within the 

Middle Sucker Creek, Upper Sucker Creek, and Grayback Creek watersheds. The extent of this 

impact on individual species and their habitat is not quantifiable because it is only a potential 

effect that may occur in the future. The effects of road maintenance on SONCC Coho Salmon is 

covered in the Western Oregon Programmatic Biological Opinion (WOPBO)(NMFS 2011).

Proximity: All of the roads described in this project are upstream of CH by at least 0.01 mile to 

greater than 3 miles (table 26).

Probability: The hydrology report noted the locations of the current road structures (culverts).

The probability of failure at a specific structure is unknown, but could occur. The amount of fine 

sediment material that could be contributed to the stream channel is also in the hydrology report.

Magnitude: The hydrology report discloses the amount of sediment for potential delivery. In 

some portions of the watershed, road-related sediment has been implicated as the major limiting 

factor to fish production. Road sediment has been described as the primary aquatic habitat 

degradation factor within the Grayback subwatershed. This sediment could affect several miles of 

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aquatic habitat depending on how much of the sediment does get delivered and transported 

downstream.

Alternative 2 – Modified Proposed Action

Road to Non-motorized Trail Conversion

This proposed activity will not be analyzed any further for direct or indirect effects because this 

action is over 3 miles upstream of CH and will have no effect on any of the habitat indicators or 

watershed conditions, nor will it affect any other aquatic biota. 

Direct Effects

Stormproofing, Road Storage, and Road Decommissioning

Sediment and pool character and quality effects

A direct causal mechanism to sensitive and threatened fish species or their habitat under this 

alternative is present where heavy equipment would be used in or near the stream channel. The 

unavoidable short-term adverse effects resulting from these activities include disturbance of 

riparian vegetation, exposure of bare soil, increased stream turbidity, increased fine sediments in 

stream substrates, and increased risk of chemical contamination from fuel and lubricants. The 

construction activities at these sites are likely to last two weeks at a maximum. During the time 

that heavy equipment is operating, juvenile salmonids may experience decreased feeding, 

increased stress, or be unable to use the stream immediately adjacent to the respective project site, 

depending on the severity of the turbidity increase. Also when the first fall rain comes the fish 

may experience sediment entering the stream. Although this represents a major behavioral 

change, the temporal and spatial scale of the impact is too small to cause measurable effects at the 

population level. 

Proximity: All of the roads described for this project are upstream of CH and it is only the 

portions of this project that are within 1,000 feet of CH that have the potential to move fine 

sediment or contaminants downstream to this habitat. The remaining portions of this project are 

located over 1,000 feet from CH and use of heavy equipment at these sites would not create a 

direct causal mechanism for fine sediment or chemicals to reach CH.

Probability: The probability of direct effect would be dependent on each site location and the 

environmental conditions at the time the project is implemented. Specifically, increased sediment 

production in stream systems has been shown to adversely affect Pacific Northwest salmonid 

species through reduction in gravel permeability and reduced egg to fry survival (Cederholm et 

al. 1980; Furniss et al. 1991). Further, sediment can reduce macroinvertebrate production and fill 

pools, reducing habitat quantity and salmonid food availability (Suttle et al. 2004; Harvey et al. 

2009). A direct linkage also exists between sediment supply and stream habitat indicators such as 

gravel permeability and pool depth (Cover et al. 2008). Likewise, inverse relationships exist 

between sediment-related stream habitat indicators and fish survival (Suttle et al. 2004; Harvey et 

al. 2009). 

Magnitude: The magnitude of fine sediment is predicted to be very minimal, lasting no longer 

than two weeks at a maximum and is likely to directly affect the CH.

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Stormproofing, road storage, and road decommissioning would reduce road miles in the Sucker 

Creek watershed.

Sediment and pool character and quality effects

Forest roads are known to contribute to the source of sediment to fish habitat. 

Proximity: All of the roads described for this project are upstream of listed fish and aquatic 

species and their habitat. Each of these sites has the potential to move fine sediment or 

contaminants downstream to this habitat.

Probability: The probability would be dependent on each site location and the conditions of the 

environment at the time the project is implemented.

Magnitude: Thirty miles of road reduction within the Sucker Creek watershed would occur, 

reducing density from 2.5 to 2.1 miles per square mile. Forest roads built for timber harvest and 

access to other natural resources can be significant sources of sediment to aquatic systems.

Summary of Direct Effects

The use of heavy equipment presents a direct causal mechanism for sediment delivery to CH 

which would likely affect the behavior of the fish.

The reduction in roads within the watershed is part of the watershed condition indicators

specifically road density/location and leads to a long term beneficial effect to these indicators.

Effects from all action alternatives would be beneficial to fish and aquatic organisms in the long 

term. There would be some short-term detrimental effects caused by an increase in turbidity as a 

result of removing culverts and legacy structures, and recontouring slopes where culverts are 

removed in close proximity to CH. These short-term effects are expected to last no longer than 2 

weeks.

Indirect Effects

Stormproofing, Road Storage, and Road Decommissioning

Alternative 2 changes the current environmental conditions within the watershed and could result 

in short- and long-term indirect effects to water quality (temperature, chemical contaminants or 

nutrients, sediment, pool character and quality, streambank condition, floodplain connectivity)

Proximity: The closer the project site is to CH the more beneficial the long-term effect could be 

for the affected species and habitat. The hydrology report lists the amount or work that would be 

implemented within 300 feet of the stream course along with the amount of sediment likely to be 

delivered to the stream channel at each stream crossing. The causal mechanism for indirect effect 

for stormproofing, road storage, and road decommissioning are the changes to the sediment 

budget associated with road treatments including biological criteria in Sucker Creek. No changes 

are expected in water temperature, dissolved oxygen, large wood, hazardous materials or any 

other water quality or habitat parameter from any of the proposed activities.

Probability: The project would have long-term indirect positive effects on CH, due to a reduction 

in the amount of sediment that could be available for sediment delivery into the stream channels.

Short term negative effects are likely to occur during project implementation or after the first rain 

storm where stormproofing, road storage or road decommissioning activities have been 

implemented.

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Magnitude: Seetable 2, table 3, and table 4 for exact quantities of sediment that are available for 

sediment delivery within each subwatershed.

Summary of Indirect Effects

There would be a short-term negative and long-term beneficial effect to for water quality 

(temperature, chemical contaminants/nutrients, sediment, pool character and quality, streambank 

condition, floodplain connectivity) from stormproofing, road storage, and road decommissioning

within the action area. The project activities provide a mechanism for potential reduction in 

upland erosion and sediment influx into stream networks, restoring the channel connections and 

streambanks8

. 

Effects to Potentially Affected Aquatic Species and Habitats

SONCC Chinook Salmon is found within the Sucker Creek watershed and may experience the 

same effect as the SONCC Coho.

Namamyia plutonis, a caddisfly species, is found within the Oregon coast range and Cascade 

Range, and suitable habitat may exist at any of the stream sites on Wild Rivers Ranger District in 

the Sucker Creek watershed. Though this species has not been documented on the Wild Rivers 

Ranger District, the project may impact N. plutonis by delivering sediment to the habitat or 

crushing the individuals if they are present because they are small and live in and near streams; 

possibly where heavy equipment would be used for implementation of project elements.

Following implementation of the project element(s), each site would be vegetated utilizing native 

plants and shrubs, accelerating the growth and establishment of riparian vegetation.

Western ridged mussels have been found in the Rogue River. Suitable habitat for this species is 

typical of some of the stream channel habitat that may be at or immediately adjacent to some of 

the project sites within the action area. Though, this species is not known to occur within the 

action area. The potential for effects to this species is very low. If present within the project area, 

the western ridged mussel may encounter some increase in fine sediment. These sediment effects 

would be mitigated through the implementation of the erosion control plan submitted for this 

project. 

This project would have similar sediment-related effects on all other aquatic species and fish as 

described above for the TES species. The project may also remove culverts that are current 

barriers to aquatic species, potentially facilitating upstream access to new habitats.

Cumulative Effects

Cumulative effects for alternatives 1 and 2 are those that result from the incremental 

accumulations of all land management activities across all ownerships. In the Sucker Creek 

watershed. In the Sucker Creek watershed, historic land management activities such as hydraulic 

mining, channelization, riparian timber harvest, and road construction have had an enduring and 

significant impact on salmonid production (USDA Forest Service 2006). The amount of sediment 

delivery that could enter any of the water bodies from the project activities would be a nominal 

8 Detailed effects can be reviewed in the Reinitiation of the Endangered Species Act Section 7 Formal 

Programmatic Conference and Biological Opinion and Magnuson-Stevens Fishery Conservation and 

Management Act Essential Fish Habitat Consultation for Aquatic Restoration Activities in the States of 

Oregon and Washington (2013 ARBO) for categories #12. Road and Trail Erosion Control and 

Decommissioning.

