U.S. Department of Agriculture 

Forest Service 

333 SW 1st Avenue, P.O. Box 3623

Portland, OR 97208 

 

U.S. Department of the Interior 

Bureau of Land Management 

333 SW 1st Avenue, P.O. Box 2965

Portland, OR 97208 

October 2003

 

Final Supplemental 

Environmental Impact Statement 

Clarification of Language in the 1994 Record of Decision 

for the Northwest Forest Plan 

National Forests and 

Bureau of Land Management Districts Within the Range of the 

Northern Spotted Owl

Proposal To Amend Wording About The Aquatic Conservation Strategy 

Western Oregon, Western Washington, and Northwestern California 
NOTICE 

Readers should note that the Secretary of Agriculture and the Secretary of the Interior 

are the responsible officials for this proposed action. Therefore, no administrative 

review (“appeal”) through the Forest Service will be available on the Record of 

Decision under 36 CFR 217, and no administrative review (“protest”) through the 

Bureau of Land Management will be available on the Record of Decision under 43 CFR 

1610.5-2. Because there is no administrative review of the decision, the Record of 

Decision will not be signed until 30 days after the Notice of Availability for the Final 

SEIS appears in the Federal Register (see 40 CFR 1506.10(b)). 

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

activities on the basis of race, color, national origin, gender, religion, age, disability, political 

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

programs.) Persons with disabilities who require alternative means for communication of 

program information (Braille, large print, audiotape, etc.) should contact USDA’s TARGET 

Center at (202) 720-2600 (voice and TDD). To file a complaint of discrimination, write USDA,

Director, Office of Civil Rights, Room 326-W, Whitten Building, 14th and Independence 

Avenue, SW, Washington, DC 20250-9410 or call (202) 720-5964 (voice and TDD). USDA is an 

equal opportunity provider and employer. 
Final Supplemental Environmental Impact Statement 

For Clarification of Language in the 1994 Record of Decision for the 

Northwest Forest Plan; National Forests and Bureau of Land Management 

Districts Within the Range of the Northern Spotted Owl 

Proposal to Amend Wording About The Aquatic Conservation Strategy 

Lead Agencies: U.S. Department of Agriculture, Forest Service 

U.S. Department of the Interior, Bureau of Land 

Management 

Responsible Officials: Ann Veneman, Secretary of Agriculture 

Gale Norton, Secretary of the Interior 

For More Information: Joyce Casey, Team Leader 

503-326-2430 jcasey01@fs.fed.us

Website Address: http://www.reo.gov/acs/

Abstract

The Secretaries of Agriculture and the Interior propose limited changes to language

about how to demonstrate that projects follow the Aquatic Conservation Strategy, part 

of the Northwest Forest Plan. Projects needed to achieve Northwest Forest Plan goals

have been delayed or stopped due to misapplication of certain passages in the Aquatic 

Conservation Strategy. The agencies are responding to the underlying need for 

increased agency success planning and implementing projects, to the extent that the 

current wording has hindered the agencies ability to follow Northwest Forest Plan 

principles and achieve its goals. The goals of the Northwest Forest Plan cannot be 

achieved without project implementation. 

Three alternatives are considered in the Final Supplemental Environmental Impact 

Statement, No Action, the Proposed Action, and Alternative A. No Action would not

change existing language within the Aquatic Conservation Strategy. The Proposed

Action and Alternative A would make limited changes to clarify documentation

requirements. Alternative A is the Preferred Alternative. If the Preferred Amendment

is approved, implementation of the range of projects envisioned under the Northwest

Forest Plan would be more likely. Land managers would more successfully 

demonstrate that projects follow the ACS. 

TABLE OF CONTENTS

SUMMARY............................................................................................................................. 1

Introduction/Purpose And Need .........................................................................................1 

The Proposed Amendment...................................................................................................1 

Alternatives Considered........................................................................................................1 

The Consequences Of No Action .........................................................................................2 

The Consequences Of The Action Alternatives .................................................................2 

Monitoring...............................................................................................................................2 

Decision Factors......................................................................................................................2 

Chapter 1. Purpose Of And Need For Action................................................................. 3

Introduction.............................................................................................................................3 

Purpose And Need.................................................................................................................6 

Need .....................................................................................................................................6 

Purpose ................................................................................................................................9 

Scope Of The Decision.........................................................................................................10 

Background: The Aquatic Conservation Strategy ..........................................................12 

Public Involvement ..............................................................................................................16 

Chapter 2. Alternatives, Including The Proposed Action.......................................... 17

Introduction...........................................................................................................................17 

Assumptions Common To All Alternatives .....................................................................17 

Alternatives Considered In Detail .....................................................................................17 

No Action ..........................................................................................................................17 

Proposed Action ...............................................................................................................18 

Alternative A – The Preferred Alternative ...................................................................18 

Alternatives Considered But Eliminated From Detailed Study ....................................25 

No Cutting Or Removal Of Trees Older Than 80 Years .............................................25 

Additional Standards And Guidelines And/Or Mitigation Measures .....................26 

Exempt Ski Resorts From Riparian Reserve Standards And Guidelines .................26 

Streamline Procedures For Planning Restoration Activities ......................................27 

Separate Watershed Restoration From Timber Sales ..................................................28 

Change Watershed Analyses To Watershed Plans......................................................28 

Incorporate Watershed Analysis Into Environmental Documentation....................29 

Required Procedures For Cumulative Watershed Impact Analysis .........................29 

Add A 10-Year Time Frame For Achieving ACS Objectives......................................30 

Proposed Action Language Circulated For Scoping ...................................................30 

Other Wording Suggestions............................................................................................30 

Slight Changes To The Proposed Action ......................................................................31 

Amend Riparian Reserves Standards And Guidelines...............................................32 

Eliminated References To The Management Direction In Attachment A As 

“Standards And Guidelines”..........................................................................................32 

Alternatives Compared .......................................................................................................33 

i
CHAPTER 3&4. AFFECTED ENVIRONMENT AND ENVIRONMENTAL 

CONSEQUENCES............................................................................................................... 35

Introduction...........................................................................................................................35 

Affected Environment .........................................................................................................35

The Four Components Of The Aquatic Conservation Strategy.................................35 

The Timber Sale Program................................................................................................41 

Monitoring And Adaptive Management......................................................................43 

Potential Changed Conditions To The Affected Environment..................................45 

New Listings Under Endangered Species Act And Clean Water Act ......................45 

Timber Harvest On Non-Federal Land.........................................................................47 

Secure Rural Schools And Community Self-Determination Act Of 2000.................47 

Environmental Consequences ............................................................................................48 

Effects On The Four Components Of The ACS............................................................48 

Effects On The Timber Sale Program ............................................................................49 

Effects On Other Activities That Implement The Northwest Forest Plan................52 

Environmental Effects Of No Action.............................................................................53 

Environmental Effects Of Proposed Action And Alternative A................................55 

Required Disclosures ...........................................................................................................58 

Relationship Between Short-Term Uses And Long-Term Productivity...................58 

Conflicts With Other Plans..............................................................................................58 

Irretrievable And Irreversible Commitment Of Resources ........................................60 

Civil Rights And Environmental Justice .......................................................................60 

Effects On Critical Elements ...........................................................................................60 

American Indian Rights And Resource Issues.............................................................61 

Chapter 5. Consultation And Coordination .................................................................. 61

Distribution Of The Draft Supplemental Environmental Impact Statement...............62 

Elected Officials ................................................................................................................62 

Intergovernmental Advisory Committee (To The Regional Ecosystem Office)......62 

Federal Agencies...............................................................................................................63 

State, County, And Local Governments........................................................................63 

American Indian Tribes And Nations ...........................................................................65 

Businesses..........................................................................................................................65 

Other Organizations.........................................................................................................67 

Libraries, Schools, And Universities..............................................................................69 

Media..................................................................................................................................70 

Individuals ........................................................................................................................71 

References..............................................................................................................................87 

List Of Preparers...................................................................................................................89 

Primary Interdisciplinary Team.....................................................................................89 

Other Contributors...........................................................................................................90

Index ...................................................................................................................................... 91

ii
List of Tables 

Table 1. Northwest Forest Plan Excerpts...................................................................................14

Table 2. Alternatives Compared by Decision Factors and Issues..............................................33

Table 3. Watershed Analysis Accomplishments........................................................................39

Table 4. Aquatic Restoration Accomplishments 1998-2001......................................................40

List of Figures 

Figure 1. Northwest Forest Plan Area................................................................5 

Figure 2. Timber Sale Volume Offered in Comparison to PSQ, 1995-2002 ....................42 

Appendices 

A. Selected Records 

a. 1999 Regional Ecosystem Office Memo 

b 2003 BLM Information Bulletin 

c. Orders and Declarations from PCFFA v. NMFS

B. Effects Findings Consistency Assessment 

C. Summary of Comments to DSEIS and Agency Responses 

D. Biological Assessment for the Preferred Alternative A 

E. Potential Changed Conditions Report 

F. Review of Scientific Concepts Report 

iii
iv
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

SUMMARY 

Introduction/Purpose and Need 

The Secretaries of Agriculture and the Interior propose limited changes to language 

about how to implement the Aquatic Conservation Strategy (ACS). The ACS is an 

integral part of the Northwest Forest Plan. The ACS is intended to maintain and 

restore the ecological health of watersheds and aquatic ecosystems within the 

Northwest Forest Plan area. The ACS includes language that has been interpreted to 

mean that decision-makers must demonstrate that a proposed project will attain all of 

the ACS objectives. These objectives were never intended to be site-specific standards; 

rather, they were intended to be achieved at the fifth-field watershed scale and 

broader, over the long term. Confusion related to the existing language has hindered 

federal land managers’ ability to plan and implement projects needed to achieve 

Northwest Forest Plan goals. 

The Proposed Amendment 

The proposed amendment would make limited changes to language within 

Attachment A of the 1994 Record of Decision (ROD) for the Northwest Forest Plan. 

These changes would amend Forest Service and Bureau of Land Management plans

throughout the Northwest Forest Plan area. The limited changes would clarify that the 

proper scale for federal land managers to evaluate progress toward achievement of the 

ACS objectives is the fifth-field watershed and broader scales. The changes would also 

clarify documentation requirements for land managers to demonstrate that projects 

follow the ACS. It would remove the expectation that all projects must achieve all ACS 

objectives, but would reinforce the role of watershed analysis in providing context for 

project planning. Current land allocations, standards and guidelines, and Northwest 

Forest Plan goals and objectives would be retained. 

Alternatives Considered 

Three alternatives - No Action, the Proposed Action, and Alternative A - are 

considered in detail in this Final Supplemental Environmental Impact Statement. The 

Forest Service and Bureau of Land Management received many comments expressing 

concern that the Proposed Action would change the original intent of the ACS. 

Alternative A was developed to mitigate these concerns. 

1
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

The Consequences of No Action 

If the proposed amendment is not approved, implementation of the range of projects 

envisioned under the Northwest Forest Plan is less likely. Projects intended to achieve 

Northwest Forest Plan goals would continue to be delayed or stopped due to 

misapplication of certain passages in the ACS. Land managers would continue to 

have difficulty demonstrating that projects follow the ACS. 

The Consequences of the Action Alternatives 

If the proposed amendment is approved, implementation of the range of projects 

envisioned under the Northwest Forest Plan would be more likely. Land managers 

would more successfully demonstrate that projects that comply with standards and 

guidelines follow the ACS. 

Monitoring 

The agencies have developed a monitoring plan to assess progress toward attainment

of ACS objectives across the Northwest Forest Plan area. The Aquatic Riparian 

Effectiveness Monitoring Plan (AREMP) was approved in March 2001 and published 

in 2003 (Reeves et al. 2003). Under the AREMP, the condition of various watersheds

across the Northwest Forest Plan area will be evaluated. Over time, AREMP will show 

whether watershed conditions are improving. The AREMP will provide information 

in a decade or more at the province scale. Monitoring also occurs as a part of each 

Resource Management Plan. 

Decision Factors 

The decision will be based on which alternative increases success planning and 

implementing projects that follow Northwest Forest Plan principles and achieve its 

goals, and has the least risk of changing the original intent of the ACS. 

2
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

CHAPTER 1. PURPOSE OF AND NEED FOR ACTION 

Introduction 

The Secretaries of Agriculture and the Interior propose limited changes to language in 

National Forest Land and Resource Management Plans and Bureau of Land 

Management Resource Management Plans within the Northwest Forest Plan area (see 

Figure 1) to clarify the Aquatic Conservation Strategy described within these plans. 

In 1994, the Secretaries of Agriculture and the Interior signed the Northwest Forest 

Plan, which amended agency management plans as part of the Record of Decision for 

Amendments to Forest Service and Bureau of Land Management Planning Documents Within

the Range of the Northern Spotted Owl. The 1994 Record of Decision resulted in several 

amended resources management plans, however agencies continue to refer to the 

coordinated management direction as the Northwest Forest Plan. 

The Aquatic Conservation Strategy (ACS) is an integral part of the Northwest Forest 

Plan. The ACS was developed to maintain and restore the ecological health of 

watersheds and aquatic ecosystems within public lands. The ACS includes language 

that has been interpreted to establish an expectation that may be impossible for 

projects to meet. These interpretations hinder federal land managers’ ability to plan

and implement projects needed to achieve Northwest Forest Plan goals. The 

Secretaries of Agriculture and the Interior propose to amend the Northwest Forest Plan 

to clarify the documentation required to demonstrate that projects follow the ACS. 

This Supplemental Environmental Impact Statement (SEIS) supplements information 

in the Northwest Forest Plan Record of Decision and FSEIS. The 1993 Forest 

Ecosystem Management Analysis Team (FEMAT) report provides the scientific basis 

for the Northwest Forest Plan and Aquatic Conservation Strategy. 

The Forest Service (FS) and Bureau of Land Management (BLM) prepared this Final

SEIS in compliance with the National Environmental Policy Act (NEPA) and other 

relevant federal and state laws and regulations. The FS and BLM are also referred to as 

“the agencies.” An Interagency Interdisciplinary Team (IDT) was chartered to evaluate 

the potential effects of the proposed amendment (see List of Preparers). 

3
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

The area affected by the proposed amendment is referred to as the Northwest Forest 

Plan area. In this SEIS, Land and Resource Management Plans for National Forests 

and Resource Management Plans for BLM Districts are collectively referred to as 

“Resource Management Plans or RMPs.” Resource Management Plans for the 

following administrative units would be amended: 

• Salem, Eugene, Roseburg, Medford, and Coos Bay BLM Districts in Oregon 

• Klamath Falls Resource Area of the Lakeview BLM District, also in Oregon 

• Arcata, Redding, and Ukiah BLM Field Offices in California 

• The King Range National Conservation Area Management Plan in the Arcata 

BLM Field Office, also in California 

• Gifford Pinchot, Olympic, Mt. Baker-Snoqualmie, Okanogan, and Wenatchee 

National Forests in Washington1

• Mount Hood, Willamette, Umpqua, Siuslaw, Siskiyou, Rogue River, Deschutes, 

and Winema National Forests in Oregon 

• The Six Rivers, Klamath, Lassen, Mendocino, Modoc, and Shasta-Trinity 

National Forests in California 

The proposed amendment would also affect management of the Coquille Forest. 

These lands are owned by the Coquille Indian Tribe, are part of the Coquille Indian 

Reservation, and are held in trust by the United States. An Act of Congress in 1996 

transferred ownership of about 5,400 acres of federal land within the Northwest Forest 

Plan transferred to the Coquille Indian Tribe. The Act required that Coquille Forest be 

managed subject to the standards and guidelines of federal forest plans on adjacent or 

nearby federal lands, therefore the Coquille Forest would be affected by this proposed 

amendment to the Coos Bay BLM Resource Management Plan. 

Throughout this document, the 1994 Northwest Forest Plan Final Supplemental Impact 

Statement is referred to as the Northwest Forest Plan FSEIS, while the 2003 ACS Final 

Supplemental Impact Statement is referred to as the Final SEIS. 

 1 The proposed amendment to National Forest Land and Resource Management Plans are considered significant

amendments under the National Forest Management Act. 

4
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

5 Figure 1. Northwest Forest Plan Area Map 
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Purpose and Need 

Need 

The Northwest Forest Plan includes the following principles (p. 3 of the 1994 Record of 

Decision): 

• “...to protect the long-term health of our forests, our wildlife and our 

waterways ...” 

• “Where sound management policies can preserve the health of forest land, 

timber sales should go forward.” 

• “...to produce a predictable and sustainable level of timber sales...that will not 

degrade or destroy the environment.” 

The goal of the ACS is stated in several places, including page B-9 of the Northwest 

Forest Plan Record of Decision: 

• “to maintain and restore the ecological health of watersheds and the aquatic 

ecosystems within them.” 

Projects intended to achieve Northwest Forest Plan goals have been delayed or 

stopped due to misapplication of certain passages in the ACS. Specific language has

been interpreted to mean that every project must achieve all ACS objectives at all 

spatial and temporal scales. This interpretation suggests land managers must 

demonstrate that a project will maintain existing conditions (or lead to improved 

conditions) at every spatial and temporal scale. Any project that may result in sitelevel disturbance to aquatic or riparian habitat, no matter how localized or short-term, 

could be precluded under this interpretation. This interpretation establishes an 

impossible expectation for demonstrating that a project follows the ACS. 

Current language has also been interpreted to imply too simplistic a relationship 

between projects and attainment of ACS objectives by requiring a “finding of 

consistency” with ACS objectives for all projects. Projects must be considered in a 

watershed-scale or broader context to determine whether potential effects to aquatic 

ecosystems are acceptable. 

The agencies are responding to the underlying need for increased success planning 

and implementing projects, to the extent that the current wording has hindered the 

agencies ability to follow Northwest Forest Plan principles and achieve its goals. The 

goals of the Northwest Forest Plan cannot be achieved without project implementation. 

6
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Types of projects most likely affected by misinterpretation of the ACS include: 

• Forest management outside reserves, including regeneration timber harvest 

and harvest within late-successional and old-growth habitats.

• Actions associated with timber harvest, including transportation system

treatments such as culvert removal and replacement. 

• Restoration silviculture in Riparian and Late-Successional Reserves, hazardous 

fuels reduction and forest health thinning, especially projects that are 

accomplished by a timber sale. 

• Special uses, mining, livestock grazing and recreation. 

• Watershed restoration projects, such as stream enhancements, fish passage 

improvements, and road decommissioning. 2

Overlap between these types of projects is common. Timber sales are used to 

accomplish hazardous fuels reduction, restoration silviculture, and forest health

thinning. Frequently, timber sales provide the opportunity and funding for culvert 

removal and replacement. 

The current wording of the ACS has influenced litigation regarding the Endangered 

Species Act. The U.S. District Court in the Western District of Washington interpreted 

the Northwest Forest Plan as requiring that, “not only must the ACS objectives be met 

at the watershed scale...each project must also be consistent with ACS objectives, i.e. it 

must maintain the existing condition or move it within the range of natural 

variability.” Pacific Coast Federation of Fishermen’s Association v. National Marine 

Fisheries Service), 71 F. Supp.2d 1063, 1069 (W.D. Wash. 1999).3 

In the PCFFA v. NMFS litigation, the U.S. District Court ruled that the Northwest 

Forest Plan programmatic biological opinion met the standards of the Endangered 

Species Act but that 24 project-level biological opinions did not adequately 

demonstrate that projects followed the ACS. The U.S. District Court ruled that NMFS 

had an independent obligation to ensure ACS consistency since it was used as a 

surrogate for jeopardy analysis4. 

 2 Other examples of restoration projects include (but are not limited to) prescribed burning, underplanting, snag and 

down wood management, invasive weed control. 

3 This case will hereby be referred to as PCFFA v. NMFS. This part of the ruling was affirmed in 253 F.. 3d 1137 (9th

Circuit 2001). See Appendix A for full text of the ruling. NMFS is now known as National Oceanic and Atmospheric 

Administration (NOAA) Fisheries. 

4 Jeopardy analysis refers to a determination that programs or projects will not jeopardize the continued existence of a 

species listed as threatened or endangered, or proposed for listing under the Endangered Species Act. Jeopardy 

analysis was at issue in PCFFA v. NMFS. 

7
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

The U.S. District Court said that National Marine Fisheries Service (NMFS): 

• failed to demonstrate that projects included in biological opinions were 

consistent with ACS objectives at all scales; 

• inadequately addressed site-specific and aggregated effects of timber sales; 

• inadequately addressed short-term adverse effects from timber sales; 

• ignored the best available scientific information due to a failure to demonstrate 

the use of watershed analysis and its recommendations; and 

• failed to show that actions proposed within Riparian Reserves would result in 

benefits to aquatic habitats and ecosystems as required by the Northwest Forest 

Plan. 

The U.S. District Court in PCFFA v. NMFS allowed some watershed restoration 

projects to proceed, even though they were covered by a biological opinion invalidated 

by the court. Timber sales under the same biological opinions were not allowed to 

proceed, even though in many cases, the action that caused the adverse effect were 

restoration components attached to timber sale activities (such as a culvert replacement 

on a timber sale haul route). This has led to further agency confusion about 

application of the ACS at the site scale. 

Northwest Forest Plan goals that would have been addressed by the timber Sales 

include: maintaining forest health, producing a sustainable supply of wood products, 

and restoring watershed health. The timber sales covered by the invalidated biological 

opinions minimized construction of roads and included associated projects such as 

decommissioning roads, and upgrading culverts. Trees were to be directionally felled 

away from the Riparian Reserves. Ground-based yarding and prescribed burning 

were to be timed to avoid harmful impacts. 

As a result of the design features and mitigation measures, the timber sales were 

characterized as having minimal impact on anadromous fish habitat. The most 

common impact noted was a transitory increase in stream sedimentation and/or shortterm, localized sedimentation from road-related activities, especially activities that 

would have been restorative in the long term but directly affected streams and riparian 

areas in the short-term, such as culvert replacement, road decommissioning, skid trail 

obliteration and road maintenance. The current wording of the ACS has been 

interpreted to preclude timber sales such as these that may result in minimal impact to 

aquatic and riparian habitat. 

8
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

NOAA Fisheries has not issued any biological opinions covering timber sales in the 

Northwest Forest Plan area since 1999. Transportation system projects associated with 

the timber Sales have also been delayed. 

The court decisions were related to biological opinions covering specific timber sales, 

but the underlying assumptions in the decisions could apply to any project. At least 

three pending lawsuits have been filed that allege that proposed projects do not follow 

the ACS because they do not maintain the existing riparian and aquatic condition at 

every scale; and thus violate requirements that projects comply with Resource 

Management Plans under the Federal Land and Policy Management Act (FLPMA) and 

the National Forest Management Act (NFMA). 5 

A difficulty presented by the court interpretations in the PCFFA litigation is that 

projects are expected to attain ACS objectives at all scales. However, the ACS 

objectives contain broad goals that are not intended to be achieved by individual 

projects. For example, the land allocations within the Northwest Forest Plan could be 

expected to meet the ACS objective to “maintain and restore the distribution, diversity, 

and complexity of watershed and landscape-scale features to ensure protection of 

aquatic systems.” However, this same objective is impossible to achieve if applied as a 

standard to an individual project. 