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amount and only occur for a short duration. It is unlikely that the sediment that would enter a 

water body would be measurable and it is determined that the most likely impact salmon fisheries 

or aquatic species would endure is individual displacement within the immediate area of the work 

sites. Consequently, it is concluded that project generated sediment would not be of sufficient 

quantity to result in a cumulative sediment effect with other projects within the watershed.

Since adoption of the Northwest Forest Plan in 1994, many of the Sucker Creek tributaries on 

public land are likely recovering from prior management activities due to current management 

guidelines and policies. For example, Gallo et al. (2005) and Reeves et al. (2006) assessed 250 

sixth-field watersheds in the Pacific Northwest and found a general increase in stream habitat 

quality in the first 10 years after the adoption of the Northwest Forest Plan, particularly in key 

watersheds and late-successional reserves. Sucker and Grayback Creeks are key watersheds. The 

Sucker Creek watershed is one of the highest priorities for watershed restoration (containing 2 of 

5 priority subwatersheds for watershed restoration) on the Rogue River-Siskiyou National Forest 

(USDA Forest Service 2011), with several significant watershed restoration projects conducted 

over the last decade. In addition to protection by Northwest Forest Plan standards and guidelines, 

the Sucker Creek watershed has several other active restoration projects ongoing including fuels 

reduction, riparian thinning and large wood placement. Finally, this watershed is almost entirely 

forest or rural residential land cover, a land use pattern that has shown benefit for ensuring Coho 

Salmon viability when compared to urbanization (Bilby and Mollot 2008).

Comparison of Effects by Alternative

Table 27. Comparison of effects to aquatic biota for each alternative by activity type

Alternative Stormproofing Road Storage Road 

decommissioning

Road to nonmotorized trail 

conversion

1 (no action) Negative (short term) and 

Beneficial (long term)) Not applicable Not applicable Not applicable

2 (action) Negative (short term) and 

Beneficial (long term) Neutral

Negative (short term) 

and Beneficial (long 

term)

Neutral

Differences between the two alternatives could be measurable and biologically important based 

on predicted background erosion rates, forecasted sediment reduction, and permeability-survival 

relationships. 

The no-action alternative would not alter the existing road treatments that may occur in the 

Sucker Creek watershed on the RRSNF. Alternatives 1 and 2 could have short-term negative 

effects due to sediment delivery from road related activities; however, there would be a long-term 

beneficial effect from reduction of road generated fine sediment that can embed gravels and fill 

pools. The primary effect would be a decrease in upland erosion and sediment influx into stream 

channels, associated with storm proofing, road storage and road decommissioning activities 

within the watershed. Alternative 1 would result in a less positive long term effects and have less 

negative short-term effects than alternative 2, as only a limited amount of stormproofing would 

occur. Alternative 2 would result in the most beneficial long term effects despite any short term 

sediment effects that may occur. 

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Effects Determinations

Alternative 1

Alternative 1 could have short-term indirect effects to SONCC Coho Salmon, SONCC Coho CH, 

SONCC Chinook Salmon, western ridged mussel, and N. plutonis.

Alternative 1 would have no effect on OC Coho Salmon, S. DPS North American Green Sturgeon 

or S. DPS Pacific Eulachon, PC Chum Salmon, OC Steelhead, Highcap lanx, Scale lanx, Robust 

walker, Pacific walker, or Haddock’s Rhyacophilan caddisfly.

Alternative 2

Alternative 2 could have short-term direct, and short- and long-term indirect effects. Based on a 

review of best available science and my professional judgment, I find direct, indirect, and no 

cumulative effects from alternative 2 of the Sucker Legacy Roads and Trails Project.

Consequently, a determination of “May Affect, Beneficial” and “Likely to Adversely Affect” to 

SONCC Coho Salmon, and its critical habitat is rendered.

A determination of “May impact individuals or habitat, but will not likely contribute to a 

trend towards federal listing or cause a loss of viability to the population or species” is made 

for the SONCC Chinook salmon, Western ridged mussel, and N. plutonis. The reason for a 

negative effect is due to short term sediment delivery from culvert removals and movement of 

sediment because of direct disturbance of the stream channel during project implementation. A 

long-term beneficial effect is a result of a long term reduction of road generated fine sediment 

that can embed gravels and fill pools.

Essential Fish Habitat is the same as Critical Habitat in the action area. Therefore, the same 

determination of effects applies to EFH, as was disclosed above for CH. The project Sucker 

Legacy Roads and Trails Project has a “Beneficial Impact” and “Likely to Adversely Affect”

Essential Fish Habitat for Coho Salmon or Chinook Salmon.

Because this project fits under the categories described in the Re-initiation of the Endangered 

Species Act Section 7 Formal Programmatic Conference and Biological Opinion and MagnusonStevens Fishery Conservation and Management Act Essential Fish Habitat Consultation for 

Aquatic Restoration Activities in the States of Oregon and Washington (2013 ARBO) for category 

#12. Road and Trail Erosion Control and Decommissioning, no further consultation with the 

National Marine Fisheries Service is required provided project design criteria are applied (chapter 

2).

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Table 28. Summary of Conclusion of Effects for TES

Species No Action Modified Proposed Action

SONCC coho BI-LAA BI-LAA

SONCC Coho CH BI-LAA BI-LAA

SONCC Coho EFH BI-LAA BI-LAA

OC coho NE NE

OC coho CH NE NE

OC coho EFH NE NE

S. DPS Pacific eulachon NE NE

S. DPS North American green 

sturgeon

NE NE

SONCC Chinook salmon BI-MIIH BI-MIIH

PC chum salmon NI NI

OC steelhead NI NI

Western ridged mussel BI-MIIH BI-MIIH

Highcap lanx NI NI

Scale lanx NI NI

Robust walker NI NI

Pacific walker NI NI

Haddock’s Rhyacophilan caddisfly NI NI

A caddisfly BI-MIIH BI-MIIH

Note: 

LAA= Likely to Adversely Affect; NE = No Effect; BI-NLAA = Beneficial, Not Likely to Adversely Affect; NI = No 

Impact; MIIH = May Impact Individuals or Habitat, But Will Not Likely Contribute to a Trend towards Federal Listing or 

Cause a Loss of Viability to the Population or Species; BI = Beneficial Impact

Roads

Introduction

While roads often provide important access and transportation, their presence can also influence 

the habitat quality, hydrology, geomorphology, and ecosystem processes of watersheds. The 

Sucker Creek watershed was selected for treatment because it has been identified as one of the 

top three priority watersheds on the Rogue River-Siskiyou National Forest for watershed 

restoration since 2006. This analysis is going to focus on changes to road access and maintenance 

costs in the Sucker Creek watershed from proposed project activities (identified in chapter 2). The 

transportation report is summarized and referenced throughout this section and is available for 

full review in the project files.

Affected Environment

Current policy requires the Forest Service to undertake a “scientifically-based” road analysis 

procedure, at appropriate scales and coordinated with other ecosystem analyses, to make better 

decisions regarding road management. Roads analysis at the forest scale will generally provide a 

broad context for informing road management decisions. Site-specific projects may be informed 

by project-scale analysis.

Forest Service responsible officials are directed to use a roads analysis process to ensure that road 

management decisions are based on identification and consideration of social and ecological 

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effects. Roads Analysis: Informing Decisions about Managing the National Forest Transportation 

System (Miscellaneous Report FS-643) has been provided as guidance for conducting a sciencebased roads analysis. This document describes the process that was used to evaluate the current 

road system for current and future needs associated with the Sucker Creek Legacy Roads and 

Trails Project. The goal of this project-scale analysis is to compare the need for roads to access 

the project planning area, with the effects roads have on natural resources.

At the forest scale and in conformance with the roads management policy, a more general 

assessment of roads was conducted and compiled in 2004 (Rogue River-Siskiyou National Forest 

Roads Analysis). A forestwide revision of this road management policy will be completed by 

2015. 

Current Road Inventory – Sucker Creek Watershed

It is important to note that roads9 occurring on Forest Service managed lands are not public roads 

in the same sense as roads under the jurisdiction of public road agencies, such as states or 

counties. Forest Service roads are not intended to meet the transportation needs of the public at 

large. Instead, they are authorized only for the administration and utilization of National Forest 

System lands. Although generally open and available for public use, such use is at the discretion 

of the Secretary of Agriculture. Through authorities delegated by the Secretary, the Forest Service 

may restrict or control use to meet specific management direction.

The Roads Analysis process starts with an inventory of all roads in the project planning area 

(Sucker Creek watershed). There are various scales that can be used when assessing road systems. 

This roads analysis utilizes a project-scale road analysis area. The analysis area for this

assessment includes those roads located in the Sucker Creek watershed. A database was 

developed to inventory all roads that are within the analysis area. Digital files representing road 

locations were secured from the Forest Service geographic information systems (GIS) for the 

Rogue River-Siskiyou National Forest.

a. Classified Road System

The following discussion includes the basis for use of classified (permanent system) roads. 