Purpose 

The purpose of the proposed amendment is to clarify that: 

• The proper scales for federal land managers to evaluate progress toward 

achievement of the ACS objectives are the fifth-field watershed and broader 

scales.6

• No single project should be expected to achieve all ACS objectives. 

 5 BARK, et al. v. Gary Larsen et al. U.S D.C. District Court of Oregon, Civil No. 02-904-HU, filed July 2002; Headwaters

and ONRC Fund v. United States Forest Service ; U.S D.C. District Court of Oregon, Civil No. 02-1519-JO, filed 

November 2002; and Klamath-Siskiyou Wildlands Center v. BLM U.S.D.C. District Court of Oregon, Civil No. 03-3006-

CO, filed January 2003. League of Wilderness Defenders and Blue Mountains Biodiversity Project, and

Cascadia Wildlands Project v. U.S. Forest Service, Civil No. 03-1357-PA (filed October 3, 2003)

6 The fifth-field scale was selected in the 1995 Federal Guide for Watershed Analysis as the consistent size for analysis. 

It is the first subdivision of a subbasin and considered the most appropriate to “provide the context for management

through description and understanding of specific ecosystem conditions and capabilities” (p. 7) and “satisf[y] many

needs and offers a consistent format for reporting results of an analysis” (p. 8).

9
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

• Decision-makers must design projects to follow the ACS. Project records must 

contain evidence that the project complies with relevant standards and

guidelines in Sections C and D of Attachment A in the Northwest Forest Plan 

Record of Decision. Project records must also demonstrate how the decisionmaker used relevant information from applicable watershed analysis to provide 

context for project planning. 

• References to ACS objectives in the standards and guidelines in Sections C and 

D do not require that decision makers find that site-scale projects, in 

themselves, will fully attain ACS objectives. 

Goals and objectives, management prescriptions and practices, land allocations and 

other management direction are contained within Attachment A. However, allocationspecific management direction that applies to project planning is also called “standards 

and guidelines.” These standards and guidelines are contained in Sections C and D of 

Attachment A. An amendment is needed to clarify that the standards and guidelines 

that must be specifically addressed in project planning records are those within 

Sections C and D of Attachment A, rather than the entirety of Attachment A. 

Scope of The Decision 

The Secretaries of Agriculture and the Interior are the decision-makers for this SEIS. 

They will decide whether or not to amend the ACS portions of all Resource 

Management Plans within the Northwest Forest Plan area. Management of the 

Coquille Forest would also be affected. The Secretaries are not reconsidering decisions 

made in 1994 regarding land allocations or fundamental management direction. 

Individual projects would not be approved with this programmatic decision. The 

Secretaries will select No Action, the Proposed Action, or the Proposed Action as 

modified in Alternative A. The secretaries may also select a combination of these

alternatives. A Supplemental EIS was prepared to address potential effects of the 

language changes because the agencies perceive that any change to the Northwest 

Forest Plan is controversial. 

The decision will be based on which alternative increases success planning and 

implementing projects that follow Northwest Forest Plan principles and achieve its 

goals and has the least risk of changing the original intent of the ACS. 

10
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

During scoping and the Draft SEIS comment period, many people suggested that the

agencies should analyze certain concurrent proposals in a single EIS. Several 

commenters specifically mentioned that the Survey and Manage Supplemental EIS 

should be combined with the ACS Supplemental EIS. 

The agencies are also concurrently considering alternatives to remove or modify the 

Survey and Manage mitigation measure in the Northwest Forest Plan to settle 

litigation filed by the timber industry and county government associations. 

Other alleged connected analyses were also named, including the Forest Service 

“Invasive Plant EIS,” the BLM and FS “Port-Orford-cedar EIS” and the BLM 

“Vegetation Treatments Programmatic EIS." The Port-Orford-cedar EIS was 

necessitated by the Kern v. BLM decision of the Ninth Circuit, and the BLM Vegetation 

Management EIS is intended (among other things) to address problems created by 

court injunctions from the 1980’s that still restrict BLM herbicide use. 

The agencies also considered the recent settlement agreement on a lawsuit pertaining 

to the federal timber sale program on Oregon and California (O&C) railroad lands. 

The major issues revolved around the alleged inappropriate application of reserves 

and wildlife viability standards to O&C lands. The O&C lands account for more than

2.5 million acres in western Oregon and northern California. 

Under the O&C settlement agreement, federal agencies will attempt to achieve the PSQ 

associated with Alternative 9 (approximately 805 million board feet - see Chapter 

Three for more information on PSQ), along with additional harvest from restoration 

silviculture within the reserves. The BLM will revise its Resource Management Plans 

within the next several years. The revision process outlined in the settlement 

agreement will require further NEPA analysis. In the meantime, the BLM will 

continue to manage lands under its administration in accordance with existing 

Resource Management Plans. 

NEPA regulations at 40 CFR 1508.25 (9)(a) discuss situations that warrant considering 

actions in a single environmental impact statement. None of the concurrent analyses, 

regulatory proposals, and settlements trigger action on the ACS SEIS, nor would a 

decision on the ACS trigger action on any of the other proposals. Each could proceed 

independently of the other. None are interdependent parts of a larger action. 

The effects of the Northwest Forest Plan as a whole are analyzed in the 1994 FSEIS. 

None of the current proposals alter Northwest Forest Plan land allocations that are the 

basis for the effects analysis. 

11
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Therefore, the agencies determined that these various proposals are not connected or

similar actions and therefore need not be combined in a single SEIS (40 CFR 1508.25). 

The cumulative effects of these actions are considered in Chapter 3&4. 

Background: The Aquatic Conservation Strategy 

The ACS was developed to restore and maintain ecological health of watersheds (and 

the aquatic ecosystems contained within them) on federally-managed lands within the 

Northwest Forest Plan area. The four major components of the ACS (Riparian 

Reserves, Key Watersheds, watershed analysis, and watershed restoration) provide the 

basis for protection of watershed health. 

As stated in the Northwest Forest Plan Record of Decision: 

“The Aquatic Conservation Strategy must strive to maintain and restore ecosystem 

health at watershed and landscape scales...This approach seeks to prevent further 

degradation and restore habitat over broad landscapes as opposed to individual 

projects or small watersheds.” 

One of the authors of the ACS from the FEMAT team described the intent of the ACS 

as follows:7 

“The ACS objectives provide a framework for managing aquatic ecosystems at 

the watershed and landscape (i.e. multiple watershed) scale. They describe the 

attributes and distribution of aquatic ecosystems believed necessary to provide 

conditions for maintaining currently strong populations of fish and other

aquatic and riparian-dependent organisms and to recover currently degraded 

ecosystems. They are not intended to be a hard set of criteria that could or can 

be applied equally at all spatial scales of concern (i.e. site, watershed, province 

and region).” 

In November 1999, the Regional Ecosystem Office (REO) published a memorandum 

addressing “Northwest Forest Plan Record of Decision requirements for determining 

project consistency with ACS objectives.” The REO clarified that “the watershed scale 

is the appropriate landscape context for determining whether actions are consistent 

with the ACS objectives.” The full text of the REO memorandum is included in 

Appendix A. 

 7 Declaration of Gordon Reeves Ph.D. filed in 1999 in PCFFA v. NMFS Civ. No. C 99-0067 T (U.S.D.C. W.D. 

Washington). Full text of the declaration is included in Appendix A. 

12
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

In December 2002, the United States Department of the Interior Office of Hearings and 

Appeals, Interior Board of Land Appeals (IBLA) upheld the BLM’s interpretation of the 

ACS. The IBLA decision states: 

“The Northwest Forest Plan does not require every action conducted in a 

watershed to result in improvement to the watershed,” and that “it may take 

decades, possibly more than a century” to achieve ACS objectives. 

The IBLA concludes that timber sales that would not degrade a watershed are not 

precluded (even though they may have short-term, site-scale effects). 

The Northwest Forest Plan includes existing language that supports the proposed 

language change (see Table 1). Gordon Reeves, PhD is a scientist who worked on the 

original Aquatic Conservation Strategy and has continued to work on ways to 

implement the strategy and monitor its results. In a 2003 review of the science behind 

the ACS, Dr. Reeves wrote: 

“The Aquatic Conservation Strategy was designed to restore and maintain the 

processes that create and maintain conditions in aquatic ecosystems over time.” 

Reeves also wrote that successful implementation of the ACS would require: 

“...policies that recognize the dynamic nature of aquatic ecosystems and 

describe practices that allow the systems to express a range of desired 

conditions over time.” 

Dr. Reeves noted that watersheds that support aquatic ecosystems display a range of 

conditions and not every reach of stream need be in good condition for the watershed 

to function properly. The full text of Dr. Reeves’ report is in Appendix F.

13
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Table 1. Northwest Forest Plan Excerpts 

Citation Excerpt Interpretation

FEMAT 

page V-30; 

FSEIS page 

B-82. 

“...To succeed, any Aquatic 

Conservation Strategy must strive to 

maintain and restore ecosystem health 

at watershed and landscape scales. 

Thus, this is the approach the 

conservation strategy here employs. 

The approach seeks to prevent further 

degradation and restore habitat over 

broad landscapes as opposed to 

individual projects or small 

watersheds... ” 

This excerpt indicates that the

Aquatic Conservation 

Strategy has broad scale 

objectives. Individual

projects must be considered 

in the context of the larger 

landscape. 

FSEIS page 

3&4-320 

 “...Projects can only proceed if 

watershed analysis and site-specific 

analysis and consultation find 

management activities consistent

with...management direction. The 

consistency of these actions with 

specific prescriptions and long-term 

objectives of this proposal will either be 

affirmed by monitoring and research, 

or will be adapted to conform with the 

long-term objectives.” 

This excerpt indicates that the

Aquatic Conservation 

Strategy has long-term 

objectives. 

FSEIS page 

B-83 

 “Implementing the ACS requires 

applying the standards and guidelines 

...within the context of the overall ACS 

objectives.” 

This excerpt differentiates 

between objectives and 

standards and guidelines. 

While all of Attachment A 

includes management 

direction, a subset of that 

direction is “standards and 

guidelines” that apply to 

project planning within 

various land allocations. 

14
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Citation Excerpt Interpretation

FSEIS page 

B-83

 “The standards and guidelines are 

designed to focus the review of 

proposed and existing projects to 

determine their compatibility with the 

ACS.” 

This excerpt indicates that 

compliance with Key 

Watershed and Riparian 

Reserve standards and 

guidelines, given context 

provided by information at 

the watershed scale, ensures 

that projects are compatible 

with the ACS. 

FSEIS page 

F-64

“The total system of Key Watersheds, 

along with Riparian Reserves and the 

specified standards and guidelines, will 

meet the need to protect the overall 

ecosystem while providing for other 

management opportunities.” 

This excerpt indicates that 

compliance with Key 

Watershed and Riparian 

Reserve standards and 

guidelines, given context 

provided by information at 

the watershed scale, ensures 

that projects are compatible 

with the ACS. 

Record of 

Decision 

page B-12; 

FSEIS page 

3&4-68

“Standards and guidelines are 

intended to prohibit and/or regulate 

activities in Riparian Reserves that 

retard or prevent attainment of the 

Aquatic Conservation Strategy 

objectives.” 

This excerpt indicates that 

compliance with Riparian

Reserve standards and 

guidelines will ensure that 

attainment of ACS objectives 

is not retarded or prevented. 

FSEIS 

Volume II, 

Appendix F. 

page F-166

“The Aquatic Conservation Strategy 

objectives do not meet the definition of 

standards and guidelines and thus, are 

not included.”

This excerpt differentiates 

between standards and

guidelines and objectives. 

15
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Public Involvement 

Scoping comments were solicited from the public, government agencies, and agency 

staffs through the following: 

• Notice of Intent published in the Federal Register on November 25, 2002.

• Scoping letters sent to 2,800 concerned parties, including Indian tribes, through 

the Northwest Forest Plan mailing list between December 17, 2002 and January 

14, 2003. 

• On January 15, 2003,the scoping period was extended to February 3, 2003 to 

assure that all interested parties were provided adequate time to comment. 

More than 400 letters, faxes, and e-mails (collectively referred to as scoping comments) 

were received from a wide variety of parties including environmental organizations, 

industry associations, local governments, individuals, and two Inter-tribal fish 

commissions. Scoping comments covered a wide array of interests. All scoping 

comments were reviewed by the IDT. 

A Draft SEIS was released in March 2003. A comment period that exceeded 90 days

was provided. The comment period ended July 10, 2003. Approximately 1,200 pieces 

of correspondence were received. A summary of substantive comments and agency 

responses is in Appendix C. The summary reflects the range of comments received. 

The public and other agencies raised the following issues during the scoping and Draft 

SEIS comment periods: 

• Changed Conditions - Changed conditions since the release of the 1994 FSEIS 

should be considered in the effects analysis. Since 1994, there have been 

droughts, floods, and wildfires and subsequent salvage and restoration 

activities. Within the Northwest Forest Plan area since 1994, several species of 

fish have been listed under the Endangered Species Act and several water 

bodies have been listed as impaired under the Clean Water Act. Since 1994, 

agencies have been unable to meet the Probable Sale Quantity associated with 

Alternative 9. 

• Increased Accomplishment - The proposed amendment is intended to increase 

agency success planning and accomplishment that follow Northwest Forest 

Plan principles, including timber harvesting. Timber harvesting and associated 

road work may have effects that are not consistent with attainment of ACS 

objectives. 

• Potential Unintended Consequences - The proposed amendment may change 

the original intent of the ACS by eliminating particular passages. The analysis 

within this SEIS is related to these issues. Alternative A was developed to 

mitigate the risk of unintended consequences. 

16
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

CHAPTER 2. ALTERNATIVES, INCLUDING THE PROPOSED 

ACTION 

Introduction 

This chapter describes and compares the alternatives considered in detail. It also 

discloses additional alternatives considered but eliminated from detailed study, and

provides rationale for their dismissal. 

Assumptions Common to All Alternatives 

• All alternatives retain land allocation decisions from the Northwest Forest Plan. 

• All components of the Aquatic Conservation Strategy are maintained, including 

Riparian Reserve standards and guidelines, watershed analysis, watershed 

restoration, and Key Watersheds. ACS objectives remain unchanged. 

• NOAA Fisheries and the U.S. Fish and Wildlife Service (USFWS) are 

developing new approaches to consultation that do not rely on the ACS as a 

surrogate for Endangered Species Act jeopardy analysis. The new approaches 

would be applied to consultation under all alternatives. 

Alternatives Considered in Detail 

Three alternatives - No Action, the Proposed Action, and Alternative A - are 

considered in detail in this Final Supplemental Environmental Impact Statement. 

These alternatives are variations on language within Attachment A of the 

Northwest Forest Plan Record of Decision. 

No Action 

Under the No Action alternative, the current wording of the ACS would be retained. 

Land managers would continue to plan projects to meet the goals and objectives of the 

Northwest Forest Plan, but would encounter difficulty demonstrating that projects 

resulting in short-term disturbance to aquatic or riparian habitat “maintain the existing 

condition.” A “finding of consistency with ACS objectives” would continue to be 

required for every project. 

17
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Proposed Action 

Under the Proposed Action, the Secretaries of Agriculture and the Interior would 

amend specific language about how to follow the ACS within Resource Management 

Plans in the Northwest Forest Plan area. Land managers would be required to 

demonstrate that projects comply with applicable standards and guidelines in Sections 

C and D of Attachment A in the Record of Decision. Land managers would also be 

required to document how applicable watershed analysis was used to provide context 

for project planning. No additional site-scale determinations regarding attainment of 

ACS objectives would be required. 

The Proposed Action does not change the goals or objectives of the 1994 Northwest 

Forest Plan Record of Decision. All components of the ACS (Riparian Reserves, Key 

Watersheds, watershed analysis and watershed restoration) would remain in place. 

 The Proposed Action also clarifies that information in watershed analysis will be used 

in planning and decision-making, but is not a decision-making process in and of itself. 

This principle is emphasized in 1994 Northwest Forest Plan Record of Decision, 1994 

the FSEIS, and the 1995 Federal Guide for Watershed Analysis. 

Alternative A – The Preferred Alternative 

The Proposed Action was modified in response to comments received during the Draft 

SEIS comment period. The modified Proposed Action is called Alternative A. 

Alternative A is the Preferred Alternative. 

Alternative A retains some paragraphs deleted by the Proposed Action and adds some 

explanatory paragraphs to the Proposed Action. These modifications are intended to 

resolve public concerns about specific wording in the Proposed Action, to more 

precisely reflect the intent of the ACS. 

Public concern was expressed that under the Proposed Action a given project would 

not be required to “maintain the existing condition or improve the watershed 

condition.” Alternative A retains the concept that under the ACS, agencies must 

“maintain existing conditions or implement actions to restore conditions at the fifthfield watershed scale, over the long term.” 

18
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Many people expressed concern about removing paragraphs that state that all of 

Attachment A should be considered “standards and guidelines.” Some people stated 

that the Proposed Action “rendered many Section C and D standards and guidelines 

unclear and ineffective.” Alternative A was developed to retain existing paragraphs 

that refer to all of Attachment A was standards and guidelines, to avoid unintended 

consequences of removing or replacing these references. Alternative A also retains the 

existing language that explains how to interpret standards and guidelines that refer to 

ACS objectives. 

Specific language choices associated with No Action, Proposed Action, and Alternative 

A are compared in the following pages. 

Northwest Forest Plan, Attachment A, Page A-6 

No Action (Existing) Proposed 

Action 

Alternative 

A 

Designated areas, matrix and Key Watersheds all 

have specific management direction regarding how 

these lands are to be managed, including actions that 

are prohibited and descriptions of the conditions that

should occur there. This management direction is 

known as “standards and guidelines” – the rules and 

limits governing actions, and the principles specifying 

the environmental conditions or levels to be achieved 

and maintained. Although the direction in all sections 

of this document constitutes standards and 

guidelines, standards and guidelines specific to 

particular land allocation categories, or relative to

specific types of management activities, are included

in Section C of these standards and guidelines.

Deleted in 

entirety 

Same as No

Action 

19
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Northwest Forest Plan, Attachment A, Page B-9 

No Action (Existing) Proposed Action Alternative A 

Any species-specific strategy aimed 

at defining explicit standards for 

habitat elements would be 

insufficient for protecting even the 

targeted species. The Aquatic 

Conservation Strategy must strive 

to maintain and restore ecosystem 

health at watershed and landscape 

scales to protect habitat for fish and 

other riparian-dependent species 

and resources and restore currently 

degraded habitats. This approach 

seeks to prevent further 

degradation and restore habitat 

over broad landscapes as opposed 

to individual projects or small 

watersheds. Because it is based on 

natural disturbance processes, it 

may take decades, possibly more 

than a century, to accomplish all of 

its objectives. Some improvements 

in aquatic ecosystems, however, 

can be expected in 10 to 20 years. 

Any species-specific strategy aimed 

at defining explicit standards for 

habitat elements would be 

insufficient for protecting even the 

targeted species. The Aquatic 

Conservation Strategy must strive to 

maintain and restore ecosystem 

health at watershed and landscape 

scales to protect habitat for fish and 

other riparian-dependent species 

and resources and restore currently 

degraded habitats. This approach 

seeks to prevent further degradation

and restore habitat over broad 

landscapes as opposed to individual 

projects or small watersheds. 

Because it is based on natural 

disturbance processes, it may take

decades, possibly more than a 

century, to accomplish all of its 

objectives. Some improvements in 

aquatic ecosystems, however, can be 

expected in 10 to 20 years. The 

baseline from which to assess 

maintaining or restoring the 

condition is developed through a 

watershed analysis. Improvement 

means restoring biological and 

physical processes within their 

ranges of natural variability. 

Same as No 

Action 

20
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Northwest Forest Plan, Attachment A, Page B-10 

No Action (Existing) Proposed Action Alternative A (see footnotes on following page)

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.

Management actions that do

not maintain the existing 

condition or lead to improved 

conditions in the long term

would not “meet” the intent 

of the Aquatic Conservation 

Strategy and thus, should not 

be implemented. 

The four components of the

Aquatic Conservation Strategy

(Riparian Reserves, Key

Watersheds, watershed analysis, 

and watershed restoration), in 

combination with application of 

pertinent standards and guidelines,

are expected to maintain and 

restore ecosystem health at 

watershed and broader scales.

By itself, no site-scale project can, 

or should be expected to fully

achieve ACS objectives. These

objectives are intended to be met 

over time at watershed and 

broader scales. Monitoring results 

will help managers evaluate 

progress toward achievement of 

ACS objectives. 

To follow the ACS at the site-scale, 

decision makers must demonstrate 

that projects comply with 

standards and guidelines in 

Sections C and D. 

The project record will

demonstrate how the agency used 

relevant information from

applicable watershed analysis to 

provide context for the design and 

site-specific assessment of the 

project, recognizing that watershed 

analysis is not a decision-making 

process in and of itself. 

References to ACS objectives in the 

standards and guidelines in 

Sections C and D do not require 

that decision makers find that sitescale projects, in themselves, will 

fully attain ACS objectives. 

The four components of the Aquatic 

Conservation Strategy (Riparian Reserves, Key 

Watersheds, watershed analysis, and 

watershed restoration), in combination with

application of relevant standards and

guidelines in Sections C and D (and other 

relevant standards in Resource Management 

Plans) are intended to achieve Aquatic 

Conservation Strategy Objectives. 1 

Under the Aquatic Conservation Strategy, the 

agencies must maintain existing conditions or 

implement actions to restore conditions at the 

fifth-field watershed scale over the long term. 

No management activities can be expected to 

maintain the existing condition at all scales and 

all times; disturbance from management 

activities must be considered in the context of

the condition of the fifth-field watershed as a 

whole. 2 

The project record will demonstrate how the 

agency used relevant information from

applicable watershed analysis to provide

context for project planning, recognizing that 

watershed analysis is not a decision-making 

process in and of itself, nor is watershed 

analysis a decision document. If watershed

analysis is not required or available, or does not 

contain relevant information, the project record 

will provide evidence that project effects were

considered relative to the watershed condition. 

Projects should be designed to comply with 

applicable standards and guidelines in Sections 

C and D (and other applicable standards in

Resource Management Plans). No further 

finding of ACS consistency is required. 

To comply with Riparian Reserve Standards 

and Guidelines that reference ACS objectives, 

the decision maker must document that 

analysis has been completed, including a 

description of the existing condition, a 

description of the range of natural variability of 

the important physical and biological 

components of a given fifth-field watershed, 

and how the project or management action 

maintains the existing condition or restores it

toward that range of natural variability.

 3 

21
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Northwest Forest Plan, Attachment A, Page C-1 

No Action (Existing) Proposed Action Alternative A 

Although the direction in all sections of

this document constitutes standards and 

guidelines, standards and guidelines 

specific to particular land allocation 

categories, or relative to specific types of 

management activities, are included (or 

referenced) in this section, Section C, of

these standards and guidelines. 

All land allocations have specific 

management direction regarding how

those lands are to be managed, including 

actions that are prohibited and descriptions 

of the conditions that should occur there. 

This management direction for specific

lands is known as “standards and 

guidelines”— the rules and limits 

governing actions, and the principles 

specifying the environmental conditions or 

levels to be achieved and maintained.

 Paragraph deleted 

All land allocations have specific 

management direction regarding 

how those lands are to be managed, 

including actions that are 

prohibited and descriptions of the 

conditions that should occur there.

This management direction for 

specific lands is known as

“standards and guidelines”— the 

rules and limits governing actions,

and the principles specifying the 

environmental conditions or levels 

to be achieved and maintained.

Same as No

Action 

Footnotes from Alternative A, page B-10: 1 Federal agencies may not be able to attain objectives within watersheds with relatively low proportions of

Federal lands (see Northwest Forest Plan FSEIS p. 3&4-82). 2 The Federal Guide for Watershed Analysis (1995) discusses issues of scale and explains why the fifth- field 

watershed scale “satisfies many needs and offers a consistent format for reporting results of an analysis.” The 

Federal Guide states that analysis at the watershed scale “provides the context for management through the 

description and understanding of specific ecosystem conditions and capabilities.” Watershed analysis 

requirements are described later in Section B. 3 The Federal Guide for Watershed Analysis (1995) discusses Range of Natural Variability on p. 20. 

22
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Northwest Forest Plan, Attachment A, Page C-2 

No Action (Existing) Proposed Action Alternative A 

Related approved plans 

such as those for National 

Scenic Areas or Wild and 

Scenic rivers are similarly 

assumed to apply where 

they are more restrictive, 

or provide greater benefits 

for late-successional forest 

related species. 

Related approved plans such 

as those for National Scenic 

Areas or Wild and Scenic 

rivers are similarly assumed 

to apply where they are 

more restrictive, or provide 

greater benefits for latesuccessional forest related 

species. 

Some standards and 

guidelines refer to attaining, 

being consistent with, 

meeting, or achieving ACS 

objectives. The intent of

these references is that 

projects will use relevant 

information from applicable 

watershed analysis to 

provide context for project 

planning. These references 

do not mean that decision 

makers must find that a sitescale project, by itself, will 

fully attain ACS objectives. 

Related approved plans 

such as those for National 

Scenic Areas or Wild and 

Scenic rivers are similarly 

assumed to apply where 

they are more restrictive, or 

provide greater benefits for 

late-successional forest 

related species. 

23
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Northwest Forest Plan, Attachment A, Page C-31

No Action Proposed Action Alternative A 

As a general rule, 

standards and guidelines 

for Riparian Reserves 

prohibit or regulate 

activities in Riparian 

Reserves that retard or 

prevent attainment of the 

Aquatic Conservation 

Strategy objectives. 

Watershed analysis and

appropriate NEPA 

compliance is required to

change Riparian Reserve 

boundaries in all 

watersheds.

As a general rule, standards 

and guidelines for Riparian 

Reserves prohibit or regulate 

activities in Riparian 

Reserves that retard or 

prevent attainment of the 

Aquatic Conservation 

Strategy objectives. 

Watershed analysis and

appropriate NEPA 

compliance is required to

change Riparian Reserve 

boundaries in all 

watersheds.

 As a general rule, standards 

and guidelines for Riparian 

Reserves prohibit or 

regulate activities in 

Riparian Reserves that 

retard or prevent attainment 

of the Aquatic Conservation 

Strategy objectives at the 

fifth-field watershed scale, 

over the long term. 

Watershed analysis and

appropriate NEPA 

compliance is required to

change Riparian Reserve 

boundaries in all 

watersheds.

To comply with Riparian

Reserve standards and 

guidelines that reference 

ACS objectives, the decision 

maker must complete an

analysis that includes a 

description of the existing 

condition, a description of 

the range of natural 

variability of the important 

physical and biological 

components of a given fifthfield watershed, and how 

the project or management 

action maintains the existing 

condition or restores it 

toward that range of natural 

variability. 

24
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Alternatives Considered but Eliminated from Detailed Study

Federal agencies are required by NEPA to rigorously explore and objectively evaluate

all reasonable alternatives to the Proposed Action and to briefly discuss the reasons for 

eliminating any alternatives that were not developed in detail (40 CFR 1502.14). The 

range of alternatives considered in detail is limited by the requirement to fulfill the 

Purpose and Need. 

Several alternatives considered by the interdisciplinary team were eliminated from 

detailed study. The Purpose and Need substantially limits the range of reasonable 

alternatives available for analysis and provides a relatively narrow scope for this 

action. 

No Cutting or Removal of Trees Older Than 80 Years 

The Oregon Natural Resources Council and several other groups and individuals 

suggested an alternative that would not allow cutting or removal of trees aged 80 years 

or older. With a few exceptions, all land allocations and standards and guidelines of 

the Northwest Forest Plan would remain in effect. Fuel reduction activities in firedependent forests may be allowed when the primary objective is ecological restoration. 

Pre-disturbance surveys would not be required for restoration projects in stands less 

than 80 years old. Pre-disturbance surveys would still be required for fuel reduction 

projects that substantially modify stands more than 80 years old. Pre-disturbance 

surveys would be conducted for Survey and Manage and Protection Buffer species 

listed in the 1994 Northwest Forest Plan Record of Decision. Strategic surveys would 

continue. 

This alternative was eliminated from detailed study because it does not respond to the 

Purpose and Need for Action. It does not suggest an alternative way to clarify 

language in the ACS, nor does it respond to the underlying need to follow Northwest 

Forest Plan principles. 

This SEIS is not intended, nor required, to re-examine management direction within 

the Northwest Forest Plan. An alternative that considered limiting harvest to stands

younger than 80 years was analyzed, but not selected, in 1994. 

25
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Additional Standards and Guidelines and/or Mitigation Measures 

Three specific alternatives were suggested to increase protection of aquatic ecosystems. 

1) An alternative was suggested to suspend existing “logging plans” and not 

permit any future plans until the “long-term consequences can be 

comprehensively approached, especially within sensitive places such as oldgrowth, areas that have not recovered from damage caused by past logging, 

and anywhere slopes are steep or unstable. “ 

2) An alternative was suggested that would have eliminated regeneration 

harvesting from consideration within the Northwest Forest Plan area. 

3) An alternative was suggested to strictly prohibit activities that could disturb 

aquatic or riparian ecosystems at any scale. Riparian Reserve standards and 

guidelines would apply to all projects, regardless of land allocation. 

 

The range of alternatives in the 1994 Northwest Forest Plan FSEIS considered measures 

such as the three suggested here. For instance, the FSEIS considered eliminating 

programmed timber harvest in late-successional and old-growth stands, and 

eliminating road building in Key Watersheds. 

The Secretaries of Agriculture and the Interior selected Alternative 9 in their 1994

decision. The current Secretaries intend to increase agency success implementing that 

plan. Alternatives that added standards and guidelines were eliminated from detailed 

study because they would not meet the Purpose and Need for Action as described in

Chapter 1. They would not result in increased success implementing projects 

(including timber sales) that follow Northwest Forest Plan principles. These 

alternatives would not address the need to clarify the current wording of the ACS to 

remove expectations that are impossible for projects to meet. 

Exempt Ski Resorts from Riparian Reserve Standards and Guidelines 

The agencies also considered an alternative to exempt ski resorts from the Riparian 

Reserve standards and guidelines. Ski area representatives have asserted that Riparian 

Reserve standards and guidelines have restricted ski run development and reduced the 

potential for additional recreational opportunities. An array of Best Management 

Practices specific to the ski industry was suggested to meet the same needs as the 

Riparian Reserve standards and guidelines but allow greater flexibility. 

26
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

During the Draft SEIS comment period, ski industry representatives stated that: 

“The Crystal Mountain Master Development Plan Draft Environmental Impact 

Statement document (August 2000) contains many examples of how Riparian 

Reserves have restricted ski trail development.“ 

“Confusion resulting from misinterpretation of the ACS objectives has 

contributed to a three-year setback for the Mt. Ashland project, likely doubled 

the expense associated with the NEPA process, and has contributed to the 

complete redrafting of the Mt. Ashland Ski Area Expansion Environmental 

Impact Statement. “ 

“In the late 1980s, operators of the Stevens Pass ski facility developed ski runs 

in the Mill Valley portion of the Stevens Pass special use permit (SUP) area. It is 

worth noting that trail development accomplished in the late 1980s would not 

have been allowed given the current, prevailing interpretation of the ACS (in 

fact, much of Region 6's ski trail infrastructure would not have been possible 

with the prevailing ACS interpretation.)” 

 

The ski industry representatives further described their suggestion for a “fundamental 

re-design” of how the Riparian Reserve standards and guidelines apply to permitted 

ski resorts. The representatives suggested a “matrix of modified standards and 

guidelines and ‘best management practices’ for special use permit lands.“ The 

representatives asserted that a significant degree of protection for riparian areas would 

be achieved with such a matrix. 

The alternative to exempt ski industry operations from the Aquatic Conservation 

Strategy standards and guidelines and replace them with another set of standards was 

eliminated from detailed study because it would not respond to the Purpose and Need. 

The scope of this SEIS is strictly limited to clarify ACS intent; this alternative would 

deviate from the intent to apply the standards and guidelines to activities within 

Riparian Reserves on federal lands within the Northwest Forest Plan area. 

Streamline Procedures for Planning Restoration Activities 

This alternative would streamline procedures for planning and implementing 

restoration activities, while leaving the existing language intact for logging, mining, 

and other extractive activities. Language would be drafted to allow short-term 

disturbance to aquatic or riparian habitat for watershed restoration projects. Shortterm disturbance to aquatic or riparian habitat would not be allowed for projects that 

are not clearly restorative. 

27
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

This alternative was eliminated from detailed study because it does not address the 

underlying need for action, which is to follow Northwest Forest Plan principles and 

achieve its goals. Alternative 9 was selected within the Northwest Forest Plan partly

because it provided higher amounts of timber than some other alternatives. This 

alternative would put impossible expectations on logging (and other “nonrestoration”) projects because “short-term disturbance would not be allowed.” 

This alternative would also leave unclear how to treat watershed restoration projects 

associated with a timber sale (such as culvert upgrades along a timber sale haul route). 

Streamlined procedures already exist for routine projects that may be categorically 

excluded from documentation in an Environmental Assessment or EIS under NEPA. 

Separate Watershed Restoration from Timber Sales 

Some comment letters to the Draft SEIS suggested that watershed restoration 

components should not be funded or accomplished with timber sales. Restoration 

work is often funded or accomplished with timber sales. This is efficient and allows 

opportunities to meet a variety of needs with an integrated project. Timber sales can 

fund road work, reduce fuel hazard, and improve forest health. Separating these 

projects in planning and/or implementation phases would be impractical. 

This alternative was eliminated from detailed study because agency funding and 

contracting procedures are beyond the scope of this analysis. It would not address the 

need to clarify language in the ACS. See Appendix C for detailed discussion about the 

integration of vegetation management and restoration. 

Change Watershed Analyses to Watershed Plans 

This alternative would modify the ACS by changing the role of watershed analysis. 

Watershed analysis would become a decision-making process and would contain 

prescriptive steps and priorities for restoring watersheds. Watershed plans would be 

similar to Resource Management Plans, except they would be applicable to a smaller 

geographic area. Projects would be required to be designed consistent with these

watershed plans. 

This alternative was eliminated from detailed study because it does not respond to the 

Purpose and Need. It would deviate from the stated role of watershed analysis in the 

1994 Northwest Forest Plan and the 1995 Federal Guide for Watershed Analysis. It 

would not clarify project documentation requirements. 

28
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Incorporate Watershed Analysis into Environmental Documentation 

An alternative was suggested during the Draft SEIS comment period to add a 

guideline that directs decision-makers to incorporate watershed analysis into 

environmental documentation by reference. The concern is that watershed analysis 

results have not been adequately incorporated into NEPA documentation. 

This concern is addressed through clarification of the information needed in project 

records document how projects are designed to follow the ACS. Alternative A 

specifically states: “The project record will demonstrate how the agency used relevant 

information from applicable watershed analysis to provide context for project 

planning...” and “To comply with Riparian Reserve standards and guidelines that

reference ACS objectives, the decision maker must document that analysis has been 

completed, including a description of the existing condition, a description of the range

of natural variability of the important physical and biological components of a given 

fifth-field watershed, and how the project or management action maintains the existing 

condition or restores it toward that range of natural variability.” 

This alternative was eliminated from detailed study because it would not clarify 

documentation requirements and its essential elements are already included in an 

alternative under detailed consideration. 

Required Procedures for Cumulative Watershed Impact Analysis 

This alternative would add language to the ACS with specific requirements to use an 

equivalent roaded area (ERA) calculation for conducting cumulative watershed impact 

analysis. ERA analysis would be limited to watersheds of 5,000 - 15,000 acres. Projects 

with a low potential to affect water quality would be exempt from using the ERA 

calculation. 

This alternative was eliminated from detailed study because it is does not address the 

Purpose and Need to clarify language in the ACS. It would create an additional 

standard, which is not within the scope of this analysis. 

Creating standards and guidelines specifying use of a single model could 

unnecessarily constrain interdisciplinary teams or require analysis that is not useful or 

relevant. NEPA requires that environmental analyses use the best available 

information. Specifying a particular model in the standards and guidelines would 

force analysts to use the model even if better methods are available or lead to endless 

amendments as models are updated and refined. Also, agency direction on how and 

when to complete cumulative effects analysis is already available. 

29
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Add a 10-year Time Frame for Achieving ACS objectives 

Some groups suggested that a 10-year time frame for achievement of ACS objectives

should be added to standards and guidelines that refer to ACS objectives. This 

alternative was considered, but eliminated from detailed study because it would 

conflict with language on page B-9 of the Northwest Forest Plan Record of Decision 

that states: 

“...it may take decades, possibly more than a century, to accomplish all of [the 

ACS] objectives. Some improvements in aquatic ecosystems, however, can be 

expected in 10 to 20 years.” 

Requiring projects to achieve ACS objectives in a 10-year time frame could establish an 

unreasonable standard. For instance, restoration of some components of old-growth 

forest habitats is likely to take more than a decade to accomplish. 

Proposed Action Language Circulated for Scoping 

The original language described in the Notice of Intent and circulated for scoping was 

eliminated from detailed study because new language better responds to the Purpose 

and Need, based on internal and public comment. The language circulated for scoping 

was intended to meet the same needs, but was found to lack some important elements. 

These were included in the Proposed Action analyzed in the draft SEIS, specifically, 

the importance of analysis at the watershed and broader scales to provide context. 

Other Wording Suggestions 

Two specific language additions were suggested that would add the following 

standards and guidelines to the Record of Decision: 

Option 1: “Watershed 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. Once a watershed analysis is completed for a 

watershed, the project record for each project proposed in that watershed will 

demonstrate how the management activity is consistent with each of the Aquatic 

Conservation Strategy objectives, including a finding that the proposed project or 

management action maintains the existing condition or moves it within the range of 

natural variability.” 

30
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Option 2: “While some objectives can only be fully achieved at a watershed or 

landscape scale, each project must be analyzed for its consistency with each Aquatic 

Conservation Strategy objective, and must be found to be consistent with the standard 

specified in the Standard and Guideline (for example, must "attain" or "not retard or

prevent attainment.”) The analysis must culminate in a synthesized conclusion of 

overall ACS consistency that considers all of the ACS objectives relevant to a given 

action. The intent (of the ACS) is to ensure that a decision maker must find that the

proposed management activity is consistent with the Aquatic Conservation Strategy 

objectives. While some objectives can only be fully achieved at a watershed or 

landscape scale, each project, including projects or portions of projects not located 

within Riparian Reserves or Key Watersheds, must be found to be consistent with the 

ACS objectives. Projects that would retard or prevent attainment of these objectives 

would not comply with the ACS. The analysis must culminate in a synthesized 

conclusion of overall ACS consistency that considers all of the ACS objectives relevant

to a given action.” 

Both of these alternatives were eliminated from detailed study because they are very 

similar to the No Action alternative. 

Slight Changes to the Proposed Action 

The following alternative was suggested to replace a portion of B-10: 

"The four components of Aquatic Conservation Strategy (Riparian Reserves, Key 

Watersheds, watershed analysis and watershed restoration), in combination with 

application of pertinent standards and guidelines, are expected to maintain and restore 

ecosystem health in the long-term at the watershed and broader scales. No site-scale 

project can, or should be expected to achieve ACS objectives. To follow the ACS at the 

site-scale, decision makers must only demonstrate that projects comply with standards 

and guidelines in sections C and D. References to ACS objectives in the standards and 

guidelines in Sections C and D do not require that decision makers find that site-scale 

projects will attain ACS objectives. Some standards and guidelines refer to attaining,

being consistent with meeting, or achieving ACS objectives. The intent of these 

references is that projects will use relevant information from applicable watershed 

analysis to provide context for project planning. These references do not mean that 

decision makers must find that a site-scale project will necessarily attain, be consistent 

with, or meet ACS objectives.” 

This alternative was not considered for detailed study because it is very similar to the 

Proposed Action. 

 

31
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Amend Riparian Reserves Standards and Guidelines 

An alternative was considered to rewrite the Riparian Reserve standards and 

guidelines to clarify how land managers are to demonstrate that projects comply with 

them. The road management (RF-2) standards and guidelines (p. C-32) provide a 

model for how this alternative would be developed. These guidelines state: “For each 

existing or planned road, meet Aquatic Conservation Strategy objectives by:...” This 

alternative would apply that format to other standards and guidelines that refer to 

ACS objectives. 

The agencies did not develop this alternative for detailed study because of the risk of

deviation from the intent of the ACS inherent in a more extensive re-write. The need 

for action is limited to increased success planning and implementing projects that

follow existing Northwest Forest Plan principles. Amending the Riparian Reserve 

standards and guidelines would go beyond the scope of meeting this need. 

Eliminated References To The Management Direction In Attachment A As “Standards 

And Guidelines” 

The Northwest Forest Plan uses the term “standards and guidelines” in two different 

ways. One usage refers to specific guidance for each of the land allocations. The other 

usage refers to all management direction included in Attachment A to the ROD, 

including objectives, land allocations, and the ecological basis for the standards and

guidelines. 

 

An alternative was considered to eliminate references to the management direction in 

attachment A as “standards and guidelines” everywhere except within specific 

portions of Sections C and D. The Proposed Action eliminates some, but not all of 

these references. 

The agencies did not develop this alternative for detailed study because public 

comments to the Draft SEIS indicated a lack of public support for this approach. Many 

members of the public expressed that eliminating references to standards and 

guidelines as all of Attachment A would render the management direction in all 

sections but C and D unenforceable. Alternative A was developed to retain the 

existing references. 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Alternatives Compared

Table 2. Alternatives Compared by Decision Factors and Issues 

Decision Factor/ 

Issue 

No Action Proposed Action Alternative A 

Purpose and Need 

for Action Met 

No, ambiguous 

language remains, 

agencies experience 

difficulty 

demonstrating how 

projects follow the 

ACS 

Yes, ACS documentation 

requirements are 

clarified, success 

implementing projects is 

increased 

Same as Proposed 

Action 

Environmental 

Consequences 

More similar to 

Alternative 1 than

Alternative 9 in 

Northwest Forest 

Plan FSEIS 

More similar to 

Alternative 9 in the 

Northwest Forest Plan 

FSEIS 

Same as Proposed 

Action 

Changed Conditions No changed

conditions that affect 

1994 FSEIS findings 

Same as No Action Same as No Action 

Scale of Evaluation 

of ACS Objectives

Ambiguous direction Fifth- field watershed Fifth- field watershed 

Use of the Term 

Standards and 

Guidelines

Applies to all of 

Attachment A 

Applies solely to Sections 

C and D 

Same as No Action 

Role of ACS 

objectives

Have been 

interpreted as “hard 

set of criteria” that 

apply to project 

planning 

Clarifies that projects, in 

themselves cannot be 

expected to achieve ACS 

objectives 

Same as Proposed 

Action; retains 

language that projects 

should be designed to 

“maintain and restore” 

aquatic ecosystem 

health 

Risk of Changing 

the Original Intent 

of the ACS 

Greatest risk More risk Less risk 

33
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

34
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

CHAPTER 3&4. AFFECTED ENVIRONMENT AND 

ENVIRONMENTAL CONSEQUENCES 

Introduction 

Chapter 3&4 presents the analytical basis for the comparison of alternatives presented 

in Chapter 2. “Chapter 3&4” is so titled because it combines the Affected Environment 

and Environmental Consequences sections required by the National Environmental 

Policy Act. These chapters were combined in the FSEIS for the Northwest Forest Plan. 

Supplemental EISs are discussed at 40 CFR 1502.9 (c) “Agencies shall prepare 

supplements...if...the agency makes substantial changes in the Proposed Action that 

are relevant to environmental concerns.” This Supplemental EIS considers whether the 

Proposed Action or Alternative A will change the environmental components 

described in the 1994 Northwest Forest Plan FSEIS. The effects findings are considered 

in light of new information or events that have occurred since 1994. Appendix B 

provides a detailed review of the findings in Chapter 3&4 of the 1994 FSEIS. 

 

Affected Environment 

The Affected Environment section considers the events and actions that have occurred 

since 1994 that may be relevant to effects of the alternatives. 

First, the four components of the ACS are considered. Next, the timber sale program is 

discussed. Weather and natural disturbance events that have occurred since 1994 are 

considered. New listings under the Endangered Species Act and the Clean Water Act 

are also discussed. Monitoring accomplishments since 1994 are reviewed. Timber 

harvest on private land is considered. The Secure Rural Schools and Community SelfDetermination Act of 2000 was also considered as a changed condition. Other aspects 

of the affected environment as described in 1994 are incorporated by reference and 

briefly described in Appendix B. 

The Four Components of the Aquatic Conservation Strategy 

This section of the Final SEIS considers the four components of the Aquatic 

Conservation Strategy and agency actions since 1994 relative to these components. The 

following discussions and tables about the four components of the ACS are excerpted 

from the Biological Assessment in Appendix D. 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Riparian Reserves 

Interim Riparian Reserve widths (as described in the Northwest Forest Plan) were 

designed to provide a high level of fish and riparian protection until watershed and 

site-specific analysis could be completed. Limited adjustment of the interim Riparian 

Reserve widths has occurred over the past ten years. Acreage has increased in the

Riparian Reserves since 1994 due to updated information on the extent of this 

allocation. 

Standards and guidelines have been established for Riparian Reserves, Key 

Watersheds, Designated Areas and Matrix, Late-Successional Reserves, Adaptive 

Management Areas, Managed Late-Successional Areas, and Administratively 

Withdrawn Areas. While not all of the standards and guidelines are aimed at 

protecting riparian-dependent resources, some of those that largely target conservation 

of terrestrial habitat will indirectly benefit riparian-dependent resources. For example,

in Late-Successional Reserves, no harvest is allowed in stands over 80 years old west of 

the Cascades (110 years in the Northern Coast Range Adaptive Management Area) 

(USDA and USDI 1994b at p. C-12) and road construction is not recommended unless

potential benefits exceed the costs of habitat impairment (Northwest Forest Plan 

Record of Decision at p. C-16). This will result in fewer ground-disturbing activities

and their potential effects on aquatic and riparian habitat. The agencies have complied 

with standards and guidelines as demonstrated by implementation monitoring results 

between 1996-2001. Detailed information about monitoring results is in the Biological 

Assessment in Appendix D. 