National Forest System roads are under the jurisdiction of the Forest Service and are deemed 

necessary for protection, administration, and use of National Forest System lands. These roads are 

inventoried, maintained, and managed by the Forest Service. Generally, these National Forest 

System roads are identified as maintenance level 1 to 5, under the following definitions:

9 The following definitions are from Forest Service Manual (FSM) 7705 and are pertinent to this roads 

analysis process.

Forest Roads. As defined in Title 23, Section 101 of the United States Code (23 U.S.C. 101), any 

road wholly or partly within, or adjacent to, and serving the National Forest System and which is 

necessary for the protection, administration, and utilization of the National Forest System and the 

use and development of its resources.

Roads are further defined:

Road. A motor vehicle travel way over 50 inches wide, unless designated and managed as a trail 

(36 CFR 212.1). For this analysis, a road may be classified, unclassified, or temporary.

a. Classified Roads. Roads wholly or partially within or adjacent to National Forest System lands 

that are determined to be needed for long-term motor vehicle access, including State roads, county 

roads, privately owned roads, National Forest System roads, and other roads authorized by the 

Forest Service.

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♦ Level 1 – Basic custodial maintenance is performed to keep damage to adjacent resources 

to an acceptable level and to perpetuate the road to facilitate future management 

activities. While being maintained at level 1, roads are closed to vehicular traffic, both 

public and administrative motorized vehicle use.

♦ Level 2 – Assigned to roads open for use by high clearance vehicles. Traffic is normally 

minor, usually consisting of one or a combination of administrative, permitted, dispersed 

recreation, or other specialized uses.

♦ Level 3 – Roads in this maintenance level are typically low speed, single lane with 

turnouts and spot surfacing. Some roads may be fully surfaced with either native or 

processed material.

♦ Level 4 – Most roads are double lane and aggregate surfaced. However, some roads may 

be single lane. Some roads may be paved and/or dust abated.

♦ Level 5 – These roads are normally double lane, paved facilities. Some may be aggregate 

surfaced and dust abated.

Most of the classified road system within the Sucker Creek watershed is currently managed as 

Maintenance Level 3. There are approximately 200 miles of roads within the Sucker Creek 

watershed.

The following is a brief description of the three key terms used in classifying the proposed work 

to be performed within the watershed:

♦ Stormproof – Roads proposed for stormproofing will be identified as Maintenance Levels 

2, 3 and 4

♦ Storage – Road proposed for storage, needed within the next 10 years, will be assigned 

Maintenance Level 1

♦ Decommissioned – Road proposed for decommissioning will be removed from the Forest 

Service road system

b. Analysis of Existing Roads

Roads analysis identified a need for most of the existing roads for long-term management of the 

Forest, and for access to recreation opportunities. Most of the existing roads are typically open to 

the public and maintained for vehicular traffic. These existing roads provide the long-term 

transportation network necessary to meet forest management objectives. The “backbone” roads in 

Sucker Creek are roads that are currently needed and into the future for multiple purposes. They 

provide important access to Oregon Caves National Monument, for land management, mining, 

and recreation needs in the watershed.

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Table 29. The “backbone” system roads in Sucker Creek watershed

Forest Service 

System Road Miles Modified Proposed 

Action Accesses

4600 6.0 State Highway Oregon Caves National Monument and 

4611, 4612,4614 road systems

4611 10.9 Stormproof

Provides an alternative route to the city of 

Williams and also serves as part of an 

escape route for the Oregon Caves

National Monument. Also provides access 

to private land inholdings

4612 9.7 Stormproof Provides access to the Red Buttes 

Wilderness and Mining Claims

4613 6.9 Stormproof Provides access to Bigelow Lakes Trail 

Head and private land inholdings

4614 4.5 Stormproof

Provides access to The Oregon Caves 

National Monument trail system and 

Mount Elijah trail

4611-079 3.9 Stormproof Serves as connector for the Oregon 

Caves National Monument Escape route

4611-070 4.3

1.4

Stormproof

Decommission

Serves as connector for the Oregon 

Caves National Monument Escape route 

optional route and access to Bigelow 

Lakes Trail 

4611-960 2.9 Stormproof Serves as connector for the Oregon 

Caves National Monument Escape route 

Continued Decline in Road Maintenance Funding

The existing road system is programmed to receive annual maintenance in accordance with 

established road management objectives. However, congressionally appropriated funds for both 

road and trail maintenance have steadily declined in since 1990 and the Forest no longer has the 

traditional road and trail crew resources. A portion of the maintenance program is funded under 

the Secure Rural Schools and Community Self- Determination Act of 2000 (Public Law 106-

393). Road and trail maintenance funding is a year to year issue. OHV grants are occasionally 

obtained from Oregon State Parks and Recreation Department for maintenance and law 

enforcement purposes on motorized trails. 

In 1990 the national Forest Service maintenance funding was approximately $90 million with 

another approximately $30 million in commercial user maintenance. In 2012 this picture has 

declined to approximately $20 million nationally and approximately $10 million in commercial 

user maintenance. Consequently the amount of deferred road maintenance on the forest continues 

to grow each year. Currently on the Rogue River-Siskiyou NF we have more than 5,200 miles of 

total roads with $111 million in deferred maintenance and $11 million required to maintain the 

5,200 miles to agency standards. For fiscal year 2014 the forest received less than $900,000 total 

road maintenance budget. This is complicated by the fact that structures such as culverts are not 

only aging but are beginning to fail at an alarming rate as many of them are beyond their designed 

life. 

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Environmental Consequences

Effects Mechanisms and Analysis Framework

Effects mechanisms serve as tools to quantify the effects to offer a basis for comparing the effects 

of management practices. This analysis will focus on changes to National Forest System roads

using the following effects mechanisms:

♦ Miles of open road (Maintenance Levels 2 to 5)

♦ Miles of closed road (Maintenance Level 1)

♦ Miles of road decommissioning

♦ Miles of road to convert to trails

The spatial bounds of this analysis is confined to National Forest System roads in the Sucker 

Creek watershed. This has been deemed appropriate because as the Sucker Creek watershed is the 

third highest ranking watershed on the forest. The forest has selected to conduct these types of 

analyses by watershed priorities.

Alternative 1 – No Action

Direct, Indirect, and Cumulative Effects

There are no direct effects of choosing the no-action alternative. However, the indirect and 

cumulative effects of not taking action would continue to add to the backlog of road maintenance 

in the watershed. This backlog of work would increase the risk of road and drainage structures 

failing and depositing huge amounts of sediment into the streams of the watershed. This sediment 

loading would deteriorate the water quality of these associated streams. Continued forest 

direction of no to little road maintenance of these roads would allow these roads to naturally close 

themselves. This means that the roads side brush would continue to close of the roads, surface 

water would continue to erode the surface making them unpassable motorized traffic and plugged 

drainages will wash roadway fills thus eliminating the roadbed.

Alternative 2 – Modified Proposed Action

Direct and Indirect Effects

The direct effect to the transportation system in the Sucker Creek watershed of implementing 

alternative 2 - modified proposed action, would be decommissioning 28 miles of National Forest 

System roads, putting 31 miles of NFS roads into storage, converting 3 miles of NFS road into 

non-motorized trail, and stormproofing 118 miles of NFS road. The estimated cost to implement 

this alternative is approximately $5 million.

The indirect effects would be:

♦ Improved road condition and drivability on 118 miles of road proposed for stormproofing

♦ Limitation of access to 31 miles of road for management and emergency access only on 

roads proposed for closure

♦ Loss of access to 28 miles of roads proposed for decommissioning

♦ Change in access to 3 miles of roads proposed for conversion of road to non-motorized 

trail

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Cumulative Effects

The effects of the Sucker Creek Legacy Roads and Trails Project overlap with the effects of the 

decision for Motorized Vehicle Use on the Rogue River-Siskiyou National Forest Project (Travel 

Management Plan), which implements the November 9, 2005, Final Rule for Travel 

Management; Designated Routes and Areas for Motor Vehicle Use. In implementing this rule, the 

Rogue River-Siskiyou National Forest designated those roads, trails, and areas open to motorized 

vehicles; the class of vehicles and, if appropriate, the times of year for which use is authorized; 

and prohibited motor vehicle use off that designated system (cross-country travel). Following a 

decision on this proposal, the Forest will publish a Motorized Vehicle Use Map (MVUM) 

designating all National Forest System roads, trails, and areas open for motor vehicle use by the 

public on the Forest. This decision and resulting motor vehicle use map is anticipated to occur 

late 2014. This map would designate 151 miles of road, 6 miles of motorized trail, and 25 miles 

of non-motorized trail open to the public in the Sucker Creek watershed. Implementation of the 

Sucker Creek Legacy Roads and Trails Project would change that to 126 miles of road, 6 miles of 

motorized trail, and 28 miles of non-motorized trail open to the public in the watershed. These 

changes would be reflected in updates to the MVUM as the project is implemented. 