Key Watersheds 

The Northwest Forest Plan established Key Watersheds to provide high water quality 

and refugia for at-risk fish species. Standards and guidelines specific to Key 

Watersheds are summarized on page C-7 of the Record of Decision. Key Watersheds 

have the highest priority for watershed restoration and require Watershed Analysis 

before activities may occur. 

Road decommissioning is a priority in Key Watersheds. Implementation monitoring 

reports for the years 1999, 2000, and 2001 evaluated the status of road mileage in Key 

Watersheds. The trend has been a reduction in total road miles in Key Watersheds. 

36
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Of seven Key Watersheds reviewed for the 1999 report, six had avoided road 

construction, six had reduced road mileage, and one had maintained road mileage. Of 

approximately 1,861 system road miles existing in 1994, 84 miles had been

decommissioned and 13.3 new miles had been constructed, a net reduction of 70.7 

miles, at a ratio of 6.3 to 1. For non-system roads, 11.9 miles had been decommissioned 

while 10.9 miles had been constructed, for a net reduction of 1.0 mile (Regional 

Implementation Monitoring Team 1999). 

There was a net reduction of 82.2 miles (4%) of system roads in 12 Key Watersheds

reported in the 2000 implementation monitoring report (Regional Implementation 

Monitoring Team 2000). The ratio of miles of road decommissioned to miles of road 

constructed was 9.6 to 1 (91.8 miles to 9.6 miles). Information was not available for 

status of non-system roads in six of the Key Watersheds. A net reduction of 11.3 miles 

(5.9%) occurred in the other six Key Watersheds. The ratio of miles decommissioned to 

miles of road constructed was 2 to 1 (23 miles to 11.7 miles). 

System road mileages were reduced by 195.4 miles (11%) in 12 Key Watersheds 

evaluated for the 2001 implementation monitoring report (Regional Implementation 

Monitoring Team 2001). The ratio of miles of road decommissioned to miles of road 

constructed was 90 to 1 (197.7 miles to 2.2 miles). The 2001 implementation monitoring 

effort did not report on non-system road mileage status for the Key Watersheds. 

The status of road mileage in the 31 Key Watersheds evaluated by the Regional 

Implementation Monitoring Team is likely representative of Key Watersheds 

throughout the Northwest Forest Plan area. There has been an aggressive effort to 

reduce road mileage by road decommissioning, while new road construction has been 

extremely limited. 

Road decommissioning has had positive benefits to the aquatic health of the Key 

Watersheds. The potential for catastrophic introduction of sediment if a culvert 

becomes plugged and the road prism fails is reduced. The concentration of flows by 

road segments augmenting the stream network is reduced. Chronic sediment delivery 

from native surface roads, fill slopes, and cut slopes has also been reduced. 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Watershed Analysis 

Watershed Analysis has been completed by the administrative units for the majority of 

Key Watersheds in the Northwest Forest Plan area. Watershed analyses have been 

completed for all of the Key Watersheds on 19 administrative units (see Table 4). Six

administrative units have completed watershed analyses for most (67-91 percent) of 

their Key Watershed areas. Small federal land ownership, lack of cooperators, and/or 

lack of project activity made these key watersheds a low priority for Watershed 

Analysis. 

Watershed analyses have been completed for the vast majority of the inventoried 

roadless areas in the Northwest Forest Plan area. Inventoried roadless areas occur only 

on National Forest lands in the Northwest Forest Plan area. Watershed analyses have 

been completed for 100% of the inventoried roadless areas in non-Key Watersheds on 

10 administrative units. Eight administrative units have not completed watershed 

analyses for inventoried roadless areas in non-Key Watersheds. 

Like Key Watersheds, Watershed Analysis is a low priority for many inventoried 

roadless areas in non-Key Watersheds due to small federal land ownership, lack of 

cooperators, land allocation designation, and/or lack of planned project activity. Data 

was not collected for the Modoc and Lassen National Forests. 

Watershed Restoration 

Watershed restoration results were reviewed for the years 1994 – 2001. Table 5 

describes these achievements. The Klamath, Mendocino, Six Rivers, Shasta-Trinity 

National Forest and the Arcata, Redding and Ukiah BLM District accomplishments 

between 1994 and 2001. The other units display information only since 1998 (1994-1998 

accomplishments are available in previously published documents). The values for 

Arcata administrative unit include the King Range National Conservation Area. 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Table 3. Watershed Analysis Accomplishments 

Administrative Unit Federal Land Area with

Completed Watershed 

Analyses (%) 

Key Watershed Area with 

Completed Watershed 

Analyses (%) 

Columbia River Gorge 

National Scenic Area 

83.3 Not Applicable

Deschutes 82.9 100

Gifford Pinchot 99.1 100 

Klamath 71 86

Lassen No Data No Data 

Mendocino 93.1 100

Modoc No Data No Data 

Mount Baker 

Snoqualmie

66.2 71

Mount Hood 100 100 

Okanogan 100 100

Olympic 80.4 91

Rogue River 100 100 

Six Rivers 80.7 85 

Siskiyou 99.9 100

Shasta-Trinity 56.4 100

Siuslaw 98 100

Umpqua 98.5 82

Wenatchee 100 100

Willamette 100 100

Winema 55.7 100

Arcata 33.5 67

Coos Bay 93.1 100 

Eugene 96.1 100

Klamath Falls 100 100 

Medford 93 100

Redding 43.6 100

Roseburg 100 100

Salem 97.1 100

Ukiah 37 Not Applicable

Source: Biological Assessment (Appendix D) 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Table 4. Aquatic Restoration Accomplishments 1998-2001. 

Administrative

Unit 

Instream 

Structures

(mi.) 

Instream 

Passage (mi.) 

Riparian 

(ac.) 

Riparian 

(mi.) 

Upland 

(ac.) 

 Road 

Decom. 

(ni)

Road 

Improved 

(mi.) 

Wetland

Fresh 

(ac.) 

Columbia

River Gorge 

NSA 

3 0 375 0 0 6 3 137

Deschutes 26.3 0.7 513 30.5 529 104.3 15.4 207

Gifford

Pinchot 

178.3 1.1 1508 21.7 11 285.8 193.3 0

Klamath 325 ND ND ND 2907 136.2 ND ND

Lassen ND ND ND ND ND ND ND ND

Mendocino 67 ND ND ND 567 62 ND ND

Modoc ND ND ND ND ND ND ND ND

Mount Baker

Snoqualmie 

8.4 0.5 13 0 1 54.4 137.6 0

Mount Hood 50.3 24.1 176 13.3 309 42.4 16.1 4

Okanogan 0.6 0.2 15 1.3 47 24.2 19.2 0

Olympic 0.8 4.3 82 9.9 368 46.7 33.9 0

Rogue River 44.5 55 628 0 99 26.5 12.9 1

Six Rivers 120 ND ND ND 711 137 ND ND

Siskiyou 62.8 39 2833 0 0 57.7 0 0

ShastaTrinity 

244 ND ND ND 1980 112.4 ND ND

Siuslaw 40.2 0 70 1.9 0 34.4 10.6 0

Umpqua 12.3 3 11 2.3 4099 85.6 110 0

Wenatchee 8.3 27 337 63.6 4 91.9 92.2 18

Willamette 18 0 613 38.7 1784 43.4 65.1 7

Winema 0.3 0 0 0 1 150.1 0.2 0

Arcata ND ND ND ND ND 33.5 ND ND

Coos Bay 12.2 25.1 1533 0.3 0 28.8 2.1 0

Eugene 7.7 8.2 11 3.1 0 5.3 0.9 0

ND = No Data 

Source: Biological Assessment (Appendix D) 

40
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

The Timber Sale Program 

The proposed amendment has the potential to affect agency success implementing the 

timber sale program. An indicator of success in implementing this program is the 

likelihood of the agencies to offer timber toward meeting the “Probable Sale Quantity.” 

The Northwest Forest Plan established the term Probable Sale Quantity (PSQ) for 

estimates of average annual timber sale levels likely to be achieved. The Northwest 

Forest Plan used the term PSQ to acknowledge inherent uncertainties in the estimates 

(Johnson et al. 1993). The Northwest Forest Plan FSEIS (Chapter 3&4, p. 267) 

addressed the potential for the PSQ to change as National Forest and BLM District 

plans were completed or revised: 

“Sustainable sale estimates will be made using more refined data and 

procedures available when Draft Forest and District Plans are completed or 

current plans are revised.” 

The Northwest Forest Plan FSEIS (Chapter 3&4, pp. 266 and 268) estimated the PSQ at 

958 million board feet (MMBF), plus an additional 10 percent volume estimated in 

“other wood” (cull, sub-merchantable, firewood, and other products) for a total of 1.1

billion board feet. 

By 1998, PSQ across the Northwest Forest Plan area was reduced by 15 percent, to 805 

MMBF. Revised Riparian Reserve acreage estimates at the local administrative unit 

level were the single largest factor for the reductions in PSQ.

The Northwest Forest Plan assumed that 90 percent of the early decades PSQ would 

come from late-successional and old-growth forest, much of it through regeneration 

harvest. Individual Resource Management Plans outline assumptions for the amount 

and timing of silvicultural prescriptions such as thinning, partial cutting, and 

regeneration harvesting. The planning assumptions are based on the type of forests 

and the mix of older and younger forests available for harvest within each

administrative unit. 

Achievement of current PSQs for the individual administrative units, and for the 

Northwest Forest Plan area as a whole, are contingent on the ability to implement the 

range of silvicultural prescriptions outlined in individual Resource Management Plans. 

The agencies have not been able to implement the range of projects across the

Northwest Forest Plan area partly because of the court interpretations in the PCFFA v

NMFS litigation. 

41
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

The agencies’ annual timber sale offerings are shown in Figure 2. Between 1999 and 

2002, the agencies offerings ranged from 148 to 400 million board feet per year. The 

reduction in sale offerings are the result of appeals and protests on individual projects, 

enjoined biological opinions in PCFFA v. NMFS litigation and the agencies’ response

to the litigation, and implementation of the Survey and Manage mitigation measures, 

among other reasons. Under the Preferred Alternative in the 2003 Survey and Manage 

Draft SEIS (USDA, USDI 2003), agencies are expected to come closer to meeting the 

PSQ. 

The Oregon BLM regeneration harvest timber sales sold during fiscal years 1999-2001

were reduced by 89 percent when compared to the fiscal year 1995-1998 timeframe. 

Regeneration harvest sales of stands 200 years and older was reduced by 88 percent 

during this timeframe. The 1995-1998 timber sales were 22 percent less than the 

harvest assumptions under the Northwest Forest Plan (source: BLM Annual Program

Summaries). 

Figure 2. Timber Sale Volume Offered in Comparison to PSQ, 1995-2002 

The following example shows the connection between the PCFFA litigation and the 

ability to meet the adjusted PSQ associated with Alternative 9. In Fiscal Years 2001, 

2002, and 2003, the Oregon BLM provided interim guidance on how to prepare and 

offer timber sales, given the uncertainty resulting from the PCFFA litigation. The most 

recent BLM Information Bulletin of the three (IB-OR-2003-026) stated: 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

“The nature of the situation dictates the development of a FY 2003 Timber Sale 

Plan that continues to place interim emphasis on partial cuts. This emphasis (a 

continuing interim strategy) is driven by circumstances in an attempt to

effectively utilize appropriated funds and implement the Allowable Sale 

Quantity (ASQ) and socioeconomic objectives of the [Northwest Forest Plan] to 

the maximum extent possible. It is anticipated that as the current challenges 

are resolved, the emphasis for balanced [Northwest Forest Plan] 

implementation, i.e., partial cuts, regeneration cuts, restoration as a 

requirement of timber sale contracts, etc., will resume.” 

These interim guidelines are not considered BLM policy, but they do indicate how the 

BLM has responded to the current uncertainty. If the BLM’s interim approach were to 

be carried out over time, harvest levels more like Alternative 1 in the Northwest Forest 

Plan would be likely. 

Monitoring and Adaptive Management 

Monitoring and evaluation occurs as part of every Resource Management Plan. Many

project-level decisions also include monitoring and adaptive management plans. Each 

National Forest and BLM District publishes monitoring results relevant to 

implementation of their respective Resource Management Plans. Project plans include 

monitoring to ensure they are implemented as planned. 

The Northwest Forest Plan Record of Decision, Attachment A, Section E provides for a 

monitoring plan. This plan has been implemented: since 1996, implementation and 

effectiveness of the ACS across the Northwest Forest Plan area has been assessed 

through the Interagency Regional Program. This program conducts broad-scale 

monitoring on federally managed lands within the Northwest Forest Plan area and 

represents the combined monitoring efforts of eight federal agencies and partnerships 

with state agencies and academic institutions. 

The 2001 field season marked the sixth consecutive year of the Northwest Forest Plan 

implementation monitoring program. This program is designed to determine whether 

the Record of Decision and its corresponding standards and guidelines are consistently 

followed across the Northwest Forest Plan area. Overall, compliance in meeting the 

Northwest Forest Plan standards and guidelines was 98 percent for the 21 projects and 

watersheds monitored in 2001 (Regional Implementation Monitoring Team 2001).

43
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Detailed implementation monitoring results are available in the Biological Assessment 

and in individual monitoring reports. Other ongoing efforts to evaluate the 

effectiveness of the ACS at watershed and broader scales include the Aquatic Riparian

Effectiveness Monitoring Plan (AREMP), which was approved in March 2001 and 

published in 2003 (Reeves et al. 2003). Under the AREMP, the condition of various 

watersheds across the Northwest Forest Plan area will be evaluated. Over time, 

AREMP will show whether watershed conditions are improving. The AREMP will 

provide information in a decade or more at the province scale. 

The authors of the Aquatic Conservation Strategy stated that: 

“We emphasize, however, that it will require time for this strategy to work. 

Because it is based on natural disturbance processes, it may take decades to

over a century to accomplish all of its objectives.” 

The Northwest Forest Plan also requires adaptive management. Adaptive 

management is a continuing process of action-based planning, monitoring, 

researching, evaluating, and adjusting with the objective of improving the 

implementation and achieving the goals of Alternative 9. Under the concept of 

adaptive management, new information will be evaluated and a decision will be made 

whether to make adjustments. Agencies will use monitoring results associated with 

individual unit plans to guide future actions. The watershed analysis process 

encourages informal updates as new information becomes available. Updated 

watershed analyses are likely to be an important future source of monitoring 

information. 

Recent water quality monitoring reports have been published in Oregon.8 The 

“Oregon State of the Environment Report 2000” describes the conditions and trends of

Oregon’s environment and suggests ecosystem indicators to help track environmental 

progress in the state. The Oregon Department of Environmental Quality used 129 

ambient monitoring stations to develop the Oregon Water Quality Index Summary 

Report for Water Years 1992 – 2001 (Cude 2001). Water quality increased at 66 sites,

decreased at 7 sites, and stayed the same at 56 sites. 

 8 Similar data are not available for California and Washington. 

44
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Potential Changed Conditions to the Affected Environment 

The agencies considered whether large wildland fires (and subsequent rehabilitation 

and salvage activities), floods, (and subsequent rehabilitation and restoration 

activities), droughts or El Niño weather patterns occurring since 1994 changed the

Affected Environment of Environmental Consequences described in FEMAT report or 

the Northwest Forest Plan FSEIS. These natural episodic disturbance events are an 

integral part of process-based management contained in the Aquatic Conservation 

Strategy. As stated in the FEMAT report (p. V-29) and the Northwest Forest Plan 

FSEIS (p. B-81): 

“The heart of the approach is the recognition that fish and aquatic organisms 

evolved within a dynamic environment.” 

The Northwest Forest Plan provided an adaptive management approach to 

environmental conditions and events. The Northwest Forest Plan recognized that

ecosystems are not static but are ever changing in response to conditions and events.

The agencies determined that large fires, flood, drought, and El Niño events occurring 

since 1994 are not changed conditions that would invalidate the four components of 

the ACS (watershed analysis, watershed restoration, Key Watersheds, Riparian 

Reserves). The Northwest Forest Plan and Aquatic Conservation Strategy require 

consideration of natural disturbances in land management decisions. The events 

occurring since 1994 are factored into the planning process at all scales. The agencies

have responded to events such as fires and floods with appropriate action that follows 

Northwest Forest Plan principles. Further information about potential changed 

conditions is in Appendix E. 

New Listings under Endangered Species Act and Clean Water Act 

Some people have suggested that new listings of fish under the Endangered Species 

Act, or new listings of streams as water quality impaired under the Clean Water Act, 

are changed conditions that may trigger a reconsideration of the Northwest Forest 

Plan. 

The Northwest Forest Plan considered effects on 259 species of fish. 

The Riparian Reserves were widened in Alternative 9 to increase the probability that 

viability of at-risk fish species would be maintained. Probability of maintaining 

viability of at-risk fish species increased from 65 percent to 80 percent due to the

increased Riparian Reserve widths. 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Approximately 20 species of fish have been proposed for listing, or listed under the 

Endangered Species Act since 1994.9 The Northwest Forest Plan anticipated 

Endangered Species Act listings (FSEIS Chapter 3&4 p. 202): 

“...the [Aquatic Conservation] strategy can succeed at maintaining and 

restoring aquatic and riparian habitats regardless of what happens on nonFederal lands, but that would not ensure the population viability of many of the 

fish stocks evaluated in the SEIS. For these reasons, it is not possible to 

determine whether any of the alternatives in the SEIS would preclude listing of 

fish species under the Endangered Species Act.” 

Nancy Foster, Ph.D., Acting Assistant Administrator for NMFS, wrote a comment 

letter to the Northwest Forest Plan Draft SEIS. In her letter, Dr. Foster wrote: 

“The relatively large Riparian Reserves...combined with the requirements to 

conduct watershed analysis prior to any resource management activities and to 

implement comprehensive watershed restoration to accelerate habitat recovery, 

could avoid harm to anadromous fish in many watersheds throughout the 

range of the northern spotted owl.”

Ten consultations and/or conferences with the NOAA Fisheries or USFWS have 

occurred related to 28 Resource Management Plans within the Northwest Forest Plan

area. There have been no significant changes to the Resource Management Plans since 

the dates of the Plan-level consultations and conferences. The effects of implementing 

the Resource Management Plans have not materially changed since the issuance of the 

Plan-level Biological and Conference Opinions. The Biological Assessment 

summarizes the history of Endangered Species Act consultation related to these

species. 

Approximately 83 sub-basins within the Northwest Forest Plan area contain streams 

that have been listed as impaired because of high water temperature and/or sediment 

loads. Several of these listings have occurred since 1994. This increase in listed waters

is not necessarily related to an increase in degraded conditions. 

 9 See Appendix D for current Endangered Species Lists. 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Since 1994, an intense effort has been underway to collect water quality information 

about streams that were not previously monitored. The increase in temperature 

listings has occurred in part because of widespread availability of inexpensive 

technology that can capture continuous, high quality water temperature data. 

Appendix F, p. 173 of the Northwest Forest Plan FSEIS notes that: 

“Not all areas have been inventoried to cover all riparian and aquatic systems 

on federal lands within the range of the northern spotted owl.” 

Judge William Dwyer ruled on whether the new listings under the Endangered Species 

Act and Clean Water Act constitute changed conditions under the Northwest Forest 

Plan: 

“The claims regarding certain fish and the declining water quality of streams 

relates not to new data but to changes in legal status under the Endangered 

Species Act and...the Clean Water Act; while these listings are important, they 

do not, in themselves, require a new SEIS.”10

Timber Harvest on Non-Federal Land 

Timber harvest on non-federal land was considered as a possible changed condition. 

The Northwest Forest Plan FSEIS acknowledged that state timber harvest rules might 

not be consistent with rules guiding harvest on federal lands. Harvests on non-federal 

lands were assumed in the 1994 FSEIS. The FSEIS stated that the choice of alternatives 

in the Northwest Forest Plan would not affect the rate of harvest on non-federal lands. 

Generally, the effects analysis assumed that non-federal timberlands would be 

harvested to the extent allowed by state law. Therefore, timber harvesting on nonfederal lands since 1994 is not a changed condition and does not invalidate Northwest 

Forest Plan findings and assumptions. 

Secure Rural Schools and Community Self-Determination Act of 2000 

In 2000, the Secure Rural Schools and Community Self-Determination Act was signed. 

Under the Act, counties within the Northwest Forest Plan area elected to receive a 

guaranteed level of payment, instead of payments that are a direct percentage of 

federal receipts. Northwest Forest Plan FSEIS findings related to county payments 

may no longer be accurate. 

 10 ONRC Action v United States Forest Service Civ. No. 98-942 WD, August 2, 1999, p 17):

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Environmental Consequences 

Effects on the Four Components of the ACS 

None of the alternatives would change any component of the ACS, nor would any 

alternative change the role of Riparian Reserves. Riparian-dependent resources would 

continue to receive primary emphasis and Riparian Reserve standards and guidelines 

would continue to be applied under all alternatives. Under all alternatives, the role,

extent or standards and guidelines for Key Watersheds would not change. Watershed 

restoration would continue to occur under all alternatives. 

The proposed amendment would clarify the documentation needed to comply with 

standards and guidelines that refer to not retarding or preventing, attaining, being 

consistent with, meeting or achieving ACS objectives. The proposed amendment 

would clarify that each project cannot be expected to achieve watershed-scale 

objectives. The amendment clarifies that short-term, site-level disturbance does not

necessarily retard achievement of the watershed-scale objectives. The proposed 

amendment clarifies the documentation requirements expected of land managers. 

The role of Watershed Analysis will not change in any of the alternatives. The 

direction related to Watershed Analysis in the proposed amendment is consistent with 

the 1995 Federal Guide for Watershed Analysis. Alternative A explicitly notes that if 

watershed analysis is not required or available, or does not contain relevant 

information, the project record will provide evidence that project effects were 

considered relative to the watershed condition. 

The Proposed Action and Alternative A are both intended to contribute to agency 

success planning and implementing projects that follow Northwest Forest Plan 

principles, but are not intended to result in site-specific project design changes. 

Agencies will continue to attempt to implement the Resource Management Plans and 

attain their goals under all alternatives. 

The assumptions of the benefits to fish and aquatic resources based upon the extent of

Riparian Reserves as originally envisioned remain valid. 

Changes have been proposed to the Survey and Manage program, changes have been

proposed for the Forest Service planning rule (36 CFR 219), changes have been 

approved to the Forest Service appeal rule (36 CFR 215), and changes have been 

approved for categorical exclusions for both agencies. None of these changes would 

affect documentation requirements related to the ACS. None of these changes would 

change the components of the ACS. 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

The No Action alternative is associated with the greatest risk of not meeting the 

original intent of the ACS. This is because the existing language has been interpreted 

to imply too simplistic a relationship between projects and attainment of ACS 

objectives. The No Action alternative remains ambiguous about the scale at which 

progress toward attainment of ACS objectives is properly assessed. 

The Proposed Action has the second greatest risk of not meeting the original intent of 

the ACS. The Proposed Action would clarify aspects of the ACS that are ambiguous 

under No Action. However, many members of the public expressed concern that the 

Proposed Action might result in unintended consequences that might deviate from the 

original intent of the ACS. Specifically, passages that refer to all of Northwest Forest 

Plan Record of Decision Attachment A as “standards and guidelines” would be 

removed, and a sentence that says “complying with the ACS means that an agency 

must manage riparian-dependent resources to maintain the existing condition or 

implement action to restore conditions.” 

Alternative A has the least risk of not meeting the original intent of the ACS. 

Alternative A clarifies the proper scales for evaluation of progress toward attainment 

of ACS objectives. However, Alternative A retains the passages that refer to all of 

Attachment A as management direction, and includes a sentence that states: “Under 

the Aquatic Conservation Strategy, the agencies must maintain existing conditions or 

implement actions to restore conditions at the fifth-field watershed scale over the long 

term.” 

Effects on the Timber Sale Program 

The proposed amendment has the potential to affect agency success implementing the 

timber sale program envisioned under the Northwest Forest Plan. Timber sales are

needed to achieve the socio-economic and ecosystem management goals of the 

Northwest Forest Plan. The degree to which current PSQs may be attained is the 

primary indicator for agency success in this regard. 

As discussed under Affected Environment, the agencies have not been able to achieve 

the level of timber sales predicted for the Northwest Forest Plan. The Northwest 

Forest Plan assumed that 90 percent of the early decades PSQ would come from latesuccessional and old-growth forest, much of it through regeneration harvest. 

However, given the court interpretations of the ACS in the PCFFA litigation, the PSQ 

cannot be sustained, because few timber sales can be designed to avoid all disturbance 

to aquatic and/or riparian habitat components. 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

For instance, timber harvest removes canopy and exposes some land to accelerated 

erosion. Road work associated with the timber sale may result in short-term 

sedimentation. In the PCFFA litigation, the court considered these types of effects 

incompatible with achieving ACS objectives. 

Future timber Sale levels under No Action are not precisely known. The agencies are 

funded to implement projects that follow Northwest Forest Plan principles, including 

timber sales. Their success implementing these projects has been hindered by current 

ACS interpretations. 

In this regard, expected future harvest levels under No Action are more like harvest 

levels in Alternative 1 in the Northwest Forest Plan FSEIS. Under Alternative 1, 

“essentially all old-growth forests would be protected; forests adjacent to streams 

would receive significant protection to protect fish; and...some forest cover would be 

retained in areas where timber harvest is allowed.” 

Several public comments noted that protection of all old-growth forests is critical to 

achieving ACS objectives. This belief is not supported by the Northwest Forest Plan 

Record of Decision, which approved both the ACS and a timber program that expected 

harvest within some old-growth forest stands. 

Alternative 1 would have resulted in a long-term PSQ that is less than one-tenth of the 

PSQ predicted for Alternative 9. Under No Action, timber sale levels are likely to 

fluctuate, but would likely drop over time. Without regeneration harvest and harvest 

within older forest stands, expected levels of harvest on non-reserved lands would not 

be sustainable. 

As the BLM Information Bulletin demonstrates (see Appendix A), the agencies have 

been compelled to concentrate their efforts on offering timber in stands where 

commercial thinning opportunities exist. These opportunities will eventually 

diminish. Without regeneration harvests, timber Sale levels could approach 

Alternative 1 (in the 1994 FSEIS). 

The degree to which the Proposed Action or Alternative A could attain PSQ associated

with Alternative 9 (and adjusted in individual RMPs) cannot be predicted precisely. 

Groups who believe that timber sales within late-successional and old-growth forests 

are incompatible with the ACS are likely to continue to initiate appeals and litigation. 

The agencies believe that such harvest can be compatible with the ACS, as evidenced 

by the Northwest Forest Plan Record of Decision and supporting documentation, 

which included both the ACS and harvest within late-successional and old-growth 

forest in Matrix lands. Other factors besides ability to harvest within late-successional 

and old-growth forests may affect the agencies’ ability to attain PSQ. 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Land managers are expected to be more successful planning and implementing timber 

sales that follow Northwest Forest Plan principles under the Proposed Action and 

Alternative A because these alternatives clarify the documentation requirements to 

demonstrate that projects follow the ACS. This clarification is expected to result in the 

range of silvicultural prescriptions outlined in individual Resource Management Plans. 

The agencies acknowledge the uncertainty about the degree to which the alternatives 

will result in the desired harvest levels. The NEPA regulations at 40 CFR 1502.22 

provide guidance: “If, when evaluating significant adverse effects on the human 

environment, information essential to a reasoned choice among alternatives is either 

missing or incomplete...” The agencies do not believe that any alternative would 

result in adverse effects beyond those already considered in the Northwest Forest Plan 

FSEIS in 1994. All of the alternatives would result in impacts within the range 

predicted in 1994. Frequently, the 1994 Northwest Forest Plan FSEIS lumps 

Alternatives 1 and 9 in reference to effects on aquatic ecosystems. 

The agencies considered the potential changed conditions and monitoring results, 

along with a review of the science related to the Northwest Forest Plan to make this 

determination. Thus, the uncertainty about how well each would meet predetermined Northwest Forest Plan goals would not result in significant adverse effects 

that were not already considered in 1994. 

Neither the Proposed Action nor Alternative A would directly affect timber sales 

covered under biological opinions that were enjoined in PCFFA v. NMFS. New 

biological opinions would have to be issued by NOAA Fisheries before these projects

could be implemented. NOAA Fisheries and the USFWS have developed new 

approaches to consultation that do not rely on the ACS as a surrogate for Endangered

Species Act jeopardy analysis. 

Cumulative Effects on the Timber Sale Program 

Changes have been proposed for the Forest Service planning rule (36 CFR 219), 

changes have been approved to the Forest Service appeal rule (36 CFR 215), and 

changes have been approved for categorical exclusions for both agencies. None of 

these changes would affect the design of projects that follow Northwest Forest Plan 

principles. None of the rule changes seek to increase PSQ associated with Alternative 9 

(as adjusted in individual Resource Management Plans - RMPS) but they are likely to 

contribute to agency success meeting the PSQ. 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Currently, the agencies are also considering further modification/elimination of the 

Survey and Manage mitigation measures in response to litigation. The effects of 

further modifications to the Survey and Manage mitigation measures are disclosed in a 

separate SEIS. The Preferred Alternative in the 2003 Draft SEIS for Survey and Manage 

would help increase agency success planning and implementing projects that follow 

Northwest Forest Plan principles. The changes do not seek to increase PSQ relative to 

Alternative 9, but is likely to contribute to agency success meeting the PSQs for 

individual RMPs. 

A recent settlement agreement on a lawsuit pertaining to the federal timber sale 

program on Oregon and California (O&C) railroad lands reinforces the agencies’ 

commitment to meeting PSQ. Under the settlement agreement, the FS and BLM 

agreed to attempt to meet PSQ in Matrix lands and increase restoration thinning in 

reserves as part of the settlement agreement. Individual Resource Management Plans 

will need to consider the role of O&C lands and determine future timber Sale levels. 

This settlement will not increase PSQ in the foreseeable future. 

Effects on Other Activities that Implement the Northwest Forest Plan 

As discussed in Chapter 1, several types of projects have the potential to be stopped or 

delayed due to current interpretations of the ACS. The language that has resulted in 

difficulty producing timber sales has also resulted in difficulty implementing the other 

types of projects. As stated in Chapter 1, the agencies plan and implement integrated

projects; watershed restoration is often coupled with timber sales. Habitat conditions 

within Riparian Reserves have improved through precommercial and commercial 

thinning to promote more rapid development of large conifers for large woody debris 

recruitment and shade. Stream restoration work to restore habitat complexity, such as 

large wood placement or creation of off-channel rearing habitat, has also been 

accomplished. Any projects that are connected to timber sales could be stopped or 

delayed as described above. 

Besides timber harvest, types of projects that could be hindered by impossible 

expectations include: 

• Non-commercial forest management 

• Actions associated with timber harvest, including transportation system

treatments, culvert removal and replacement. 

• Restoration silviculture in Riparian and Late-Successional Reserves, hazardous 

fuels reduction and forest health thinning, especially projects that include an 

element of commercial harvesting. 

• Special uses, mining, livestock grazing, and recreation. 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

• Watershed restoration projects such as stream enhancements, fish passage 

improvements, and road decommissioning.11

The Northwest Forest Plan did not include predictions of levels of achievement of any 

of these activities. The O&C settlement establishes a volume of timber to be produced 

from thinning within reserves; this implies a certain level of accomplishment. 

Under No Action, the agencies would continue to plan projects that follow Northwest 

Forest Plan principles. These projects would be designed to comply with applicable

standards and guidelines and contribute to meeting Resource Management Plan goals 

and objectives. Any of these projects could be subject to ambiguous expectations if 

they have any possible effects on the aquatic environment. 

In general, the agencies expect to be more successful planning and implementing all 

types of projects that follow Northwest Forest Plan principles under the proposed 

amendment. The proposed amendment would clarify the documentation needed to 

demonstrate compliance with standards and guidelines. 

Environmental Effects of No Action 

The precise environmental effects of No Action are not known. Site-specific analysis 

under NEPA would continue to occur for all proposed projects. As discussed 

previously, agencies would continue to plan projects that follow Northwest Forest Plan 

principles (Alternative 9). Managers would attempt to implement their respective 

Resource Management Plans. However, some of these projects would be subject to 

ACS interpretations that may delay or stop the project. Based on public comments 

received on the Draft SEIS, the projects most likely to be stopped or delayed include an 

element of timber harvest within late-successional and old-growth forest. 

The comments state that “faithful implementation of the ACS” would exclude such

harvest. Given these attitudes, land managers would be encouraged to avoid such 

harvests (see BLM Information Bulletin for example of “interim” direction). In this

regard, the results of No Action would more likely result in harvest levels (and 

environmental effects) more like Alternative 1. 

 

11 Other examples of restoration projects include (but are not limited to) prescribed burning, underplanting, snag 

and down wood management, invasive weed control. See Appendix D (Biological Evaluation) for further 

discussion about various categories of federal actions generically authorized in Resource Management Plans. 

53
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

An ironic result of PCFFA v. NMFS is that federal timber sale planners have become 

reluctant to include restoration work in proposed timber sale projects if the restoration 

work may result in disturbance to aquatic or riparian habitats and triggers the need for 

Endangered Species Act consultation. Under No Action, projects with any short-term 

impact could have the potential to be stopped or delayed due to ACS 

misinterpretations, appeals, and litigation. In the short term, delaying or avoiding 

projects could have some positive benefits on the physical and biological environment, 

since the risk of short-term adverse effects from the projects would be reduced or 

eliminated. However, opportunities to restore watersheds through cumulative action 

over time could be foregone. 

Fuels management projects, especially those that include an element of commercial 

harvesting, could be stopped or delayed due to ACS interpretations. Implementation

of these projects is needed to achieve goals of the National Fire Plan. If the ACS 

interpretation results in delayed implementation of fuels reduction projects, the risk of 

adverse effects of wildland fire could increase. 

 

Delays in restoration can have negative longer-term consequences to aquatic 

ecosystems. Under No Action, less active restoration would likely occur than under 

the Proposed Action. Reduced levels of restoration could reduce the rate of watershed 

recovery. Reductions and delays in project implementation could lead to increased risk 

of ongoing and catastrophic adverse effects from road failure and landslides. 

Appendix V-J of the FEMAT report stated that processes that have degraded 

watersheds would not be reversed without a comprehensive restoration program. 

Over the long-term, No Action would likely have physical and biological effects that

are more similar to Alternative 1 in the Northwest Forest Plan than Alternative 9. 

Frequently, the Northwest Forest Plan FSEIS lumped Alternatives 1 and 9 in reference 

to effects on aquatic ecosystems, because both of these alternatives included large 

Riparian Reserves and the Aquatic Conservation Strategy (see Appendix B). No 

Action is more like Alternative 1 to the extent fewer projects would likely be 

implemented. 

Socio-economic Effects of No Action 

 

FEMAT and the 1994 FSEIS include detailed socio-economic analysis, which is not reevaluated here. This evaluation focuses on conditions related to timber harvest since 

1999 and the 2000 Secure Rural Schools and Community Self-Determination Act. 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

As described previously, timber harvest levels expected under No Action are closer to 

levels predicted for Alternative 1 (in the 1994 FSEIS) than Alternative 9. Appendix B 

demonstrates that as a result of the reduced harvest levels, the No Action alternative 

would have socio-economic effects more similar to Alternative 1 than Alternative 9. 

One difference between the 1994 analysis and the current situation is the de-linking of 

payments to counties from federal timber sale levels. In the past, a percentage of 

proceeds from timber sales on federal lands were paid to counties in lieu of taxes. 

These payments have declined over time as timber harvest has declined (see 1994 

FSEIS for detailed discussion). In 2000, the Secure Rural Schools and Community SelfDetermination Act was signed. The Act allowed counties to choose a guaranteed level 

of payments, rather than payments based on timber harvests. These payments are 

higher (on average) than assumptions made in 1994. Effects on counties (i.e. schools, 

roads, etc.) are more affected by laws such as the Secure Rural Schools Act than any of 

the ACS SEIS alternatives. Further information about payments to counties is in the

analysis files. 

These payments are scheduled to expire (with the Act) in 2006. In 2007, assuming the

guaranteed payments are not reauthorized and payments are again sensitive to harvest 

levels, the effects of No Action are predicted to be most like Alternative 1 in the 1994 

FSEIS. 

Environmental Effects of Proposed Action and Alternative A 

Neither the Proposed Action nor Alternative A changes the predicted effects of 

Alternative 9 in the Northwest Forest Plan (see Appendix B). Physical and biological 

effects are adequately described in the 1994 FSEIS. 

The Northwest Forest Plan acknowledges that disturbances are natural occurrences 

within forested habitats and that management of this habitat without disturbance is 

impossible. Some level of disturbance is necessary, and even beneficial to the 

ecosystem. The clarified language for the ACS would result in improved decisions that 

reflect these concepts. Short-term adverse effects associated with disturbance (such as 

increased turbidity or streambed sedimentation) accrue from activities such as culvert 

removal and replacement, road obliteration, and other restoration activities in riparian 

areas or streams. These actions are intended to provide for long-term benefit to aquatic 

and riparian habitats. 

The risk of adverse short-term, site-level impacts would increase proportionately to the 

amount of work implemented. Extent and duration of these effects would be 

considered in project-level analysis. 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

The agencies considered the potential effects of the proposed amendment (Proposed 

Action/Alternative A) on a variety of wildlife, fish, and plant species of concern. A 

Biological Evaluation (BE) was prepared that addresses species listed or proposed 

under the Endangered Species Act (ESA), as well as Forest Service sensitive species 

and their habitats within the Northwest Forest Plan area. 

The change in language itself does not approve any specific projects and would not 

result in any effects on species or habitat. Further disclosure under NEPA and the ESA 

would occur before specific projects would be approved. The BE states that the 

proposed amendment “would have no effect to any ESA-listed species, or on 

designated or proposed critical habitat.” As Appendix B demonstrates, the proposed 

amendment would not alter any Northwest Forest Plan conclusions or assumptions 

related to species viability. 

Forest Service biologists have also determined that the proposed amendment would 

have “no impact” on any sensitive species identified on the Region 6 and 5 Regional 

Forester’s Sensitive Species Lists. The species lists and BE are included in the analysis 

files. 

NOAA Fisheries recently reviewed the status of all listed salmon and steelhead within

the Northwest Forest Plan area. The FS and BLM have initiated consultation and a 

Biological Assessment (BA) prepared on these species for Resource Management Plans 

that would be amended under Alternative A. The BA is in Appendix D. The BA lists 

and describes the status of a fish species and considers effects on these species from all 

activities typically conducted on FS and BLM lands, including forest management, 

recreation, grazing, mining, watershed restoration, fish and wildlife habitat 

management, fire and fuels management, land acquisitions and exchanges, and special 

uses. 

The BA concludes, “The land allocations result in approximately 80 percent of federal

lands in some sort of reserve status across the Northwest Forest Plan area...This 

provides benefits to ESA-listed fish species by minimizing the amount of grounddisturbing activities and potential adverse impacts to water quality and fish habitat.” 

The BA also states, “...the implementation of standards and guidelines, particularly 

those for Riparian Reserves, Key Watersheds, and Watershed Analysis are beneficial to 

ESA listed species and critical habitat by providing guidance for the design, 

prioritization and implementation of actions with the potential to affect ripariandependent resources.” 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

The BA acknowledges that the “land allocations where most of the potential grounddisturbing actions may occur is Matrix, Adaptive Management Areas and Managed 

Late-Successional Reserves.” The BA sums the land area within these three allocations 

and concludes that they cover approximately 7 to 26 percent of the Northwest Forest

Plan area. 

The BA states “The design, location, and timing of federal timber sales planned in 

accordance with the Northwest Forest Plan and its Aquatic Conservation Strategy will 

minimize the potential to: 1) reduce stream shade canopy to the extent that water 

temperatures are measurably increased; 2) reduce the supply of large wood debris; 3) 

alter stream flow regimes; and 4) accelerate surface erosion and mass wasting to the 

extent that there is increased sediment delivery and turbidity in streams....When 

conducting forest management and watershed restoration activities, there may be an

increase in the potential for short-term adverse effects to ESA listed fish species, but 

these effects are within the original scope analyzed in earlier plan-level Biological 

Opinions.” The BA also concludes, “There is the potential for an increase in long-term 

benefits since restoration will be implemented...” 

The Biological Assessment also finds that “In summary, the integration of the ACS 

components of WA, Key Watersheds, Riparian Reserves, watershed restoration, and 

associated [standards and guidelines] result in a management framework that 

minimizes or avoids the potential negative impacts of land management actions to 

water quality and fish habitat, while also restoring aquatic and riparian habitat 

conditions. This will enhance the long-term potential to sustain populations of at-risk 

fish species. Consequently, the ACS as a strategy and its individual components are 

beneficial to ESA-listed fish species and critical habitat.” 

The BA goes on to state that, “Despite the protective and restorative aspects of NWFP 

and ACS implementation, a sub-set of actions will nevertheless result in adverse effects 

to ESA-listed and candidate fish species and proposed or designated critical habitats. 

These adverse effects are typically short-term in nature and often associated with 

watershed restoration efforts. Therefore, most of the RMPs ‘may affect, likely to 

adversely effect’ (LAA) [some] listed species or critical habitat.” 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Socio-economic Effects of the Action Alternatives 

Under the Proposed Action and Alternative A, the agencies would likely increase 

timber harvest levels, up to levels envisioned Alternative 9 in the 1994 FSEIS and 

adjusted in individual RMPs. To the extent that timber harvest levels reach these 

levels, the socio-economic effects of the action alternative are likely to be similar to the 

effects predicted for Alternative 9. As discussed previously, the Secure Rural Schools 

and Community Self-Determination Act of 2000 allowed counties to choose a 

guaranteed level of payments, rather than payments based on timber harvest. 

However, the Act expires in 2006. FEMAT and the 1994 FSEIS include detailed socioeconomic analysis, which is not re-evaluated here. 

Required Disclosures 

This section focuses on Alternative A. 

Relationship Between Short-term Uses and Long-term Productivity 

Alternative A does not approve any short-term uses nor would it have any effects on 

long-term productivity. The ACS is still intended to protect long-term productivity of 

aquatic and riparian ecosystems within the Northwest Forest Plan area. 

Conflicts with Other Plans 

Other Analysis Efforts Within the Northwest Forest Plan Area 

Other planning efforts are underway within the Northwest Forest Plan area that may 

affect various Resource Management Plans and how they are implemented. The 

agencies are currently considering alternatives to modify or eliminate the Survey and 

Manage mitigation measure in the Northwest Forest Plan. In 2001, the Secretaries of 

Agriculture and the Interior amended the Northwest Forest Plan with the Record of 

Decision for Amendments to the Survey and Manage, Protection Buffer, and other 

Mitigation Measures standards and guidelines. 

Timber industry and county government associations litigated that decision. On 

September 30, 2002, the Secretaries entered into a settlement agreement with that

required the BLM and Forest Service to examine an alternative “that replaces the 

Survey and Manage mitigation requirements with existing Forest Service and BLM 

special status species programs to achieve the goals of the Northwest Forest Plan 

through a more streamlined process” in a new SEIS. 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

The Draft SEIS to eliminate or modify the Survey and Manage Mitigation Measure 

Standards and Guidelines was published in April 2003 (USDA, USDI 2003). 

Other ongoing analysis efforts within the Northwest Forest Plan area include the FS 

“Invasive Plant EIS,” the BLM and FS “Port-Orford-cedar EIS,” and the BLM 

“Vegetation Treatments Programmatic EIS." The Port-Orford-cedar EIS was 

necessitated by the Kern v. BLM decision of the Ninth Circuit. The BLM Vegetation 

Management EIS was initiated to (among other things) address problems created by 

court injunctions from the 1980’s that still restrict BLM herbicide use. 

The cumulative effects of proposed Northwest Forest Plan amendments are similar to 

effects analyzed in the 1994 Northwest Forest Plan FSEIS for Alternative 9. None of 

these efforts seek to change the predicted effects of the ACS. The decision whether or 

not to amend ACS language is not dependent on the other planning efforts. 

As discussed in the 1994 FSEIS: “In addition, all ground-disturbing actions are 

conducted only after site-specific environmental analysis has been completed. This 

site-specific analysis will also analyze the cumulative impacts of the project 

alternatives on adjacent lands and resources, and on the watershed. This provides 

opportunities to detect and minimize cumulative environmental effects that cannot be 

ascertained at the programmatic level of this SEIS.” 

Other Concurrent Regulatory Proposals that May Affect Aquatic Resource 

Management 

This SEIS incorporates by reference the discussion in the Northwest Forest Plan FSEIS 

concerning conflicts with other plans (USDA, USDI 1994a, pp. 3&4-319 and 320, and

Appendix D). The proposed amendment would not alter the conclusions of the 

Northwest Forest Plan FSEIS regarding the possible conflicts with other plans. 

Currently, several regulatory proposals about federal land management have been 

proposed or adopted. These proposals do not conflict with the Northwest Forest Plan. 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Irretrievable and Irreversible Commitment of Resources 

The proposed amendment does not make any irretrievable or irreversible

commitments of resources beyond those predicted in the Northwest Forest Plan FSEIS 

(p. 3&4-321): 

“Implementation of projects in accordance with the preferred alternative 

[Alternative 9] would result in some, if not all, loss of utility of habitat for latesuccessional and old-growth related species for the period of time needed for 

that habitat to grow again-a commitment of over a century. Some old-growth 

forest stands would be harvested under the preferred alternative. Although 

certain economic and social values will be saved at the point of harvest, these 

areas will then not contain as full an array of ecological and human values

associated with old-growth forests as stands not harvested. Depending on the 

physiographic province and site, it would be several centuries or more before 

the full array of those characteristics return.” 

Civil Rights and Environmental Justice 

No disparate or adverse effects are identified to groups of people identified in Civil 

Rights statutes or Executive Order 12898 (Environmental Justice) from Alternative A. 