Implementation is expected to take approximately 5 years, depending on funding.

Conclusion

In conclusion, this modified proposed action will correct the road deficiencies that exist in the 

Sucker Creek watershed by: 

♦ Replacing failing and undersized culverts, which would greatly reduce the risk of losing 

large roadway fills and portions of roadways.

♦ Correcting roadway surface issues by placing new surfacing, constructing rolling dips 

and drivable water bars, which would drain surface water from the roadway surface thus 

minimizing surface erosion and scour; in turn greatly reducing the need of annual 

maintenance.

♦ Closing and decommissioning roads and removing culverts, thus restoring the drainage.

This will nearly eliminate the surface erosion and create stabilized drainages.

These activities will improve water quality as sediment transportation will thus be negligible.

This will also reduce the annual maintenance costs and reduce the risk level of road failures of the 

watershed.

Mining

Introduction

The discovery of gold was the catalyst for development of the Sucker Creek watershed. There 

were two rushes to Sucker Creek – one in 1853, and one in 1856 – attracting about 2,000 people 

during the height of activity. Mining has been sporadic since that time. One larger-scale operation 

exists on Sucker Creek today; most of the other operations that occur over the estimated 500 

claims are small. The effects of historic, large scale mining on riparian and aquatic habitat remain.

Simple panning was the earliest technique used to mine placer gold in the Sucker Creek area. 

Gold was found the full length of the drainage, but was concentrated between Grayback and 

Bolan creeks. By the late 1850s, large hydraulic operations had developed, employing huge 

numbers of imported laborers, primarily Chinese. This technique allowed miners to wash entire 

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hillsides through their sluice boxes, and accounts for most of the landscape alterations (large 

headwalls and vast tailings piles) visible today. Hydraulic mining tapered off by the early 1880s.

The turn of the century saw a resurgence of mining activities. Various companies arrived from 

outside the area and invested capital in large-scale developments. Lode (or "hard rock" or 

"ledge") mining began to rival placer mining at this time. The Briggs Pocket Mine, near the 

Siskiyou Crest, yielded 2,000 ounces of gold from three shallow pits. The 1930s saw a renewed 

interest in gold mining as individuals or loosely organized small groups of miners tried to make 

ends meet during the hard times of the depression era. Overall, these were small-scale operations. 

During World War II, the mining of non-strategic minerals was halted by the War Productions 

Board. Following the war, costs of labor and supplies had increased so much that mining, for the 

most part, was no longer profitable. 

Affected Environment

Mining continues at present levels. Refined land use practices and restoration emphasis has 

resulted in less riparian disturbance.

Use of water in Sucker Creek also has a long history dating back to the earliest mining days when 

water was needed to operate hydraulic systems (little giant - monitors). Competition among 

miners and soon thereafter with ranchers downstream was only the beginning of what has become 

a major issue in the watershed. Today, existing water supplies remain inadequate to satisfy all the 

users within the watershed.

Local knowledge and written history indicate that Cave Creek had little or no mining. However, 

renewed mining activity along Sucker Creek (Throop and Smith, 1986) includes settling ponds at 

the mouth of Cave Creek that have been pumped and rechanneled. Starting in 2007 this area was 

mined again by the Carlon’s through 2011 leaving several large settling ponds filled with water. 

Today, two kinds of mining continue within the Grayback/Sucker Watershed, placer and lode 

mining. Most of the mining on Forest Service lands occurs along Sucker Creek. The lands and 

mineral specialist with the FS estimated that there were about 200 to 500 claims (most of them 

placer claims) along Sucker Creek. The values of these claims have been recorded as among the

most valuable in southwestern Oregon.

Effects for Mining Access

Effects for mining are based on access to mining claims. Miner need to have reasonable access to 

their mining claims. This could be for vehicles, ATVs or foot travel. The modified proposed 

action generated comments from miners that roads needed for access to claims were proposed for 

decommissioning. The miners were contacted to find out the type of access they needed. The 

roads were re-evaluated by the IDT to determine the risk of sediment delivery to the aquatic 

ecosystem. If there was a low risk of sediment delivery, no road stream crossings, the road 

treatment was changed from decommissioning to stormproofing, knowing that road would remain 

stable with little or no road maintenance. If there were stream crossings that created a risk of 

sediment delivery, then the road was changed from decommissioning to storage where the stream 

crossing would be removed leaving a trail for foot access to the mining claims.

♦ Modify NFS Road 4612-058 from decommissioning to stormproofing – This road was 

initially proposed for road decommissioning to reduce road density for wildlife benefits; 

this road does not have the issue with sediment delivery to streams. During scoping

several commenters noted that this road accesses several mining claims, one that has an 

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environmental assessment nearly completed and a second claim that has a plan of 

operations that has been submitted to the Forest Service. Therefore, this road was 

modified to stormproofing to maintain access to these mining claims.

♦ Modify a portion of NFS Road 4612-069 from decommissioning to stormproofing –

This road was proposed for road decommissioning to reduce sediment delivery to streams 

in the area; there are several culverts on the road that are problematic. Several 

commenters brought forward the information that the road is used by miners, hikers, and 

hunters. The first 0.25 miles in particular is used to park cars and for camping. Therefore, 

alternative 2 was modified to stormproof the first 0.25 miles of the road (to Sucker 

Creek), and then decommission the remainder of the road; the first 0.25 miles of National 

Forest System Road 4612-069 does not have issues with sediment delivery to nearby 

streams.

♦ Modify NFS Road 4703-440 from decommissioning to storage – This road segment 

was initially proposed for decommissioning to reduce sediment delivery to streams and to 

reduce road density for wildlife. During scoping a commenter brought up a concern that 

this road is used to access several mining claims and for recreation by hunters. Therefore, 

this road segment was modified from decommissioning to storage to maintain access to 

this area.

♦ Modify NFS Road 4703-458 decommissioning to stormproofing – This road was 

initially proposed for road decommissioning to reduce road density for wildlife; this road 

does not have the issue with sediment delivery to streams. During scoping a commenter 

brought up a concern that this road is used to access several mining claims. Therefore, 

this road segment was modified to stormproofing to maintain access to these mining 

claims.

Compliance with Other Laws, Regulations, and Executive 

Orders

This section deals with those effects for which disclosure is required by NEPA regulations, Forest 

Service policy or regulation, various executive orders, or other laws and direction covering 

environmental analysis and documentation. In many cases, the information found here is also 

located elsewhere in this document. In other cases, the effects are not necessarily connected to 

any particular resource area.

Clean Air Act

The alternatives are designed to meet the National Ambient Air Quality Standards through 

avoidance of practices that degrade air quality below health and visibility standards. The project 

is consistent with the 1990 Clean Air Act and the 1977 Clean Air Act and its amendments.

The Clean Water Act

This act establishes a non-degradation policy for all federally proposed projects. Compliance with 

the Clean Water Act would be accomplished through planning, application, and monitoring best 

management practices (BMPs). Based on the analysis presented in this EA, TMDL requirements 

would be met in each alternative.

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Executive Orders 

Floodplains and Wetlands

Executive Order 11988 requires government agencies to take actions that reduce the risk of loss 

due to floods, to minimize the impact of floods on human health and welfare, and to restore and 

preserve the natural and beneficial values served by floodplains. 

Executive Order 11990 requires government agencies to take actions that minimize the 

destruction, loss, or degradation of wetlands. There are no wetlands associated with Executive 

Order 11990 that exist within the project area. If any wetlands were to be located during project 

activities, appropriate buffers would be provided in compliance with the ACS of the Northwest 

Forest Plan.

Migratory Birds 

Executive Order 13186 –A Memorandum of Understanding was signed between the USFS and 

USFWS to complement the January 2001, Executive Order. There are several bird species 

recognized as neo-tropical migrants on the Rogue River-Siskiyou National Forest. 

Facilitation of Hunting Heritage and Wildlife Conservation 

Executive Order 13443 –August 17, 2007, Executive Order requires Federal agencies “to 

facilitate the expansion and enhancement of hunting opportunities and the management of game 

species and their habitat.” 

Energy Requirements and Conservation Potential

Some form of energy would be necessary for projects using mechanized equipment. Project 

activities would involve both heavy and small machines, which would result in minor energy 

consumption.

Environmental Justice and Civil Rights

Environmental Justice – Executive Order 12898, “Federal Actions to Address Environmental 

Justice in Minority Populations and Low Income Populations,” directs federal agencies to 

integrate environmental justice considerations into federal programs and activities. Environmental 

justice means that, to the greatest extent practical and permitted by law, all populations are 

provided the opportunity to comment before decisions are rendered or are allowed to share in the 

benefits of, are not excluded from, and are not affected in a disproportionately high and adverse 

manner by government programs and activities affecting human health or the environment.