This finding is due largely to the administrative nature of the proposed change (i.e. a 

change in wording of an existing SEIS to clarify requirements). A Civil Rights Impact 

Analysis was prepared to comply with all applicable civil rights statutes, including 

Title VI of the Civil Rights Act of 1964. 

Effects on Critical Elements 

Both agencies require disclosure of effects on several critical elements of the human 

environment. These include air quality, Areas of Critical Environmental Concern, 

Cultural Resources, prime and unique farm and forest lands, floodplains, Native 

American religious concerns, threatened and endangered species, hazardous materials 

and solid waste, surface and ground water quality, wetlands and riparian zones, wild 

and scenic rivers, noxious weeds and environmental justice. The BLM requires that 

these elements be specifically addressed in environmental impact statements (H-1790-

1). 

The proposed amendment does not have the potential to affect any of these elements 

beyond the levels disclosed previously in the Northwest Forest Plan FSEIS (see 

Appendix B for details). Appendix D includes a Biological Assessment for certain fish 

species listed under the Endangered Species Act. The Biological Assessment 

summarizes the history of Endangered Species Act consultation related to these

species. As discussed above, a Civil Rights Impact Analysis was prepared for the 

proposed amendment. 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

American Indian Rights and Resource Issues 

Discussion about tribal treaty rights and trust resources starts on page 54 of the 

Northwest Forest Plan Record of Decision. American Indian treaty rights and trust 

resources will be protected under the proposed amendment. A reduction in timber 

sales may affect tribes’ ability to secure resources for traditional and cultural uses, such 

as logs for canoes and long houses. 

The proposed amendment would affect management of the Coquille Forest. These 

lands are owned by the Coquille Indian Tribe, are part of the Coquille Indian 

Reservation, and are held in trust by the United States. An Act of Congress in 1996 

transferred ownership of about 5,400 acres of federal land within the Northwest Forest 

Plan area transferred to the Coquille Indian Tribe. The Act required that Coquille 

Forest be managed subject to the standards and guidelines of federal Forest Plans on 

adjacent or nearby federal lands. The proposed amendment has effects on tribal treaty 

rights and trust resources similar to Alternative 9 in the Northwest Forest Plan. 

CHAPTER 5. CONSULTATION AND COORDINATION 

This SEIS was prepared by an Interagency Interdisciplinary Team (see List of Preparers 

below). Several agencies provided consultation and coordination input. The primary 

agencies involved include: 

Department of Commerce, 

National Oceanic and Atmospheric Administration (NOAA Fisheries), , 

Regional Ecosystem Office Environmental Protection Agency 

United States Department of the Interior, 

Bureau of Land Management, 

Bureau of Indian Affairs, 

Solicitors’ Office, 

U.S. Fish and Wildlife Service (USFWS), 

United States Department of Agriculture, 

Forest Service, 

Office of General Counsel, 

Pacific Northwest Research Station 

61
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Distribution of the Draft Supplemental Environmental Impact 

Statement 

This Draft Supplemental Environmental Impact Statement (SEIS) was mailed to the 

following individuals, groups, and organizations. The list includes elected officials; 

federal agencies; state, local, and county governments; American Indian Tribes and 

Nations; businesses; other organizations; libraries; and individuals. It is also available

via the Internet at: http://www.reo.gov/acs/. 

Elected Officials 

California

Senator Barbara Boxer 

Senator Dianne Feinstein 

Representative Sam Farr 

Representative Wally Herger 

Representative Barbara Lee 

Representative Robert Matsui

Representative George Miller 

Representative Doug Ose 

Representative Nancy Pelosi 

Representative Mike Thompson 

Representative Lynn Woolsey 

Oregon

Senator Gordon Smith

Senator Ron Wyden 

Representative Earl Blumenauer 

Representative Peter DeFazio

Representative Darlene Hooley 

Representative Greg Walden

Representative David Wu 

Washington

Senator Maria Cantwell 

Senator Patty Murray 

Representative Brian Baird 

Representative Norman Dicks 

Representative Jennifer Dunn

Representative Richard Hastings 

Representative Jay Inslee 

Representative Rick Larsen

Representative Jim McDermott 

Representative George Nethercutt

Representative Adam Smith

Intergovernmental Advisory Committee (to the Regional Ecosystem Office) 

Dave Allen 

U.S. Fish and Wildlife Service

Elaine Brong

Bureau of Land Management, 

OR/WA 

Lance Clark

State of Oregon Rep. 

Kent Connaughton 

USDA Forest Service, Region 5 

Merv George, Jr. 

CA Indian Forest and Fire 

Management Council

Linda Goodman 

USDA Forest Service, Region 6 

Bob Graham 

Natural Resources

Conservation Service 

David Herrera 

Northwest Indian Fisheries 

Commission 

Colonel Richard Hobernicht 

U.S. Army Corps of Engineers 

Jon Jarvis 

National Park Service 

Anne Kinsinger 

U.S. Geological Survey 

Robert Lohn 

National Marine Fisheries

Service 

Albert McKee 

Representative of Washington 

Counties

Rocky McVay 

Association of O & C Counties 

Mary Nichols

California Resources Agency

Robert Nichols 

WA State Senior Executive

Policy Assistant 

Jennifer Orme-Zavaleta 

Environmental Protection 

Agency 

Michael Pool

Bureau of Land Management, 

CA 

Dave Powers

Environmental Protection 

Agency 

Tom Quigley 

USDA Forest Service, PNW 

George Smith 

Intertribal Timber Council 

Joan Smith 

Representative of California 

Counties

Stan M. Speaks

Bureau of Indian Affairs 

Steve Thompson

U.S. Fish and Wildlife Service

CA/NV 

62
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Federal Agencies 

Advisory Council on Historic

Preservation 

Bonneville Power 

Administration

Environmental Protection 

Agency 

Geographic Implementation 

Unit 

Operations Office 

 Region 9 

 Region 10 

Federal Energy Regulatory 

Commission 

Portland Federal Executive 

Board 

Regional Ecosystem Office

U.S. Army 

U.S. Coast Guard 

U.S. Department of Agriculture 

Animal and Plant Health 

Inspection Service 

Environmental Coordinator of

Ecological Services 

Forest Service 

Pacific Northwest Regional 

Office and Forests 

Pacific Southwest Regional 

Office and Forests 

Pacific Northwest Research 

Station 

Pacific Southwest Research 

Station 

National Agriculture Library

Natural Resource 

Conservation Service 

OPA Publication Stockroom 

U.S. Department of Commerce 

NOAA Fisheries (National

Marine Fisheries Service) 

U.S. Department of Defense

Army Corp of Engineers

 PE PF

 Seattle District

Walla Walla District 

Naval Submarine Base

Bangor 

U.S. Department of Energy 

U.S. Department of Interior 

Bureau of Indian Affairs 

Bureau of Land Management 

National Park Service 

Office of Environmental Policy

and Compliance 

Bureau of Reclamation 

Klamath Soil & Water 

Conservation Dist.

National Park Service 

Ft. Vancouver National 

Historic Site 

Olympic National Park

Redwood National Park 

Redwood Sciences Lab 

Office of the Regional Solicitor 

Office of the Secretary

Fish and Wildlife Service 

U.S. Geological Survey 

Biological Resources 

Division 

Pacific Northwest District

U.S. Department of Justice 

U.S. Ecosystem Restoration

Office 

U.S. Housing and Urban 

Development 

U.S. Small Business 

Administration

U.S. Department of 

Transportation 

Federal Aviation Administration 

Federal Highway 

Administration

State, County, and Local Governments 

California

State of California 

 Caltrans

Department of Forestry 

Department of Forestry and 

Fire Protection

Department of Water 

Resources 

Fish and Game Commission 

 Lands Commision 

Office of the Governor 

Parks and Recreation 

 Resources Agency

 State Clearinghouse 

California Regional Water 

Quality

City of Yreka 

Colusa County, Agriculture 

Department 

Del Norte County Board of

County Supervisors

Eel - Russian River Commission 

Glenn County 

 Agriculture Department 

Board of Directors 

Board of Supervisors 

Coop Extension Office 

 Planning Department 

Humboldt County Board of

Supervisors 

63
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Lake County Board of 

Supervisors 

Mendocino County 

Board of Supervisors 

 Cooperative Extension 

 Planning Department 

 Water Agency 

North California Water 

Association 

Pinecrest Permittees Association 

Shasta County Board of

Supervisors 

Siskiyou County 

 Administrators 

Board of Supervisors 

Sonoma County Conservation 

Action 

Tehama County 

Board of Supervisors 

 Planning Department 

Trinity County, Board of County 

Supervisors 

Colorado

San Miguel County 

District of Columbia

Rural Utilities Service 

Oregon

State of Oregon 

Department of Agriculture 

Department of Energy 

 Department of 

Environmental Quality

Department of Fish & 

Wildlife 

Department of Forestry 

Department of Geology and 

Mineral Industries 

Department of Human 

Resources 

Department of Revenue 

 Department of 

Transportation 

 Employment Department 

 Executive Department 

Farm Bureau Federation 

 Historic Preservation Office 

 Marine Board 

Office of The Governor 

Parks And Recreation 

 Public Interest Research 

Group 

 Small Business

Administration

Water Resources Department 

Association of O&C Counties

Association of Oregon Counties 

City of Cottage Grove 

City of Eugene, Parks and 

Recreation District 

City of Klamath Falls 

Coos County Board of 

Commissioners 

Curry County Board of 

Commissioners 

District 17 Watermaster 

Douglas County 

Board of Commissioners 

 Natural Resources

Conservation Service 

 Planning Department 

Hood River County 

Grants Pass & Josephine County

Chamber of Commerce 

Jackson County Commissioners 

Jefferson County Commissioners 

Josephine County 

 Courthouse

 Forestry Department 

 Planning Department 

Klamath Basin Water Resources 

Advisory Commit 

Klamath County 

Klamath County Commissioners 

Klamath Irrigation District 

Lake County

Lane County Commissioner 

Meadows Drainage District 

Mohawk Watershed Planning 

Group 

Northwest Power Planning 

Council 

Portland Chamber of Commerce 

Portland Water Bureau 

Rogue Institute of Economy And 

Ecology 

Rogue Valley Council of 

Governments

Southeastern Oregon Advisory 

Council 

Umpqua Regional Council of 

Governments

Wasco County Commissioners 

Washington

State of Washington 

Department of Ecology 

Department of Fish and

Wildlife 

Department of Natural 

Resources 

 Department of 

Transportation 

 Executive Policy Office 

Office of The Governor 

Chelan County Planning 

Department 

City of Port Townsend 

Clallam County Commisioner 

Forks Chamber of Commerce 

Jefferson County Commissioners 

Lewis County Commissioners 

Mason County Commissioner 

Skagit County 

Skamania County Planning 

Department 

Washington State Association of 

Counties

Washington Environmental 

Council

64
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

65

American Indian Tribes and Nations 

Big Valley Rancheria 

Blue Lake Rancheria 

Columbia River Inter-Tribal Fish 

Commission 

Colville Confederated Tribes 

Colville Tribal Office 

Confederated Tribes of Grande 

Ronde Indians 

Confederated Tribes of Lower 

Coos 

Confederated Tribes of Siletz

Indians of Oregon 

Confederated Tribes of The 

Chehalis Reservation 

Confederated Tribes of The 

Warm Springs Reservation of

Oregon 

Coquille Indian Tribe 

Covelo Indian Community 

Cow Creek Band of Umpqua 

Tribe of Indians 

Cowlitz Indian Tribe 

Cowlitz Wahkiakum Council of 

Government 

Coyote Valley Rancheria 

Elk Valley Rancheria 

Grindstone Rancheria 

Hoh Tribe 

Hoopa Tribal Fisheries 

Department 

Hoopa Valley Tribal Council

Intertribal Timber Council 

Jamestown S’kallam Tribe 

Kalapooya Sacred Circle

Alliance 

Karuk Tribe of California 

Klamath General Council 

Klamath Indian Game 

Commission 

Lower Elwha S’klallam Tribe 

Lummi Indian Business Council 

Lummi Tribe of The Lummi

Reservation 

Makah Tribe 

Muckleshoot Indian Tribal 

Council 

Native American Heritage

Committee 

Native American Program

Oregon Legal Services Corp. 

Nisqually Indian Community 

Council 

Nooksack Indian Tribal Council 

Northwest Indian Fisheries 

Commission 

Paskenta Band of The Nomlaki 

Point-No-Point Treaty Council 

Port Gamble Band of S’klallam 

Indians 

Puyallup Tribal Council 

Quinault Indian Nation 

Reservation Ranch 

Resighini Rancheria 

Robinson Rancheria Pomo 

Indian Tribe 

Rohnerville Rancheria 

Round Valley Indian Tribes 

Samish Indian Tribe 

Sauk Suiattle Indian Tribal 

Council 

Shasta Nation 

Shoalwater Bay Tribal Council 

Siletz Tribal Council 

Snohomish Tribe 

Squaxin Island Tribal Council 

Stillaguamish Board of Directors 

Suquamish Tribal Council 

Swinomish Indian Tribal

Community 

Table Bluff Reservation 

The Klamath Tribes 

Tolowa Nation

Tsnungwe Council 

Tulalip Board of Directors 

Twin Rocks Inholders 

Upper Lake Rancheria 

Upper Skagit Indian Tribal 

Council 

Yakama Indian Nation Tribal 

Council 

Yurok Tribe

Businesses 

Adobe Rose 

Akins & Villavicencio Llp 

Alder Creek Lumber Co. 

Alpha World International Corp. 

American Forest and Paper 

Assn. 

American Forest Resource 

Council 

American Forestry Association 

American Rivers, Inc. 

Amerititle 

Armco 

Associated Oregon Industries

Associated Oregon Loggers 

B.S. Roads, Inc. 

BAC Logging

Barnes & Associates, Inc.

Berry Botanical Garden 

Blue Lake Forest Products, Inc
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Boise Cascade Corporation 

Brecher & Volker LLP 

Brewley, Inc. 

Burlington Northern, Inc. 

Buse Timber & Sales, Inc.

C & D Lumber Co.

C.E. Exploration Co. 

Cascade Timber Consulting 

Cavenaugh Forest Industries 

CH2M Hill Northwest 

Clear Creek Copters, Inc. 

Clifford, Chance, Rogers and 

Wells Law Firm

Cobbett Law Office 

Columbia Forest Products 

Columbia Helicopters, Inc.

Conifer Pacific, Inc. 

Crown Pacific 

Crystal Mountain 

David Evans and Associates, Inc. 

Deer Creek Timber, Inc. 

Deixis Consultant 

Douglas County Lumber Co.

Douglas Timber Operators 

Dreyer Lapidos Geyer & Van 

Horn, Inc.

DRJohnson Lumber Co. 

Earthwise Excavation 

East Fork Lumber Co., Inc.

Edaw, Inc.

Eel River Sawmills, Inc. 

Enterprise Rent-A-Car 

Ericson Air Crane Co.

Forestry and Resource 

Consulting 

Freres Lumber Co., Inc. 

Freshwater Farms 

Future Logging Co.

Galea Wildlife Consulting

Gary Cook & Associates

Georgia Pacific West, Inc. 

Georgia Pacific Corporation 

Giustina Land & Timber Co.

Glide Lumber Co. 

Gustin Enterprises 

Haglund, Kirtley, Kelley and

Horngren 

Hampton Tree Farms 

Harwood Products 

Heebphoto Inc. 

Hendrix Enterprises 

Herbert Lumber Co. 

High Cascade, Inc. 

Hillcrest Vineyard 

Home Animation Limited

Huffman &Wright Timber 

Corporation 

Hull Oakes Lumber Co.

Hydro Energy Development 

Corporation 

Independent Thinning 

Indian Hill LLC

Indian Hill Timber Co. 

Industrex Unlimited

J. Davidson & Sons Construction 

JA Brennan Associates 

Jeld Wen, Inc. 

K.D. Logging 

Keller Lumber Co. 

Ken Sorenson Logging, Inc.

Keslick And Son Modern 

Arboriculture 

Klamath Insurance Center 

Klamath Potato Growers 

Association 

Land & Water Consulting, Inc.

Laughing Horse Book Store 

Law Office of Nancy Page 

Lee Enterprises 

Leo Miller Contracting

Logging Engineering Int., Inc.

Lone Rock Timber Co. 

Longview Fibre Corporation 

Lusignan Forestry, Inc.

M&A Broken Limb 

Madroak Logging 

Marys River Lumber 

Mason Bruce & Girard, Inc. 

Mater Engineering, Ltd.

Matesol 

McFarland Cascade 

McKenzie River Guides 

Merlin Biological 

Merrill & Ring

Mountain Title Company 

Mt. Ashland Association 

Mt. Hood Meadows 

Northwest Forest Resources 

Northwest Forestry Association 

Northwest Mining Association 

Northwest Timber Review 

Northwest Whitewater 

Excursions 

NRM Corp 

Offices of Marin Psychological 

Services

Oregon Forest Industry Council 

Overland Express 

Pacific Northwest Ski Areas 

Assn. 

Pacific Power and Light 

Pan Pacific Forestry

Perkins Coie LLP 

Plum Creek Timber Co. 

Public Timber Purchasers Group 

Quafco 

Rayonier, Inc. 

Resource Recovery Group, Inc. 

Resources Northwest 

Consultants 

Richard L. Willis Logging

Roberts Cummings, Inc.

Rocking C Ranch 

Rogue Forest Protective 

Association 

Rosboro Lumber Co. 

Roseburg Forest Products 

Rough & Ready Lumber Co. 

Salt Springs Logging 

Saltman and Stevens, P.C. 

SDS Lumber Company 

Seneca Jones Timber Co.

Seneca Sawmill Company 

Sequoia Associates 

Sierra Pacific Industries 

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Silver Butte Timber 

Simpson Door Co. 

Simpson Investment Co. 

Siskiyou Coop., Inc. 

Snowy Butte Helicopters

South Umpqua State Bank 

Sparkling and Son, Inc. 

Spider Webb Ent., Inc. 

Starfire Lumber Co. 

Stevens Pass Ski Resort 

Superior Lumber Co., Inc.

Sustainable Northwest 

Swanson Group 

Swanson Superior Forest 

Product, Inc.

T.H. Ireland, Inc. 

The Nicholoff Company 

The Timber Company 

Thinking, Inc. 

Three Rivers Logging Co. 

Timber Data Company 

Timber Products Co. 

Timberland Logging 

Trinity River Lumber Co. 

US Forest Industries, Inc. 

US Timberlands Klamath Falls 

LLC 

Wards Creek Logging 

Washington Belt & Drive 

Systems 

Washington Contract Loggers 

Association 

Washington Forest Law Center 

Westbrook Land and Timber 

Western Forest Protection 

Association 

Western Timber Co. 

Western Wood Products

Association 

Westest Logging 

Weyerhauser Co. 

Wilkins, Kaiser, & Olsen 

Willamette Industries 

Wolfe’s Guide Service 

Woody Contracting, Inc.

Woolley Enterprises, Inc. 

WTD Industries, Inc.

Other Organizations 

1000 Friends Of Oregon

1000 Friends Of The Earth

Alameda Creek Alliance 

Allegheny Defense Project

Alpine Lakes Protection Society 

Altacal Audubon Society Inc 

American Alpine Institute 

American Fisheries Society 

American Lands 

American Lands Alliance 

Ancient Forest Defense Fund 

Applegate Partnership 

Applegate River Watershed Council 

Arc-En-Ciel 

Association of Northwest

Steelheaders 

Association of Oregon Counties 

Audubon Society 

 Black Hills 

 Columbia Gorge 

 Corvallis 

 Golden Gate

 Grays Harbor 

 Kalmiopsis 

 Kitsap 

 Kittitas 

 Klamath Basin

 Leavenworth 

 National 

N. Central Washington

 Pilchuck

 Rainier 

 Redwood Chapter 

 Rogue Valley 

San Juan Islands 

 Seattle 

 Siskiyou 

 Spokane 

 Umpqua Valley 

BARK

Baron Family Partnership 

Basketweavers Project

Bike To Nature 

Biodiversity Northwest

Blue Ribbon Coalition

Breitenbush Community 

Breitenbush Hot Springs 

Butte Falls Advocates 

California Cattlemens Association

California Coalition for Alternatives 

to

Pesticides 

California Lichen Society 

California Native Plant Society 

California Trout

California Wilderness Coalition

Californians For Alternatives to

Toxins

Cascadia Forest Alliance 

Cascadia Wildlands Project

CATs

Central Cascades Alliance 

Central Oregon Motorcycle and ATV 

Club

Central Valley WQCB 

Cheetwoot Wilderness Alliance 

Citizens For Better Forestry 

Citizens Interested In Bull Run

Clackamas Trout Unlimited

Clackamas-Marion Forest Prot Assn

Claggett Creek Watershed Council 

Coast Range Association

Coastal Forest Alliance 

Columbia Basin Wildlife Assn. 

Communities for a Great Oregon

Concerned Friends of Ferry County

Cottage Grove Historical Society 

Deer Creek Vly Ntrl Resrc Conserve 

Defenders Of Wildlife 

Ducks Unlimited-South Oregon

Earth Justice 

EF! Wolf Action Network 

Endangered Species Coalition

Environmental Protection

67
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

68

Information Center 

Environmental Resources Ctr 

Essex Junction 

Environmental Group 

Forest Conservation Council 

Forest Guardians 

Forest Issues Group 

Forest Landowners of California 

Four Runners Four Wheel Drive 

Club 

Franciscan Sisters of the Poor 

Friends Of Clackamas River 

Friends Of Del Norte County 

Friends Of The Greensprings 

Friends Of The River 

Friends Of Trees 

Gifford Pinchot Task Force 

Global Peoples Assembly Network 

Great Lake United 

Headwaters 

High Country Citizens Alliance 

High Desert Trail Riders 

Hood Canal Coordinating Council 

Inland Empire Public Lands Council 

Institute for Applied Ecology 

Institute for Policy Research 

Izaak Walton League of America 

John Muir Project 

Keep Oregon Green 

Kettle Range Conservation Group 

Klamath Basin Snowdrifters 

Klamath Forest Alliance 

Klamath Siskiyou Wildlands Center 

Klamath Yacht Club 

La Canada Flintridge Trails Council 

Land & Water Fund Of The Rockies 

Lassen Forest Preservation Group 

League Of Wilderness Defenders 

Little River Committee 

M.U.D.D. 