One goal of Executive Order 12898 is to provide, to the greatest extent practicable, the 

opportunity for minority and low-income populations to participate in planning, analysis, and 

decision-making that affects their health or environment, including identification of program 

needs and designs. This public involvement process for the Sucker Creek Legacy Roads and 

Trails Project has been conducted under Departmental regulation 5600-2, December 15, 1997, 

including the Environmental Justice Flowchart (Appendix E of the regulation). The project, its 

purpose and need, and area of potential effect have been clearly defined.

There would be no adverse effects to human health and no alternative has been determined to 

disproportionately affect minority or low income populations. The alternatives do not appear to 

have a disproportionately high or adverse effect on minority or low-income populations. Scoping 

did not reveal any issues or concerns associated with the principles of environmental justice. No 

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

mitigation measures to offset or ameliorate adverse effects to these populations have been 

identified. All interested and affected parties will continue to be involved with the public 

involvement and decision process.

United States Department of Agriculture (USDA) Civil Rights Policy – The Civil Rights 

Policy for the USDA, Departmental Regulation 4300-4 dated May 30, 2003, states that the 

following are among the civil rights strategic goals: (1) managers, supervisors, and other 

employees are held accountable for ensuring that USDA customers are treated fairly and 

equitably, with dignity and respect; and (2) equal access is assured and equal treatment is 

provided in the delivery of USDA programs and services for all customers. This is the standard 

for service to all customers regardless of race, sex, national origin, age, or disabilities.

Disparate impact, a theory of discrimination, has been applied to the Sucker Creek Legacy Roads 

and Trails Project’s planning process in order to reveal any such negative effects that may 

unfairly and inequitably impact beneficiaries regarding program development, administration, 

and delivery. The objectives of this review and analysis are to prevent disparate treatment and 

minimize discrimination against minorities, women and persons with disabilities and to ensure 

compliance with all civil rights statutes, Federal regulations, and USDA policies and procedures.

Persons with Disabilities – Under section 504 of the Rehabilitation Act of 1973, no person with a 

disability can be denied participation in a Federal program that is available to all other people 

solely because of his or her disability. No groups or classes or persons were found to be 

disproportionately negatively affected by this project. This project would apply equally to all 

members of the public, and therefore is not discriminatory to any person or group.

In the 2010 American Community Survey, people were defined as having a disability if they 

responded “yes” to a sensory, physical, cognitive, self-care, go-outside-home, or employment 

disability. Children under 5 years of age were only included in the hearing and vision questions.

The Sucker Creek Legacy Roads and Trails project area is located within Josephine County and 

according to the U.S. Census Bureau, 2010 American Community Survey percentage of the 

population with disabilities in the county is 14.3 percent. For comparison, the rate for all of 

Oregon is 13.8 percent and the rate for the nation is 11.9 percent. The total population affected by 

a disability for each geographic extent was tallied for the civilian non-institutionalized 

population.

Determination that a Civil Rights Impact Analysis (CRIA) is not needed – The scoping process 

was initiated in the Grants Pass Daily Courier on October 1, 2013. The District received 15

emails and letters during the public scoping period. The interdisciplinary team analyzed these 

emails and letters using an established analytical process known as content analysis. Comments

are made by those who are interested in specific issues, favor an alternative, have concerns over 

the plan or analysis, or other concerns. People self-select to participate and are not required to 

provide any information concerning individual demographic information. Based on public 

comment, there were no issues raised that would suggest, or from which one may infer, that 

implementation of the Sucker Creek Legacy Roads and Trails Project would affect groups or 

classes of persons, negatively, because of one or more prohibited bases.

Short-term Uses and Long-term Productivity

Maintaining long-term site productivity is the basis for the ecosystem being able to meet the 

needs of the land and people through time. The maintenance of productivity is required through 

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legislation: the Organic Act of 1897, the Multiple Use Sustained Yield Act of 1960, the National 

Environmental Policy Act of 1969, and the National Forest Management Act of 1976.

Long-term productivity and sustainability is the inherent potential of the land (ecosystem) to 

produce a certain level of vegetation and associated processes, such as wildlife, water, and clean 

air, indefinitely into the future.

Fixed components influencing productivity include local climate, topographic features, and soil 

type. Components affecting productivity that can be changed include: soil volume, porosity, water 

availability, chemistry, and biology. Factors that can affect these components include: compaction 

and soil displacement from timber harvest and fuels treatment activities; loss of soil organic 

matter; modification of the water table or moisture-holding capacity; and reductions in the 

functioning of soil organisms from compaction or displacement.

Unavoidable Adverse Effects

Implementation of any action alternative would result in some adverse environmental effects that 

cannot be avoided. For example, disturbance and removal of vegetation and soil would have some 

adverse effects on sediment delivery. However, the magnitude of these effects relative to the 

proposed project would be small and within prescribed standards and guidelines of the Siskiyou 

LRMP and the Northwest Forest Plan. The degree of adverse effects is substantially reduced by 

following both plans’ standards and guidelines, and by including the mitigation measures and 

design criteria outlined in chapter II. See the issues discussed earlier in this chapter, by resource 

area, for more information.

Irreversible and Irretrievable Effects

Irreversible commitment of resources refers to a loss of future options with nonrenewable 

resources. An Irretrievable commitment of resources refers to loss of opportunity due to a 

particular choice of resource uses.

The soil and water protection measures identified in the Siskiyou Forest Plan Standards and 

Guidelines, water quality BMPs, and mitigation measures and design criteria listed in chapter II 

of this document, are designed to avoid or minimize the potential for irreversible losses from the 

proposed management actions.

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Chapter IV. Coordination 

Interdisciplinary Team Members

A variety of specialists and managers from the Rogue River-Siskiyou National Forest contributed 

information for this project. 

Matt Paciorek ~ Wild Rivers District Ranger

Chris Park ~ Team Lead/Forest Hydrologist 

Jamie Krezelok ~ Hydrologist

Sasha Fertig/Shannon Downey ~ Environmental Coordinator

Joni Brazier ~ Soil Scientist

Steve Anderson ~ Fire and Fuels Specialist

Rob Barnhart ~ Silviculturist

Stuart Osbrack ~ Botanist

Bonnie Allison ~ Wildlife Biologist

Karla Cottom ~ Fisheries Biologist

Scott Blower ~ Road Development Engineer 

Dave Knutson ~ Archaeological Technician

Brian Long ~ Recreation Specialist

Robert Shoemaker ~ Forest Minerals Administrator

Mark Hocken ~ Range Specialist

Gary Einck ~ Realty Specialist

Janice Schultz ~ Writer/Editor, TEAMS Enterprise Unit

Agencies and Persons Consulted 

The Forest Service consulted the following individuals, Federal, State, tribal, and local agencies 

during the development of this environmental assessment: 

Federal, State, and Local Agencies

Army Corps of Engineers, Federal Highways Administration – Oregon Division, Josephine 

County Commissioners, Josephine County Forestry, Josephine County Planning Department, 

Josephine County Sheriff’s Office, Klamath National Forest, Medford Bureau of Land 

Management, Oregon Caves National Monument, Oregon Department of Environmental Quality, 

Oregon Department of Fish and Wildlife, Oregon Natural Resources Office

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Tribes 

Confederated Tribes of the Grand Ronde Community of Oregon, Confederated Tribes of the 

Siletz Indians of Oregon 

Others

American Bird Conservancy, American Forest Resource Council, American Hiking Society, 

American Indian Cultural Center, Big Wildlife, Blue Ribbon Coalition, Capital Trail Vehicle 

Association, Cascadia Wildlands Project, Central Oregon Motorcycle & ATV Club, Deschutes 

County 4-Wheelers, Emerald Trail Riders Association, Friends of the Kalmiopsis, Illinois River

Watershed Council, Josephine County Library, Kalmiopsis Audubon Society, Klamath Siskiyou 

Wildlands Center, Motorcycle Riders Association, OHV Allocations, Oregon Hunter’s 

Association, Oregon Motorcycle Riders Association, Oregon Wild, Pacific Crest Trail

Association, Pacific Northwest 4-Wheel Drive Association, Recreation Outdoors Coalition, 

Rogue Group Sierra Club, Rogue Riverkeeper, Siskiyou Audubon Society, Siskiyou Project,

Southwest Oregon Mining Association, The Nature Conservancy, The Wilderness Society, Waldo 

Mining District, Western Environmental Law Center, Wildlands CPR, and other interested

citizens

184

Opportunity to Object under 36 CFR 218

This project is subject to the objection process specified in 36 CFR §218, subparts A and B. 

Individuals, organizations, or tribal entities who submit specific written comments during the 

scoping period, the comment period following release of the environmental assessment, or any 

other period during which the responsible official seeks written comment are eligible to file an 

objection. The objection process provides an opportunity to have unresolved concerns receive 

independent review by the Forest Service prior to a final decision being made by the responsible 

official.