Mattole Salmon Group 

Mazama Conservation Committee 

Mckenzie Guardians 

Mckenzie River Trust 

Mckenzie Watershed Council 

Mendocino Environmental Center 

Moose School Productions 

Mt. Adams Adopt-A-District 

Mt. Mazama Mushroom Association 

National Forest Protection Alliance 

National Wildlife Federation 

Native Fish Society 

Native Plant Society 

 Oregon 

 Siskiyou 

Native Sky Wildlife Sanctuary 

Nature Conservancy 

Nature Society 

NCASI West Coast Regional Center 

North Coast Recreation Coalition 

Northwest Coalition For 

Alternatives To Pesticides 

Northwest Ecosystem Alliance 

Northwest Environmental Defense 

Fund 

Northwest Old-Growth Campaign 

Northwest Rafters Association 

Nuview -Evaluation & Learning 

Oak Ridge National Laboratory 

OFREG 

Olympic Forest Coalition 

Olympic Park Associates 

Orca Quest 

Oregon Bicycling Advisory 

Committee 

Oregon Cattlemans Association 

Oregon Coast Mycological Society 

Oregon Council Rock and Mineral 

Clubs 

Oregon Council Trout Unlimited 

Oregon High Desert Museum 

Oregon Historical Society 

Oregon Hunters Association 

Oregon Independent Miners/BMOA 

Oregon Institute of Technology 

Oregon Lands Coalition 

Oregon Mycological Society 

Oregon Natural Desert Association 

Oregon Natural Resources Council 

Oregon Park Associates 

Oregon Sheep Growers Association 

Oregon Small Woodlands 

Association 

Oregon Trail Coordinating Council 

Oregon Trout 

Oregon Waterfowl and Wetlands 

Oregon Wildlife Federation 

Oregonians for Action 

Oregonians for Food and Shelter 

Ouachita Watch League 

Pacific Biodiversity Institute 

Pacific Coast Federation of 

Fisherman’s Assn. 

Pacific Crest Trail Association 

Pacific Northwest 4 Wheel Drive 

Assn. 

Pacific Rainforest Wildlife Guardians 

Pacific Rivers Council 

Pacific Wildlife Research 

PEER 

People for the USA Happy Camp 

Predator Conservation Alliance 

Public Lands Foundation 

Reed College Forest Watch 

Rocky Mountain Ecosystem Defense 

Rogue Fly Fishers 

Roseburg Resources 

Rural Information Network 

Save Our Klamath Jobs 

Seattle Lichen Guild 

Shenandoah Ecosystems Defense 

Group 

Sierra Club 

 Cascade Chapter 

 Illinois Valley 

 Many Rivers Group 

 Northern Great Plains 

 Northwest 

 New York City Chapter 

 Plant Society 

 Rogue Group 

 Tillamook 

 Yahi Group 

Sierra Club Legal Defense Fund 

Siskiyou Project 

Siskiyou Regional Education Project 

Smith River Alliance 

SOCATS 

Society for Range Management 

Society of American Foresters 

South Carolina Forest Watch 

Southern Apalachian Biodiversity 

Project 

Southern Oregon Alliance for 

Resources 

Southern Oregon Forest Coalition 

Southern Oregon Timber Industry 

Association 

Southern Willamette Earth First! 

Steamboaters 

Stillwater Sciences 

Stop Oregon Litter and Vandalism 

Sutherlin Watershed Action 

Committee 

Takilma Watershed Committee 

TELAV 

The Bot Works, Inc. 

The Cascadians 

The Ecology Center 

The Lands Council 

The Mountaineers 
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

69

The Nature Conservancy 

The Ptarmigans 

The Wilderness Society 

The Wildlife Society, Oregon Chaper 

Trees of Mystery 

Trout Unlimited 

Umpqua Watersheds, Inc. 

United Anglers of California 

University of Oregon, Survival 

Center 

Vancouver Wildlife 

Washington Wilderness Coalition 

Washington State Hi-Lakers 

Washington State Snowmobile 

Association 

Washington Trout 

Washington Wilderness Coalition 

Water For Life 

WELC 

West Montana Mycological 

Western Environmental Law Center 

Western Fire Ecology Center 

Western Forest Industries 

Association 

Western Forestry & Conservation 

Association 

Western Mining Council 

Wilderness Watch, NW Chapter 

Willits Environmental Center 

World Wildlife Fund 

Xerces Society

Libraries, Schools, and Universities 

Aberdeen Timberland Library 

Albany City Library 

Albina Library 

Algona-Pacific Library 

Amanda Park Timberland Library 

Applegate Branch Library 

Arcata Branch Library 

Ashland Public Library 

Auburn Library 

Bandon Public Library 

Battleground Library 

Bellevue Regional Library 

Bend Public Library 

Black Diamond Library 

Blemont Library 

Bleyhl Community Library 

Blue Lake Branch Library 

Bothell Regional Library 

Boulevard Park Library 

Brownsville Public Library 

Buena Library 

Burien Library 

Butte County Library 

C Giles Hunt Memorial Library 

California State University, Chico 

Camas Public Library 

Canyonville Branch Library 

Capitol Hill Library 

Carnation Library 

Carpenter Memorial Library 

Cascade Foothills Library 

Cascade Locks Library 

Cascade Pacific Library Network 

Cascade Park Library 

Central Library 

Central Washington University 

Chemult Branch Library 

Chetco Public Library 

City Of Eugene Library 

City Of Springfield Library 

Clallam Bay Library 

Clark College Cannell Library 

Colorado State University Libraries 

Columbia Gorge 

Community College 

Coos Bay Public Library 

Coquille Public Library 

Corning City Library 

Corvallis Benton Public Library 

Cottage Grove Public Library 

Cottonwood Library 

Covington Library 

Curry County Public Library 

Dallas Library 

Del Norte County Library District 

Des Moines Library 

Douglas County Library System 

Dufur Community Library 

Dunsmuir Library 

Duvall Library 

Eastern Washington University 

Ellensburg Library 

Entiat Public Library 

Eugene Public Library 

Everett Library Main Branch 

Evergreen State College 

Fairview-Columbia Library 

Fairwood Library 

Fall City Library 

Fall River Library 

Federal Way 320th Library 

Federal Way Regional Library 

Ferndale Branch Library 

Flora M Laird Memorial Library 

Forks Library 

Fort Bragg Library 

Fort Jones Branch Library 

Fortuna Branch Library 

Foster Library 

Ft Vancouver Regional Library 

Garberville Branch Library 

Glendale Branch Library 

Gold Beach Public Library 

Goldendale Library 

Granger Library 

Grants Pass Library 

Gregory Heights Library 

Gresham Library 

Happy Camp Library 

Harrah Library 

Hazel M Lewis Library 

Hillsdale Library 

Holgate Library 

Hollywood Library 

Hood River County Library 

Hoodsport Timberland Library 

Hoopa Branch Library 

Hoquim Timberland Library 

Humboldt Countylibrary 

Humboldt State University 

Issaquah Library 

Jackson County Library System 

Jacksonville Public Library 

Jefferson Co Library 

Jefferson Public Library 

Josephine County Library 

Keizer Reading Connection 

Kenmore Library 

Kent Regional Library 

Kingsgate Library 

Kirkland Library 

Klamath County Library 

Klamath Union High School 

Lacey Timberland Library 

Lake County Library 

Lake Forest Park Library 

Lake Hills Library 

Lakeport Library 

Land-Air-Water Law Center 

Lane Community College Library 

Lapine Public Library 

Lebanon Library 

Lyons Public Library 
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

70

Mabton Library 

Maple Valley Library 

Mazama High School 

Mccloud Branch Library 

Mckinleyville Branch Library 

Medford Library 

Mercer Island Library 

Middletown Library 

Midland Library 

Mildred Whipple Library (Drain 

Branch) 

Mill City Public Library 

Modoc County Library 

Montague Branch Library 

Mosier Public Library 

Moxee Library 

Mt. Shasta Library 

Muckleshoot Library 

Myrtle Creek Branch Library 

Naches Library 

Newport Way Library 

Nile Library 

North Bend Library 

North Bend Public Library 

North Bonneville Library 

North Central Regional Library 

System 

North Portland Library 

North State Coop Library System 

Northwest Library 

Oak Run Community Library 

Oakland Branch Library 

Oakridge City Library 

Olympia Timberland Library 

Oregon Institute Of Technology 

Oregon State University 

Orland City Library 

Parkdale Library 

Peninsula College 

Plumas County Library 

Port Angeles Library 

Port Townsend Library 

Quinney Natural Resources Library 

Red Bluff Library 

Redbud Library 

Redmond Public Library 

Redmond Regional Library 

Reedsport Branch Library 

Richmond Beach Library 

Riddle Branch Library 

Ridgefield Library 

Rio Dell Branch 

Rockwood Library 

Roseburg Library 

Roslyn Library 

Round Valley Public Library 

Ruch Branch Library 

Salem Public Library 

Salem State College, Dept Of 

Geography 

Sammamish Library 

Seattle Public Library 

Selah Library 

Sellwood-Moreland Library 

Sequim Library 

Shasta Bible College Library 

Shasta College Library 

Shasta County Library 

Shasta Lake Gateway Library 

Shelton Timberland Library 

Shingletown Library 

Shoreline Library 

Simpson College & Graduate School 

Siskiyou County Library 

Sisters Public Library 

Siuslaw Public Library District 

Skykomish Library 

Skyway Library 

Snoqualmie Library 

Southeast Yakima Library 

Southern Oregon University 

Southwest Oregon Community 

College Library 

Springfield Public Library 

St. Johns Library 

State of Illinois University 

Stayton Public Library 

Stevenson Library 

Summit View Library 

Sunnyside Library 

Sunriver Area Public Library 

Susanville District Library 

Sweet Home Public Library 

Tehama County Library 

Terrace Heights Library 

The Dalles-Wasco County Library 

Three Creeks Library 

Tieton Library 

Tillamook County Library 

Toppenish Library 

Trinidad Elementary School Library 

Trinity County Library 

Tukwila Library 

Tulelake Library 

Ukiah Library 

Union Gap Library 

University of Oregon Library 

University of California 

University of Washington 

Upper Lake Library 

Valley View Library 

Vancouver Library 

Vashon Library 

Wapato Library 

Washington State University Library 

Washougal Library 

West Salem Library 

White Center Library 

White Salmon Valley Library 

White Swan Library 

Willits Library 

Willow Creek Branch 

Willows Public Library 

Winston Branch Library 

Woodinville Library 

Woodland Library 

Woodmont Library 

Woodstock Library 

World Botanical Association 

Yakima Valley Regional Library 

Yoncalla Branch Library 

Yreka Library 

Zillah Library 

Media 

Ashland Daily Tidings 

Environmental Media Services 

The Associated Press 

The Chronicle 

The Columbian 

KMTX TV 

News Review
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Individuals 

Zach Aaronson

Nikki Abbott 

Sylvia Abbott

Neil Abelson

Darren Aboulafia 

S.C. Abrahams 

Diane Abrams 

Jose Abreu 

Stephere Acel 

Terry L. Ackart

B. Acland

Shannon Adamson 

Roger Adkins 

Michael Adler 

Stu & Marcia Adler 

Lorraine Agost 

Maureen Ahearn 

Stephen Ahern

Mergan Ahoute

Annette Albert

Martin Albert 

Thomas P. Albertson

Audrey Albrecht 

Jack B. Albrecht 

Priscilla Albright 

Stacy Alcorn 

John Alder 

Cathy Alexander 

Shara Alexander 

William S. Alexander 

Blake & Stephanie Alexandre 

Casey Allen

Diana Allard 

Janet Allen

M.J. Allen

Tyler Allen 

Michael Allender 

Anna Allred 

Emma Amiad 

Robert F. Amon

Carol & Ken Ampel 

Stephen M Amy

Rain Ananael 

Sue Andersen 

Connie Anderson 

Dale E. Anderson

Ellen K. Anderson

Joanne Anderson

Kara M. Anderson

Lauren & Clark Anderson

Paul D. Anderson

Raja Anderson 

Ralph E. Anderson 

Ryan Anderson 

Laura Andersson 

Jackie Andrewjeski 

Stephanie Andrews 

Leslie Angel 

Robert L. Annear Jr 

Katti Aparier 

Susan Applegate

Thomas Arbanas 

Sheri Archey 

Fabio Arevalo 

Kimberly Arner 

Thomas Arnold 

Elliot Aronin 

Suzanne O. Artemieff 

Richard Artley 

Sara Ashley 

Maryanne Ashton 

Stephanie Astorino

David Atcheson 

Kristy Athens 

Tanya Atkinson

Mohan Attar

Paul Attemann 

John W. Augenstein

Catherine Augsburger 

M.L. Austin 

Colleen Auth 

Joseph Auth 

Thomas & Rita Auth 

Thomas Avery 

Susan Ayres 

Jim Babson

Stephen Bachhuber 

Maggie Bagon 

Eric Baicy 

Erin K. Bailey 

Mark Bailey 

Stephanie Bailey 

Heather Baines 

Jeannette Baker

Michael Baker 

Mollie Bakken 

Eldon L. Ball 

Jennifer Ball 

Debra Ballheim 

Tom Bancroft 

M. Banis 

Kenny Bannerman 

Pinchas Baram 

Judith Baranowski 

Bruce Barbarasch 

Charles Barker 

Robert J. Barnard 

Selina & Ken Barnett 

Doug Barrett 

Marion R. Barry 

William A. Barry 

James Barsimantov 

Nancy Bartell 

Jeff Bartholomew 

Robert & Lesa Barton 

Jim Bartos

Nicole Baschloben 

Donna Basiliese 

Derek Bass 

Susan Bassein

Charles D. Bates 

G. Batio 

Virginia Batson

Elmer Bauer 

Erwin & Peggy Bauer 

Sarah B. Bauer

David G. Baxter

Joe Baxter 

Mary Baylor 

Sara Baz 

Justin Bean 

Anne E. Beardsley 

Marc Beauchamp 

Suzanne Beaudene

Tom Beautait 

Diane Beck 

Laura Beck 

Laurie Becker 

Jerry Becker 

Anthony E. Becket 

Rudolf W. Becking 

Kerby Beckman 

Claire Beckmann 

Azel Beckner 

Michael Bedle 

Jeanie Bein 

Amy Beliveau 

William C. Belknap 

Jon Bell 

Tyler Bell 

Margaret Bellerowen 

Anna T. Bellerson

Peter & Mary Alice Belov 

Rachael Belz 

Erica Benedict-Barta 

Rachel Bengtson

Dale A. Benjamin

Cehlishina A Bennett 

Gina L. Bentley 

Nina Berenfeld 

Julia Berger 

Kristin D. Berger

David Berger 

Carolyn Bergeron 

Elizabeth Bergmann Harms 

William J. Berigan

Jason Berkenfeldt

Kip Berman 

71
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Jordan Bernstein

Shawn Bert 

Lara N. Berthiaume

Ron Berti 

Andy Bertrand 

Sharon K. Bess 

Richard D. Beving

Anita Beyer 

Gary Bickett 

Michelle Bienick

Paula Bigley 

Dianne Billings 

Melinda Bilodeau 

Tami Binder 

Brian Birch 

Stonewall J. Bird 

Joann Birdsall

Kevin Birkes 

Barbara Birney 

David Biser 

Patricia Bitner 

M.B. Black Eagle 

Tina Blade 

David Blair 

Donald Blair 

Judy Blair 

Steve Blair 

Colin Blake 

Carmen Blakely 

Russell Blalack 

Spencer Blatt 

Efrain Bleiberg 

Alex Blementhal 

Daniel Bloch-Jeyden 

L. Blodgett

Paul Blom 

Connie M Bloom 

Warren Bloomfield 

T. Blossom 

Jeffrey J. Bode 

Brad Boer 

Joan Bohn 

Charlotte Bolinger 

Rex Boller 

Brian D. Bollman 

Elizabeth & John P Bolte 

Louisa Bolton 

Larry Boltz 

Jennifer Bommarito 

Teresa Bondavalli 

Darrel Bonde 

Shira Bonnerman 

Patty Bonney 

Sam Booher 

Deb Booth 

Howard Booth 

Karen Booth 

T. William & Beatrice Booth 

Anna Boranian 

Donald Born 

Christina Borra 

Kristin Bott 

Libby Bottero 

Dan Bourdet 

Waylon T. Bowers 

Gene & Beth Bowling 

David Bowra 

Timothy J. Boyden

Marylou Boydston 

Charles Boyer 

Tracy Boyer 

J.L. Boyle 

Christina Boyles

Craig S. Bradford

Matt Bradley

Joseph & Jill E. Bradwell 

Ruth Bramall 

Pamela A. & Thomas L. Branch 

Lindsey Brand 

Erin Brand 

Victoria Brandon 

Deborah R. Brandt 

John Brandt 

Roger Brandt 

Barbara Branham 

Marc Brashear 

Dana G. Braswell

Janet Braun 

Peter A. Bray

Julia Brayshaw 

Robert Breheny 

Maple H. Breitbach

Billie Bresnahan 

Chris Bretherton 

John Brinda 

Richard Brock 

Scott Broder

Eric Brody 

Jason Broehm

Eriks Brolis 

Honey Bronson 

Beau Brookans 

Gillian Brooks 

Jane & Al Brooks

Adriane Brown 

Alex P. Brown

Beatrice E. Brown 

Bob Browne 

Deanna Brown 

Donna M. Brown

Katrina L. Brown

Kendall Brown 

Laura S. Brown 

Rebecca Brown 

Rick Brown 

Shirley & Carl Brown 

Susan Brown 

William Brown 

John Browne, Jr.

Corinne D. Brownell 

Susan J. Brubaker-Cole 

Rachel Bruhnek

Viola Brumbaugh 

David P. Brunner

James R. Brunner

Jacs Bruscato

Elizabeth Brusin

Harry Bruton 

Marie Bryan 

Clifford M. Bryden 

Elizabeth J. Bryer 

Corey Bryerman 

Louis Bubala

Gregory Buck 

M. & Lisa Buck 

Mitch & Jennifer Buckley 

Jenifer Buckley 

Ona Budo 

Greg & Catherine Bueker 

Barbara Buettner 

Patricia Bugas-Schramm 

Nathan Bull 

E. Bullard

Barbara Bullock 

Adi Bunim

Heather Burger 

Kathryn Burger 

Sylvia Burges 

Erik Burke 

William T. Burke

Bryan E. Burke 

Joel Burnett 

Victor Burns 

Robert Burr 

Lonnie Burson

Kirsten Burt

John Bush 

Dean Bushue 

Jim Buss 

Dea Butcher 

Steven Butler 

Adrian Byers 

Jennifer Byington 

Russ Cabtrel 

Gregory Cadieux 

Jon Cain 

Deborah Caine 

Elena Cajacob 

Michelle Calasaletta 

Matthew Caldwell 

Deanna Calef 

Conrad Calimpong 

Claudia Calistro 

Dale Calkin 

Jim Call 

Marjorie Calvert 

Sally Cambell 

Mary L. Cammann 

Orville Camp 

Homer J. Campbell 

72
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

73

Frantz Campbell 

Jay Campbell 

Ron Campbell 

Lynne Campbell 

Bruce Campbell 

Brian & Lina Campopiano 

Saul Candib 

Steve Canning 

Robert L Cannon 

John R. Cannon 

Katrina M. Canti 

Linda R. Cantrell 

Sylvia Cardella 

Gregory D. Carey 

Lynn Oha Carey 

Alex Caring-Lobe 

Ariella Carlin 

Jennifer & Ken Carloni 

Brad Carlquist 

Warren Carlson 

Don Carlton 

Alan Carlton 

Toni Carmichael 

Diane Carney 

Hugh M. Carola 

Tom Carother 

Jeremy Carpenter 

Carol Carpenter 

Elizabeth M. Carr 

Sherry Carr 

Sandra C. Carrillo 

Carla Carroll 

Sara Carter 

Brenda Carter 

Emily Carter 

Stephen C. Carter 

Therese Cartwright 

David Cascadden 

Bruce Lee Casey 

Gracia Cass 

Penny L Cass 

Sean J. Castor 

Martin Catania 

Katie Cather 

Sharon P. Cavallo 

Ron Cavin 

Scott Cecile 

Janice L. Ceridwen 

J. Paul Cessaro 

Jean B. Chalmers 

Gretchen Chambers 

Leslie Chapman 

James L. Chapman 

Cathy Chappell 

Michele Chartier 

Tia M. Chartier 

Clark Chase 

Joe Chasse 

Ronald & Kathleen Chassie 

Mike Chedwick 

Peter Chen 

Colby Chester 

Maurice R. Chevalier 

Debra Chilton 

Evangeline Chinn 

Kristine K. Chinn 

Tom Chisholm 

Barbara Christensen 

Merri Jae Christiansen 

Larry M. Christiansen 

James Christie 

Stephanie A. Christopher 

Cecelia Church 

Concerned Citizen 

Jane Civiletti 

Patrick Clancy 

Laurie A. Clapp 

Reece Clark 

Robert Clark 

Jason Clark 

John Clark 

Montgomery Clark 

Connie L. Clark 

Fiona Clark 

Gavin Clark 

Michelle Clark 

Gary Clarke 

Karen Clausen 

Jim Claussen 

Curt Clay 

Judy Clement 

Ron Clementsen 

Carl M. Clemons 

Roy Clendaniel 

Shannon Clery 

Jim Clover 

Brett Clubbe 

Susan Clyde 

Christine Cody 

Debora Coen 

Ira H. & Jerolyn A. Coen 

Steve Cogswell 

Andrew Cohen 

James Cohen 

Alicia Cohen 

Brian Cohen 

Claire & Joseph Cohen 

Dan Coher 

Tom Coiner 

Christine Colasurdo 

Zane Colby 

Jessica Coldren 

Dick Cole 

Ray Cole 

Pam Cole 

Roger Cole 

Kelli Cole 

Robbianne Cole 

Susan Coleman 

Dean Coley 

Louis Colli 

Fred Collier 

Bobbi Collyer 

Tracy Colton 

Alan Colvin 

John Colvin 

Kate Conant 

Peter Conard 

Linda Conaway 

Amy Concilio 

Maria & Clarence Conkey 

Cliff & Holly Conley 

Jan Conley 

Chris Connolly 

Catherine Conolly 

Jody Conrad 

Teresa A. Conrad 

Michael S. Cook 

Walter Cook 

Langdon Cook 

Ralph K. Cook, Jr. 