Specific written comments should be within the scope of the proposed action, have a direct 

relationship to the proposed action, and must include supporting reasons for the responsible 

official to consider. Comments must include your name, postal address, the title of the proposed 

project, and your signature or other verification of identity. Comments must be submitted 

(received or postmarked) within 30 days after the publication of the legal notice of opportunity to 

comment. Paragraphs (a)(3) and (a)(4) of §218.25 provide additional information on the required 

content and submission of comments to establish standing to object to a draft decision.
Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

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Glossary

Even aged Management ~ “...a stand in which essentially all trees have been removed in one 

operation —note depending on management objectives, a clearcut may or may not have reserve 

trees left to attain goals other than regeneration” (Beaufait et. al. 1984).

Seed Tree Harvest ~ “...the cutting of all trees except for a small number of widely dispersed 

trees retained for seed production and to produce a new age class in fully exposed 

microenvironment —note seed trees are usually removed after regeneration is established” 

(Beaufait et. al. 1984).

Shelterwood Harvest ~ “...the cutting of most trees, leaving those needed to produce sufficient 

shade to produce a new age class in a moderated microenvironment —note the sequence of 

treatments can include three types of cuttings: (a) an optional preparatory cut to enhance 

conditions for seed production, (b) an establishment cut to prepare the seed bed and to create a 

new age class, and (c) a removal cut to release established regeneration from competition with the 

overwood; cutting may be done uniformly throughout the stand (uniform shelterwood), in groups 

or patches (group shelterwood), or in strips (strip shelterwood); in a strip shelterwood, 

regeneration cuttings may progress against the prevailing wind” (Beaufait et. al. 1984).

Decommission ~ Roads are not needed for 20 years or more and or maybe accessed by other road 

networks not decommissioned by the modified proposed action. 

Storage ~ Roads are not needed within the next 10 years or more due to previous treatments and 

or slow growing site conditions.

Storm Proofing ~ Roads are needed for treatment of managed stands within the next five years 

and or managed stand exist on a backbone road network that has multiple uses.

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Appendices

Appendix A – Compliance with Aquatic Conservation 

Strategy

An integral part of the Northwest Forest Plan is the Aquatic Conservation Strategy (ACS). The 

ACS is intended to maintain and restore the ecological health of the watersheds and ecosystems 

within the Northwest Forest Plan area. On March 30, 2007, the District Court, Western District of 

Washington, ruled adverse to the US Fish and Wildlife Service (USFWS), National Oceanic and 

Atmospheric Administration (NOAA-Fisheries) and USFS and BLM (Agencies) in Pacific Coast 

Fed. of Fishermen’s Assn. et al. v. Natl. Marine Fisheries Service, et al. and American Forest 

Resource Council, Civ. No. 04-1299RSM (W.D. Wash)( (PCFFA IV). Based on violations of the 

Endangered Species Act (ESA) and the National Environmental Policy Act (NEPA), the Court set 

aside the USFWS Biological Opinion (March 18, 2004), the NOAA-Fisheries Biological Opinion 

for the ACS Amendment (March 19, 2004), the ACS Amendment Final Supplemental 

Environmental Impact Statement (FSEIS) (October 2003), and the ACS Amendment adopted by 

the Record of Decision dated March 22, 2004. 

As a result of PCFFA IV, the Forest Service must now assess project consistency with the nine 

ACS objectives as was done prior to the 2004 Record of Decision for the ACS amendment. New 

project NEPA decisions must be consistent with the wording regarding ACS consistency, 

including consistency with the nine ACS objectives, as ACS consistency is described in the 1994 

NWFP ROD on page B-10. In making the ACS consistency finding and to be guided by PCFFA 

IV, the decision maker must: 

♦ Review projects against the ACS objectives at the project or site scale, rather than only at 

the watershed scale. This review can be accomplished through cumulative effects 

analyses (e.g., by evaluating the incremental effect of the project added to the existing 

condition, and the effects of other present and reasonably foreseeable future actions) on 

watershed conditions. 

♦ Evaluate the immediate (short-term) impacts, as well as long-term impacts of an action.

♦ Provide a description of the existing watershed condition, including the important 

physical and biological components of the 5th field watershed. 

♦ Provide written evidence that the decision maker considered relevant findings of 

watershed analysis.

The Northwest Forest Plan requires consistency with ACS with specific reference to nine ACS 

Objectives. Below, is a summation of the environmental analysis regarding consistency with the 

elements and components of the Objectives. Specific rationale may be found in other analysis 

documented under other resources, e.g., Soils, Fisheries, Wildlife, Botany.

Aquatic Conservation Strategy Objectives

This section focuses on the attainment of the nine Aquatic Conservation Strategy Objectives of 

the alternatives considered in detail, the response to the specific Standards and Guidelines 

associated with Riparian Reserves (NWFP C-33 & 34), and the attainment of Standards and 

Guidelines associated with Key Watersheds (NWFP B-19).

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Complying with the Aquatic Conservation Strategy objectives means that an agency must manage 

the riparian-dependent resources to maintain the existing condition or implement actions to 

restore conditions. The baseline from which to assess maintaining or restoring the condition is 

developed through a Watershed Analysis. Improvement relates to restoring biological and 

physical processes within their ranges of natural variability. 

The Standards and Guidelines are designed to focus the review of proposed and certain existing 

projects to determine compatibility with the Aquatic Conservation Strategy objectives. The 

Standards and Guidelines focus on "meeting" and "not preventing attainment" of Aquatic 

Conservation Strategy objectives. The intent is to ensure that a decision maker must find that the 

proposed management activity is consistent with the Aquatic Conservation Strategy objectives. 

The decision maker will use the results of watershed analysis to support the finding. 

In order to make the finding that a project or management action "meets" or "does not prevent 

attainment" of the Aquatic Conservation Strategy objectives, the analysis must include a 

description of the existing condition, a description of the range of natural variability of the 

important physical and biological components of a given watershed, and how the proposed 

project or management action maintains the existing condition or moves it within the range of 

natural variability. 

The Northwest Forest Plan requires consistency with ACS with specific reference to nine ACS 

Objectives. Below is a summation of the environmental analysis regarding consistency with the 

elements and components of the objectives. 

ACS Objective 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.

Alternative 1 would result in failures of unmaintained road stream crossings and road ditch 

drains. There are approximately 480 stream crossings within the Sucker Creek watershed, none of 

which would be removed. Culverts with a high plug potential would be likely to fail during large 

storm events, causing large inputs of sediment to the stream system impacting water quality and 

stream health. With no treatments on any roads the potential sediment yield during a storm event 

would be approximately 245,000 cubic yards (Weppner and Weaver 2010, 2013). Future 

sediment delivery from the failure of these sites during storm events will not ensure protection of 

the aquatic system. This alternative does not meet the objective. 

Alternative 2 would remove over 100 culverts reducing sediment delivery by approximately 

150,000 cubic yards, or 70 percent. A reduction in sediment input would ensure protection of instream habitat and improve water quality. There would be reduction in the extended channel 

network currently associated with the road system, which would improve hillslope hydrology and 

dispersed subsurface flow. This would reduce the future risk of sediment delivery and ensure the 

protection of the aquatic system.

ACS Objective 2. Maintain and restore spatial and temporal connectivity within and between 

watersheds. Lateral, longitudinal, and drainage network connections include floodplains, 

wetlands, upslope areas, headwater tributaries, and intact refugia. These network connections 

must provide chemically and physically unobstructed routes to areas critical for fulfilling life 

history requirements of aquatic and riparian-dependent species.

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All of the alternatives would maintain the current condition since there are no new developments 

proposed. Under Alternative 2 approximately 31.4 miles of road would be decommissioned and 

over 100 culverts would be removed, which would improve the spatial and temporal connectivity 

within the stream systems. 

ACS Objective 3. Maintain and restore the physical integrity of the aquatic system, including 

shorelines, banks, and bottom configurations.

Alternative 1 would result in failures of unmaintained road stream crossings and road ditch 

drains. Future sediment delivery of approximately 245,000 cubic yards could occur during storm 

events, which would increase pool filling and stream widening and instability. This would impact 

the physical integrity of the aquatic system. This alternative does not meet the objective.

Alternative 2 would reduce future sediment delivery from roads to streams by approximately 

150,000 cubic yards reducing the risk of pool filling and stream widening and instability. This 

would improve the physical integrity of the aquatic system.

ACS Objective 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.

Alternative 1 would result in failures of unmaintained road stream crossings and road ditch 

drains. Future delivery of approximately 245,000 cubic yards of sediment from the failure of 

these sites during storm events would not ensure protection of the aquatic system. This could 

impact water quality, specifically turbidity and sedimentation. This alternative does not meet the 

objective.

Alternative 2 would reduce future sediment delivery to streams reducing turbidity during storm 

events and decreasing sediment input to the stream channel. This would improve sediment 

transport and protect spawning gravels and pool habitat improving water quality. 

ACS Objective 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.

Alternative 1 would result in failures of unmaintained road stream crossings and road ditch drains 

of approximately 245,000 cubic yards. These high sediment inputs have impacted the stream 

system through filling of spawning gravels and pools, which would continue. This alternative 

does not meet the objective.

Alternative 2 would reduce potential sediment yield from roads by approximately 150,000 cubic 

yards improving sediment transport throughout the stream system. This would reduce pool filling, 

stream widening, channel instability, and erosion.

ACS Objective 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. The timing, magnitude, duration, and spatial distribution of peak, high, and low flows 

must be protected.

None of the alternatives would have a measurable effect on stream flow.

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ACS Objective 7. Maintain and restore the timing, variability, and duration of floodplain 

inundation and water table elevation in meadows and wetlands.

All of the alternatives would maintain the current condition.

ACS Objective 8. Maintain and restore the species composition and structural diversity of plant 

communities in Riparian Reserves 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.

Alternative 1 would maintain the current condition.

Alternative 2 would slightly improve riparian condition by decommissioning roads within 

riparian reserves allowing for revegetation with riparian plants along approximately 9 miles of 

road. 

ACS Objective 9. Maintain and restore habitat to support well-distributed populations of native 

plant, invertebrate, and vertebrate riparian-dependent species.

All of the alternatives would maintain the current condition.

Alternative 1 does not meet the Aquatic Conservation Strategy

Alternative 2 meets the Aquatic Conservation Strategy

Summary

This analysis indicates that alternative 1 would not be in compliance with the ACS listed in the 

Northwest Forest Plan. It would result in failures of unmaintained stream crossings. There are 

approximately 480 stream crossings within the Sucker Creek watershed, none of which would be 

removed; however, some of the high risk culverts on level 3 roads could be replaced during 

routine road maintenance. Culverts with a high plug potential would be likely to fail during large 

storm events, causing large inputs of sediment to the stream system impacting water quality and 

stream health. With no treatments on any roads the potential sediment yield during a storm event 

would be approximately 245,000 cubic yards (Weppner and Weaver 2010, 2013). Normal road 

maintenance could still occur under this alternative. This would reduce sediment yield by

approximately 63,000 cubic yards, if done on all level 3 roads throughout the watershed. 

The condition class of the watersheds would not improve in the priority watersheds and could be 

further degraded. The improvements made with the stream restoration projects could be impacted 

by filling pools with sediment and covering spawning gravels, reducing their effectiveness. Road 

density would remain at 2.5 miles per square mile and percent of stream within 300 feet of a 

perennial stream would remain at 38 percent, both of which result in functioning at risk ratings 

for these attributes (USDA Forest Service 2010). 

Alternative 2 would be in compliance with the ACS and would reduce sediment input to the 

stream system by approximately 150,000 cubic yards, or 70 percent. Over 100 culverts would be 

removed with 90 of these being on road-stream crossings. Approximately 31.4 miles of road 

would be decommissioned reducing density from 2.5 to 2.1, which is a small reduction but does 

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move that attribute to an improved condition within the Watershed Conservation Framework 

(USDA 2010). Percent of road within 300 feet of perennial streams would remain high at 33 

percent; however, by removing the high risk culverts and stormproofing roads, there would be a 

lesser impact on sediment input to the stream system from these roads. A reduction in sediment 

input would ensure protection of in-stream habitat and improve water quality. There would be 

reduction in the extended channel network currently associated with the road system, which 

would improve hillslope hydrology and dispersed subsurface flow. Essential projects discussed in 

the WRAP associated with road restoration would be completed on top of those already 

completed during the stream restoration projects (USDA 2011). This would move subwatersheds 

that are currently functioning at risk toward, and may attain, proper functioning condition.

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Appendix B – Applicable Best Management Practices

Best Management Practices (BMPs) are developed to comply with Section 208 of the Clean 

Water Act. BMPs have been certified by the State Water Quality Resources Control Board and 

approved by the Environmental Protection Agency (EPA) as the most effective way of protecting 

water quality from impacts stemming from non-point sources of pollution. 

Forest Service National Best management Practices for Water Quality Management on National 

Forest System Lands, Volume 1 National Core BMP Technical Guide (BMPs, USDA Forest 

Service 2012) and the Region 6 General Water Quality Best Management Practices (USDA Forest 

Service, 1988) applicable to road and trail management would be implemented under the action 

alternative for the Sucker Creek Legacy Roads and Trails Project. These are identified here and 

are an integral part of implementation. 

These practices have been applied in timber sales and road construction projects in watersheds 

over the last 20 years and have been found to be effective in protecting water quality within the 

Rogue River-Siskiyou National Forest. Specifically, effective application of the USDA Forest 

Service Region 6 BMPs has been found to maintain water quality that is in conformance with the 

Water Quality Objectives in the Rogue Basin Plan. USDA Forest Service Region 6 BMPs have 

been monitored and modified since their original implementation in 1979 to make them more 

effective. Numerous on-site monitoring has found the practices to be effective in maintaining 

water quality and protecting beneficial uses/resources (e.g., domestic use, anadromous and 

resident fish). 

The following BMPs were selected for the Sucker Creek Legacy Roads and Trails Project. Sitespecific design criteria to implement these BMPs would be refined during the course of project 

and contract planning and operations. Design criteria included in the proposed action are 

described in chapter 2.

National BMPs

Plan-2. Project Planning and Analysis

Plan-3. Aquatic Management Zone Planning

AqEco-1. Aquatic Ecosystem Improvement and Restoration Planning

AqEco-2. Operations in Aquatic Ecosystems

Fac-2. Facility Construction and Stormwater Control

Fac-10. Facility Site Reclamation

Rec-4. Motorized and Non-motorized Trails

Road-1. Travel Management Planning and Analysis

Road-3. Road Construction and Reconstruction

Road-4. Road Operations and Maintenance

Road-6. Road Storage and Decommissioning

Road-7. Stream Crossings

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Road-9. Parking and Storage Areas

Road-10. Equipment Refueling and Servicing

Region 6 BMPs

R-2. Erosion Control Plan

R-3. Timing of Construction Activities

R-5. Road Slope and Waste Area Stabilization (preventative)

R-6. Dispersion of Subsurface Drainage Associated with Roads

R-7. Control of Surface Road Drainage Associated with Roads

R-9. Timely Erosion Control Measures on Incomplete Roads and Stream Crossing 

Projects

R-12. Control of Construction in Streamside Management Units

R-13. Diversion of Flows Around Construction Sites

R-14. Bridge and Culvert Installation and Protection of Fisheries

R-15. Disposal of Right-of-Way and Roadside Debris

R-16. Specifying Rip-Rap Composition

R-17. Water Source Development Consistent with Water Quality Protection

R-18. Maintenance of Roads

R-19. Road Surface Treatment to Prevent Loss of Materials

W-1. Watershed Restoration

W-4. Oil and Hazardous Substance Spill Contingency Plan and Spill Prevention 

Control and Countermeasure Plan

W-5. Cumulative Watershed Effects

W-7. Water Quality Monitoring

W-8. Management by Closure to Use (Seasonal, Temporary, and Permanent)

W-9. Surface Erosion Control at Facility Sites

VM-3. Revegetation of Surface Disturbed Areas

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Appendix C – Revegetation Plan

The proposed project area is vulnerable to both erosion and the establishment and spread of 

invasive plant infestations. Disturbed areas would be re-vegetated to prevent the establishment or 

spread of invasive plants and noxious weeds. Disturbed areas would also be re-vegetated for bank 

stabilization and erosion prevention. The following areas may be re-vegetated dependent on the 

requirement and need of each individual site influenced by the activity that would occur at these

sites.

♦ Culvert removal or replacements areas

♦ Areas with vegetation removal and canopy loss

♦ Decommissioned roads

♦ Roads placed into storage 

♦ Staging areas

♦ Disturbed areas from project implementation

♦ Areas needing erosion control

Project implementation schedule must be communicated to District Botanist, District 

Silviculturist, and Forest Soil Scientist well in advance to facilitate rehabilitation and revegetation of sites. Adequate advance would have to allow enough time (one year minimum 

notice) to grow plants and/or purchase native plant materials from disease and weed free 

nurseries.

Revegetation Species Lists

All revegetation species would be native and be appropriate for the habitat type and elevation. 

Table C- 1. Some appropriate revegetation species 

Plant Species Comments

Chamaecyparis lawsoniana (Port Orford Cedar) Must be disease resistant stock and proper 

elevation band

Alnus rubra (Red alder) Riparian species proper elevation band

Populus balsamifera ssp. trichocarpa (black 

cottonwood)

Riparian species proper elevation band

Fraxinus latifolia (Oregon ash) Riparian species proper elevation band

Pinus lambertiana (sugar pine) 

Must be rust resistant stock

Upland species proper elevation band

Thuja plicata (western red cedar) Riparian high elevation band

Abies magnifica (red fir) Upland high elevation band

Acer macrophyllum (bigleaf maple) Riparian species proper elevation band

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Plant Species Comments

Cornus sericea ssp. sericea (American dogwood) Riparian species proper elevation band

Acer circinatum (vine maple) Riparian species proper elevation band

Holodiscus discolor (ocean spray) Upland species proper elevation band

Rhamnus californica (coffeeberry) Upland species proper elevation band

Additional tree and shrub species Species appropriate for site location plant 

community, habitat, and elevation

Native forb species Species appropriate for site location plant 

community, habitat, and elevation

Native grass seed Species appropriate for site location plant 

community, habitat, and elevation

Revegetation Timing

Disturbed areas would be re-vegetated dependent on implementation timing. Factors for optimum 

results for successful survivability would be contingent on life form, species specific, and 

elevation bands. Revegetation would be could potentially be phased due to completion of 

implementation operations. 

The first phase would include erosion control and invasive plant mitigations for establishment 

and spread of infestations. This phase would include planting of native grasses in disturbed areas 

and for slopes greater than 45% areas may be mulched with weed free straw or mulch. 

Phase two would include planting trees, shrubs, and forbs. Phase two timing would conditional on 

growing season elevation bands.

Examples are: Disturbed sites with a July implementation completion would be planted with 

native grass seed (and possibly mulching) for preventing impacts during the initial period. The 

following spring Trees, shrubs, and forbs would be planted during the optimal establishment 

conditions.

Revegetation Sites

Revegetation would require site-specific reconnaissance for stand typing to ensure the proper 

species mixture would be selected for the site. Site visits would also assess timing and planting 

conditions.

For culvert removal and replacement; roads that would be decommissioned; roads to be put into 

storage; and other disturbed sites the following general re-vegetation guidelines would be 

followed. 

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Table C- 2. Revegetation site types and criteria

Revegetation Site Type Comments and criteria

♦ Culverts replacement and removal areas

would be re-vegetated with the riparian 

native tree, shrub, forb, or grass species 

listed.

♦ Resistant Port Orford Cedar would be 

used at least 25 feet above the stream 

and 25 between seedlings to prevent 

spores migrating with water into their 

root system.(approx.. 70 trees/acre) 

♦ Other riparian tree and shrub species 

can be planted in disturbed areas and 

to the stream channel

♦ Tree and shrubs will be planted in all 

disturbed areas to minimize soil 

erosion into stream channel and 

provide bank stability. Grass and forbs 

could be utilized for appropriate site 

needs

♦ Decommissioned roads would be 

seeded with the appropriate native grass 

seeds and/or trees and shrubs

♦ The first 100 feet or wherever this is 

ripping and re-contouring would be 

seeded with native grass seed 

♦ Areas with slopes over 45 percent may 

be seeded with native grass seed and 

mulched with weed free mulch and/or 

planted with the appropriate trees, 

shrubs, or herbs for the habitat.

♦ If road is ripped and re-contoured 

♦ Staging areas or other disturbed areas, 

and roadbeds going into storage with 

erosion concerns

♦ Would be planted with the appropriate 

tree, shrub, herb, or grass species 

dependent on habitat, soils, elevation, 

and disturbance area.

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POC Planting Instructions

• Plant resistant 

stock POC in their 

respective 

planting zones. 

Follow the 

breeding zone 

map for stock 

placement. 

• Plant resistant 

stock only in uninfested sites 

where POC 

normally occurs.

• Space POC 

seedlings 25 feet 

from water 

sources and 25 

foot spacing. See 

below figure for 

example of 

planting in 

riparian zone.

Figure C- 1. POC planting location diagram for culvert removal locations

Stream course

Stream Channel 

Zone (25 ft.) Do not

plant POC in this 

zone

Plant POC at 

a 25’ spacing 

in this area

Culvert removal 

locations

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Appendix D – Applicable Fish Passage Restoration Criteria

The following criteria, applicable to the Sucker Creek Legacy Roads and Trails project activities, 

are required under the Endangered Species Act- Section 7 Programmatic Consultation Biological 

Opinion and Magnuson-Stevens Fishery Conservation and Management Act Essential fish 

Habitat consultation. Fish Habitat Restoration Activities in Oregon and Washington, 2013 (ARBO 

II).

Fish Passage Restoration includes the following: total removal of culverts or bridges, or 

replacing culverts or bridges with properly sized culverts and bridges, replacing a damaged culvert

or bridge, and resetting an existing culvert that was improperly installed or damaged; stabilizing

and providing passage over headcuts; removing, constructing (including relocations), repairing, or

maintaining fish ladders; and constructing or replacing fish screens for irrigation diversions. Such

projects will take place where fish passage has been partially or completely eliminated through

road construction, stream degradation, creation of small dams and weirs, and irrigation diversions.

Equipment such as excavators, bull dozers, dump trucks, front-end loaders, and similar equipment

may be used to implement projects.

Stream Simulation Culvert and Bridge Projects – All road-stream crossing structures shall

simulate stream channel conditions per Stream Simulation: An Ecological Approach to Providing 

Passage for Aquatic Organisms at Road- Stream Crossings (USDA-Forest Service 2008), located

at: http://stream.fs.fed.us/fishxing/aop_pdfs.html

i. Culvert criteria – Within the considerations of stream simulation, the structure shall, at a

minimum, accommodate a bankfull wide channel plus constructed banks to provide for

passage of all life stages of native fish species (for more information, reference Chapter 6,

page 35 of the USFS Stream Simulation Guide). The following crossing-width guidance

applies to specific ranges of entrenchment ratios as defined by Rosgen (1996):

1. Non-entrenched Streams: If a stream is not fully entrenched (entrenchment ratio of

greater than 1.4), the minimum culvert width shall be at least 1.3 times the bankfull

channel width. This is consistent with Anadromous Salmonid Passage Facility

Design (section 7.4.2 “Stream Simulation Design”) (NMFS 2011). However, if the

appropriate structure width is determined to be less than 1.3 times the bankfull

channel width, processes for variances are listed in “iv” and “v” below.

2. Entrenched Streams: If a stream is entrenched (entrenchment ratio of less than 1.4),

the culvert width must be greater than bankfull channel width, allow sufficient

vertical clearance to allow ease of construction and maintenance activities, and

provide adequate room for the construction of natural channel banks. Consideration

should be given to accommodate the floodprone width. Floodprone width is the

width measured at twice the maximum bankfull depth (Rosgen 1996).

ii. Bridge Design

1. Bridges with vertical abutments, including concrete box culverts, which are

constructed as bridges, shall have channel widths that are designed using the culvert

criteria (PDC 21a-i above). This opinion does not cover bridges that require pile

driving within a wetted stream channels.

2. Primary structural elements must be concrete, metal, fiberglass, or untreated timber.

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Wild Rivers Ranger District, Rogue River-Siskiyou National Forest

Concrete must be sufficiently cured or dried13 before coming into contact with

stream flow.

3. Riprap must not be placed within the bankfull width of the stream.

4. Riprap may only be placed below bankfull height when necessary for protection of

abutments and pilings. However, the amount and placement of riprap should not

constrict the bankfull flow.

iii. Crossing Design

1. Crossings shall be designed using an interdisciplinary design team consisting of an

experienced Engineer, Fisheries Biologist, and Hydrologist/Geomorphologist.

2. Forest Service crossing structures wider than 20 feet or with costs that exceed

$100,000 shall be reviewed by the USDA-Forest Service, Region 6, Aquatic

Organism Passage Design Assistance Team.

3. At least one member of the design team shall be trained in a week- long Aquatic 

Organism Passage course based Stream Simulation: An Ecological Approach to 

Providing Passage for Aquatic Organisms at Road-Stream Crossings (USDA-Forest 

Service 2008).

4. Bankfull width shall be based on the upper end of the distribution of bankfull width

measurements as measured in the reference reach to account for channel variability

and dynamics.

iv. NMFS fish passage review and approve – If the structure width is determined to be less than 

the established width criteria as defined above, a variance must be requested from NMFS for 

consistency with criteria in NMFS (2011).

v. Opportunity for individual consultation – The Action Agencies have a legal duty under the 

ESA to consult with NMFS and USFWS on a project- specific basis if they prefer to operate 

outside the conditions in this opinion. The standards provided in this document are 

conservative for the purpose of this programmatic and may or may not be applicable to 

projects that undergo individual Level 1 Consultation. The standards in ARBO II are not new 

defaults to be used universally outside the programmatic arena.

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Attn: Chris Park

Grants Pass, OR 975622164 N.E. Spaulding Ave.Grants Pass Interatency OfficeRogue River-Siskiyou National Forest
Sucker Creek Legacy Roads and Trails Environmental Assessment

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