Mel Cooke 

Frank A. Cool 

Ed Cooley 

Eva Millette Coombs 

Norman Cooney 

Pat Cooper 

Linda Cooper 

Michael Cooper 

Marcia Cooperman 

Noah Cope 

Josiah H. Cornell, III 

David Cornfield 

James Cornwell 

R. Corroone 

P. Cottam 

Tom Cottrell 

Ricardo Cottrell 

Phyllis Couillard 

Nancy Court 

Matthew R. Courter 

Becky Coward 

Jean E. Cox 

Karen M. Cox 

Lylanya Cox 

Monica Coyne 

John S. Cramer 

Michael & Tammie Cramey 

Susan Crampton 

Herbert O. Crane 

Donna Crane 

Kimberly S. Crihfield 

Christine Cripps 

Courtney Crist 

Jay T. Criswell 

Scott Crockett 

Nancy Crom 
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

74

Nicolette Crone 

Carrie Croson 

Bill Crossman 

Gerrit Crouse 

Earl Crowd 

Maribeth Crowe 

Ellen Crumb 

Marian Cruz 

Cheryl Cullen 

Liz Cullen 

Burt Culver 

Michael Cumini 

Robert J. Curry 

Richard L. Curtis 

Tim Cuthbertson 

Sandra T. Cutter 

Andrew Cvitanovich 

Ingrid Dahl 

Ngoc Dai 

Emily Dale 

Anne Daletski 

Scott Damberger 

Renel Damero 

Elizabeth Daniels 

Marie T. Daniels 

Nora Danielson 

Donald & Jacqueline Dann 

John D'anna 

Thomas A. Dark 

Kathryn Darnell 

David Darnell 

Pablo A. Davanzo 

L. Davidson 

Alix Davidson 

Gyllian Davies 

Steve Davies 

Frank N. Davis 

Charlie C. Davis 

Bryan Davis 

Edwin G. Davis 

Stephen H. Davis 

Barbara Davis 

John E. Davis 

Frances Davis 

Darcy Davis 

Adam Davis 

Rick Davis 

Jeff Davis 

Liz Dawson 

Scott Dawson 

Jerry W. Dawson 

Michael H. Day 

Margaret Day 

Lee Dayfield 

David De A'morelli 

Carol De Fazio 

Diana De Groot 

James W. De Pree 

Susan De Vries 

Michael H. Dean 

Kat Deaner 

Sheila Dearden 

Janet Deboototr 

Peter W. Dekramer 

Paul H. Delahanty 

Melissa Delikat 

Susan Delles 

Roger Delmar 

Brian Delshad 

Carmen Delsnig-Prager 

Valerie Delucia 

Harry Demaray 

Tamara Demetro 

Sarah Dempsey 

Brook Denegre 

J.L. Denison 

William L. Denneen 

Dash Dennis 

Deston L. Denniston 

Arlene K. Dennistoun 

Richard Dentem 

Cathy A. Desmet 

Susan Deth 

Bill Devall 

Lisa Devaney 

Edmund L. Devereaux, III 

Barbara Devner 

Derek Dexheimer 

T. Dicker 

Tom Dickinson 

Andrea Diephuis 

Mary Pat Dileva 

Chris Dillard 

Tom Dimitre 

Marilyn Dinger 

Karen Dingmon 

Brian L. Dipert 

Jim Dipeso 

Charles Dixon 

Jerry Dixon 

Damian Dlugolecki 

Kim M. Dobson 

Andrew K. Dockhorn 

Hudson Dodd 

Nancy Dollard 

Karen Dolphin 

Leif Donlan 

William L. Donnelly 

Stephen Donnelly 

Alec Donoso 

Kate Doran 

Don Dorman 

Herbert W. Dornbush, Jr. 

Anne L. Dorsey 

Dudley Doss 

Patricia Doud 

Anne E. Douglas 

Dennis & Elsa Douglass 

David Dragos 

Meyer Drapkin 

Ricky Drawhorn 

Joe Dray 

Michael & Karen Dreiblath 

Violet Drennan 

Susan Drew 

Maureen Driese 

Dean A. Drugge 

Michael Drumheller 

Jonathan Dubay 

Jennifer Dubois 

Denis Dubois 

Courtney Dubois 

Kirk Dubose 

Michael E. Dubrasich 

Branden Dubst 

Marilyn Duchoff 

Nick Duckstein 

Lori Duda 

Barbara Dudley 

Barbara Dudman 

Jennifer Duffy 

R.J. Dufour 

Christopher S Duke 

Jon Duke 

Anne Dulfer 

Chris Dulis 

Joyce Duncan 

Sarah Duncan 

Anne Dunlap 

Dennis R. Dunmyer, II 

Joan Dunn 

James A. Dunn 

Nathan Dupre 

Moses Durazo 

Andrea Dworkin 

Mary E. Dyson 

Gregory J. Dyson 

Allyson Earnest 

Darla Eaves 

Shanette Echols 

Lars Ecklund 

John Eckman 

Jim Eckman 

Liz Edmondson 

Cory Edwards 

Deborah Efron 

Johan Eichmeyer 

E. Eisen 

Hilary Eisman 

Maya Elashi 

J.W. Elder 

Bill Elder 

Jacquelyn Ellenz 

Nancy Ellis 

Lorne Ellis 

Myrriah K. Ellis 

Greg Ellis 

Thomas I. Ellis 

Linda Ellsworth 

Aaron Elman 
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

75

Caroline Elman 

Alice Elshoff 

Todd Elsworth 

J. Denise Elway 

Trent Elwing 

Lynnzee Elze 

H C Ely 

Amelia Ender 

The Engelfrieds 

Ute Engelke 

Claire Englander 

Karen Engle 

Melissa English 

Wayne & Jo Ann English 

Nancy Engst 

Karin S. Engstrom

Dianne Ensign 

Walter Epp 

Lynn Epstein 

Carolyn Erbele 

Susan Erickson

Anne Erlandson 

Brent Erskine 

Grace Ertel 

Marjorie Erway 

Lauren Escobales 

Ben Eshelman

Joan Espana 

Adrienne Esposito 

Rick Esterly 

Rose Estes 

Gregory Esteve 

Felicity Eubanks 

Shirlee Evans 

Susan Evans 

Todd Evans 

Joey Evans 

Zac Ezrin 

Jack Fackerell 

Susanne K. Fahrnkopf 

Jim Fairchild 

Louise & Jenny Falkoff 

Pete Fallac 

Peter A. Fallaw 

Catherine Fallon 

Steffen Fanger 

John Farak 

Sarah Farber 

Paul & Sarah Farrell 

Brittney Farrow 

Susan H. Farrow 

Sarah P. Faulconer 

Kristin & Dan Faulkner 

Greg Fawcett 

Lynell Fay 

Jesse Feathers

Suzanne Feiner 

John Feit 

Dorene Feld 

A. Felix 

Richard Felley 

John Felsner 

Fred Felter 

Shelley Ferer 

Jannette Ferguson 

Brian Ferguson 

Nicolas Ferlott 

Marc Fernandes 

Matthew L. Fero

Charles J. Ferranti 

Charles Ferris 

Carolyn Fershtman 

Hyla Fetler 

Eberhard E. Fetz

Marjorie Fields 

Nancy & Tom Fiene 

Deborah Filipelli 

Jules Filipski 

Elizabeth Filmer 

Ann Marie Finair 

Alex Finder 

Karen Fineide 

Richard Finlap 

R. Finlay 

Rosanne Fisch 

Justin Fischer 

Maureen E Fischer 

Hyland Fisher 

Dennis Fisher 

Erik Fisher 

Josh Fister 

Annemarie Fitzell 

Teasha Fitzthum Feldman 

Stephanie Flach

Rachel Flading 

Leah Flaks 

Marie A. Flanagan

Peter C. Reilly & A. Flannery 

Daniel Flannery 

Robin Flatow 

Sue Fledman 

Fredric L. Fleetwood 

Sheri Fleming 

Kathy Fletcher 

Michael V. Flores

Dawn Florio 

Edward Flounoy Jr 

Bobbie D. Flowers 

Shelley Flynn 

Susan Flynn 

Sarah Fogel 

Chris Fontenot

Merritt Ford 

Scott Forrester 

Lisa Forsberg 

Leonard Forsman 

J.K. Fort-Strietzel 

Demi Foster 

Whitney Fouler 

Dawna Fowler 

Jeff Fox 

Willow Fox 

Kirk Francis 

Clay Francis 

Rebecca Francis 

Bea Frederickson 

Charles R. Freed 

Michelle Freed 

Marilyn J. Freedberg 

William Freestone 

Kim Freet 

Julia Freewoman 

J.W. & Madelaine Freidmann 

Clark D. Frentzen 

Constance Frenzen 

Janice Freund 

Chris & Laura Frick 

Ariel Fried 

Becky Fried 

H.E. Fried 

John Friede 

Cameron Friedman 

Charles Friedman 

Leanne Friedman 

Laurie Friedman

Greg Fritzberg 

Jonothan Frochtman 

E. Frodsham 

Jeffri Frontz 

Christopher Frost 

Robert K. & Irene C. Froyd 

Emily Fruchtman 

James Frye 

Chris Fuess 

Ryan Fuld 

Christian Fulghum 

Linda Fulmer 

Steven L. Funk

Victor Furman 

Desiree Furness 

Margaret Furstnau 

Lynnett Fusaro 

Stephen J. Gabor

Marley Gaddis 

Keith Gagomiros 

Francine Galebert 

Eduardo Gallo 

Mamie Galston 

Gayelynn Galusha 

G.L. Galusha 

Tara Galuska 

Kinson Ganivych 

Nancy Gankon 

Patricia M. Gannon

Lyn Gannon 

Deborah Gant 

Alex Gaos 
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

76

Sonya Garbutt 

Cynthia Ann Garcia 

Teresa Garcia 

Nadia Gardner 

Ginger Garff 

Elean Garison 

Marie Garon-Maloy 

Kima Garrison 

Courtney Gartin 

Shawn Garvey 

Victor Gates 

Ricky Gates 

Nancy Gathing 

Doug Gaulke 

Juliet Gault-Thomas 

Larissa Gauslard Tatso 

Steven Gausrow 

Rebecca Gaynor 

Barbara Geiger 

Lindsay Gelb 

Strauss George 

Alberta Gerould 

Russ Getchell 

Paul Ghosthorse 

Dana Giffen 

Liz Gifford 

Patricia Gilbert 

Kent Gill 

Raymond Gill 

David Gillingham 

Joseph Gillock 

Monica Gilman 

Kevin Gilmore 

Andrew Gilmore 

Keith Gilroy 

Joe Ginsburg 

Adam Girgent 

John Gjolmesli 

Gertrude Glad 

Phillip E. Gladfelter 

Ora Gladstone 

Samuel Gladstone 

Philip Glaser 

Cheyenne Glasgow 

Amanda A. Glasser 

Henry & Jeremiah Glazer 

Bradford Gleim 

Marie Glennon 

Barry & Jacob Glicklich 

Jerry Goad 

Ginger Goble 

Rachel Goeke 

Norman Goetz 

Jillian Gold 

Ami M. Goldberg 

Alex Goldblatt 

Muriel E. & Marvin C. Goldman 

Meadow Goldman 

Adam & Matt Goldman 

Lawrence & G. Goldstein 

Alex Goldstein 

Ian Goldstein 

Arthur M. Goldstein 

Elliot Goliger 

Jeffrey Goll 

Jan & Wayne Gombotz 

Daniel E. Gonsor 

Dan Gonsor 

Barbara & Rob Goodell 

Darcella Goodman 

Matt Gordon 

Nicole Gordon 

Jim B. Gordon 

Jim B. Gordon 

Patrick Gorman 

Kimberly Gossen 

Brian Gottlieb 

William Gould 

William & Jacqueline Gould 

Alberta Gould 

Gail Gove 

Thema R. Gower 

Connie Mack Gradoville 

Melinda Graetz 

Ann Graham 

Tonya Graham 

Donald Graham 

Jenna Grauer-Gray 

Regina Graves 

Steve Graves 

Mike Graves 

Hannah Gray 

Michael Greco 

Katrina M. & Dana J. Greeley 

Ruth A. Green 

John Green 

Cynthia Green 

Steve Green 

Jonathan Greenberg 

Matthew Greenberg 

Kristin Greene 

Alan Gregory 

Kraig Greiner 

Linda & Robert Gresky 

James Greve 

Eva Marie Grey 

Mark Gribbons 

Adrian Griffin 

Dian Griffith 

Todd Griffith 

Suzanne G Griffith 

Marie L. Griffith 

Robert Griffiths 

David W. Griffiths 

Melissa Grimm 

David Grimmer 

Monique Grindell 

Simone Grissette 

Barbara Gross 

Nancy Gross 

Elizabeth Grossman 

Richard T. Grost 

Christian Groth 

Karen Groth 

Steve Grotten 

V. Lee Grover 

Ed Grumbine 

John Guccione 

Ronald L. Guiles 

Jea Gundry 

Mel Gurtov 

Lisa L. Gust 

Judith Gustafson 

Candice Guth 

M. Gutierrez 

Justin Guttman 

Henry Guttman 

Gary & Jan Guttormsen 

Catherine Haber 

Danielle S. Haber 

Sheryl Haber 

Julie Hackworth 

Michael Hadley 

Dylan Haggerty 

S. Erik Hagstrom 

Kyle Haines 

Sara L. Hains 

Jim & Rosie Hajek 

Gary Hale 

David Hale 

Connie Half 

Jill Hall 

Kevin Hall 

Paula Hall 

Jeremy Hall 

Anne Hallee 

Tom Halley 

Karen Halliday 

Andrew Hallman 

Kyle Halmrust 

Sue Halupowski 

Annette Halvorson 

Scott Hamersly 

Ron Hamill 

Sandra Hamilton 

Maryjane Hammel 

Ruth & Ben Hammett 

Jessica & Thomas P. Hammond 

Ned Hamson 

Lillian Hanahan 

Leigh Hancock 

Robert F. Haney 

Darcy Schultz Hanita 

Jack & Astrid Hanke 

Kelly Hanlon 

Norman Hanscam 

Mark R. Hanschka 

John Hansen 

Ted Hansen 

Doug Hansen 
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

77

Courtney Hanson 

Robert Hanson 

Larry Hanson 

Elaine Harans 

Laura A Harders 

Frank J. Harmon 

Tasha Harmon 

Zeke Harms 

Harry A. Harms 

Robert A. Harms 

Carolyn Kay Harper 

James W. Harrington, Jr. 

Courtney Harris 

Michael Harris 

Ashlee Harrison 

Larry & Janet Harshfield 

Connie L. Hart 

Ted Hart 

Susan R. Hartford 

William Hartl 

Alan Hartley 

Jed Hartvenk 

Margaret Hartzell 

Kristin Hasselblad 

Joan Hasselgren 

John V. Hastings 

Walter T. & Batty Y. Haswell 

Andrew Haugen 

Ryan Hawkes 

Charles Hawkins 

Anne E. Hay 

Danielle B. Hayashi 

Catherine Hayden 

Justin Hayes 

Joseph Haynes 

Lynn Hays 

David Head 

Kevin Head 

Shannon Healey 

Amy Healy 

Brian & Joy Healy 

Alan Healy 

Reginald James Heath 

Bruce Hecht 

Brandy S. Hedger 

Emma Heiken 

Jain Hein 

Dave Heiss 

Gary A. Hekkanen 

Benjamin Heller 

Lorraine Heller 

Kenneth & Harriet Heller 

Lisa Hemmert 

Lisa Hemphill 

Erin Michelle Hemric 

DE.H. Henderson, Jr. 

Rebecca Hendon 

Daniel Henling 

Kevin Hennegan 

Tim Hennessy 

Peter Henry 

Chris Heppe 

Diana Herbst 

Rodger Herbst 

Jo Ann Hereford 

Robert Herren 

M. Hershfield 

Lavernna Hess 

Kent Heuer 

Lauren Hewitt 

Ted Hewitt 

Catherine Hickey 

Jessica Hiemenz 

Alan & Annette Higinbotham 

Sara Hilbrich 

Ruth Hildner 

Matthew J. Hill 

Gregory Hill 

Larry Hill 

Karie Hillery 

James Hines 

Paula Hinman-Scott 

Betty Hittler 

Adam B. Hixon 

John Hjelmstad 

Julie Hochfeld 

Ted Hochstadt 

Sara Hockert 

Patrick Hodges 

Bob O. Hoehne 

Marcia & Brian Hoelzen 

Randi Hoenig 

Eileen Hoenig 

John C. Hoer 

Diane Hoffman 

Daniel F. Hogan 

Dale & Clark F Hogle 

Joe Hohlfeld 

Terry Hohner 

Pamela K. Hoke 

Axel W. Hoke 

Ray Holbool 

Ted Holdt 

Ann Holland 

Melisa Holman 

Cheron Holman 

Mary Holmes 

Sean Honeychuch 

Fred Hoover 

Kevin M. Horace 

Heye Horlings 

Andrew Horn 

Jean Horn 

Matt Hornback 

Gayle Hornell 

Michael F. Horner 

Amy Horowitz 

Deonne Horton 

Liz Horvath 

Wes Hoskiins 

Richard E. Hoskins 

Joseph Hostler 

Emily Hoteling 

John Houck 

Janet Houghton 

Tasker Houston 

William N. Howald 

Robert E .Howard 

Toni Howard 

Cassandra Howe 

Susan Hoyt 

Brad Hoyt 

Karin L Hoyt 

Carol Hubbird 

Katherine Huber 

Patrick Huber 

Craig Hubu 

Chris Huff 

David Huffaker 

Angie Hughes 

Patrick Hulett 

Rose Hulls 

Julie & Rob Handy Hulme 

Bruce Humes 

Bill Hunger 

David Hunt 

Natalie Hunt 

Elizabeth Hunter 

Albert E. Hunter 

Blake Hutchins 

Janice Hutchinson 

Terrance Hutchinson 

Sally Hyde 

Jeannie & Jim Ianelli 

George Imrie 

Tiffany Inglett 

Julie Ireland 

Lura B. Irish 

Miles Irwin 

Allison Isaak 

Nancy Iscovitz 

Raye & Sheldon Isenberg 

James Israel 

J. Israelachvili 

Wayne Iverson 

Kristen Jaax 

Sego Jackson 

Erlene Jackson 

Bruce Jackson 

Veronica Jacobi 

Debra Jacobsen 

Diane Jacobstein 

Lisa Jaffee 

Melissa Jahnke 

Laurence Jalangan 

Kurt L. James 

Sarah James 
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Beth James 

Susan Schumaker James 

Loretta Jancoski

Steve Janosik 

John K. Jansen

Delmar Janson 

Marilyn Jasper 

Eugene Javens 

Melisa Jencks 

Michael Jenkins 

Carolyn Jenkins

Carol Jenkins 

Luke Jennings

Tel Jensen 

Tomas Jensen 

Greg Jirak 

Vicky Johns 

Michael M. Johnsen 

Valerie Johnsen

Steve Johnson 

James & Samalee Johnson 

Siri Johnson 

Gordon Johnson

Tara Lee Johnson

Sara Johnson 

Pamela Johnson

Eugene Johnson

Thom H. Johnson 

John Christopher Johnson 

Mark Johnson 

Susan Johnson 

Michael Johnson

Judy Johnson 

Kirk Johnson 

Margaret Johnston 

Stuart Johnston

Amanda Johnston

Susan Jonas

Judy Jones 

Mary Jones 

Samuel Jones 

Matt Jones 

M.L. Jones 

Carla Jonientz 

Sandra Joos 

Marjorie Jordan 

James Jordan

Karl Jordan 

Lynnda Jordan

Ted & Diana Jorgensen 

Mary Anne Joyce 

Cory & Beth Julie 

Linda Kadas 

John Kador 

Tim Kadrmas 

Kevin Kahn 

John Kaiser 

Stephan M. Kallus 

S. Kamelgard 

Jeremy P. Kamil

Sarah Kane 

John Kannin 

Matt Kapko 

Charles Kapner 

Lawrence Karol 

Sylvia D. Kassalow 

Jonathon & Mitchell Kassoff 

Richard Katzdo 

Adene Katzenmeyer 

Jane Kauffman 

Joshlyn Kaufman 

Albert Kaufman 

Tina Kaye 

Philip Kazmierowicz 

Betty Jean Keele 

Chelsea Keenan

Timi Keene 

Carolyn Kehoe 

Jennifer B. Keller

Lori Keller 

Matt Keller 

Tiffany Kellett 

Christopher Kelley 

Geoff Kelley 

Mary E. Kelley 

Patricia Kellogg 

Bev Kelly 

Kathryn Kelly 

Pira Kelly 

Stephen Kemp 

Richard Kemper 

Terence Kendrick 

Linda C. Kenis 

Michael J. Kennedy 

Jean Kent 

Ed Kenyon 

Eric Kerekes 

Cheryl Kerner 

Abby Ketner 

Jason Keyes 

Mha Atma S. Khalsa

Youssef Khodaparast 

Jim Kidwell 

George Kiesel 

Forrest Kievrt 

Amy Kiffe 

Alan Kilgore 

Sharon Killay 

Matthew Killian 

Jefferson Kincaid 

John & Ellen Kindsvater 

Ed King 

Angela King 

Kay King 

Lois King 

Cristin G. King 

Joanne Kinghorn 

Anne Kinnaman

Jeff Kipilman 

Kate Kirkham 

Amy Kirkland 

Norton & Saran Kirschbaum 

Robert & Eileen Kirschner 

Susie Kisber 

Lorna Kitchen 

Jennifer Klaudinyi 

Howard B. Kleckner 

Annie Kleffner 

Richard & Ellen Klein 

Fred Kleindenst 

Gregg Kleiner 

Gregory Kleiner 

Jessica Ann Klinkert 

Roseann Klipper

Charles Klyn 

Amber Knapp 

Tyler Knapp 

Holly Knight 

Phil Knight 

Emily Kodama 

Leah Koehn 

John Koenig 

Steven Kohn 

Kathryn Kolb 

Art Koning 

Brian & Ashley Kotkin 

Jo Ann Kots 

Aaron Kottke 

Karen Kovalik 

Dawn Kozin 

Anne Krancus 

Jim Kraus 

Ben Kraus 

Terri Krauthamer 

Jerry Kravitz 

Laura Krebsbach 

Rich Krenkel 

Dale Krewson 

Fred Krieger 

Valerie Krull 

Mary Ann Kruse 

Jim & Jill M. Krymkowski 

Katherine Kuber 

Chad Kuipers 

Joel Kuperberg 

Dane Kuppinger

Lorna Kurtz 

Aurora Kushner 

Nora B. Kyte

Christopher Laarman 

John Laboyteaux 

Jared Lafave 

Jorah Lafleur 

Henry M. Lagergren 

Jeannie Lagor 

William Lagrange 

Jeffrey Laing 

Margaret Lake 

Crystal Lamb

Fish Lambert 

78
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Robert Lance 

Dave Lander 

Jessica Lane 

Mary B. Lane 

Alfred F. Lang 

Kenneth Lang 

Michael Lang 

Julie Langabeer 

John Langan 

Harley Langberg 

Jerry Lansdowne 

Dan Lappin 

Consuelo Larrabee 

Tim Larrabee 

Hannah S. Larsen

Nathaniel Larsen 

Brian Larson 

Karen Larson 

Kenneth J. Larson

Margaret J. Larson

Sam Larson 

Anthony Lash

Katherine Lato 

Jeanne Latorre

Kirsten Lau 

Dina Lauman 

Susan M. Lavelle 

Tom Lawler 

Jill Lawrence 

Rhett Lawrence

Frank Lawton 

Bruce Lax 

Karin Lazarus 

Howard Lazzarini 

Ron Leach 

Everett Leader 

Martin Leblanc 

Elese Lebsack 

Lynn Ledgerwood 

Christopher Lee 

Ken Lee 

Robert E. Lee, Jr.

Kimberly Bixler Leeds 

Luann & W. Leeds 

Robert Lee-Engel 

Ruth Lefevre 

Rachel Lehman 

Jack Leishman 

Jon Leland 

Bill Lemaster 

Judy & Maya Lentz 

Sharon Leonath

Darrel Lepiane 

Nancy Lerner 

Laverne Leroy 

Maria Lesan 

Dawn Lesley 

Rebecca Lester 

Michael Letendre 

Nete Leth 

Jim Lethbridge 

Kianna Levay 

Mark Levensky 

Caren Levenson

Sara Levien 

Daniel Levin 

Joel Levin 

Brian Levin 

Bertram Levine

Shana M. Levy 

Susan Levy

Philip Lewin 

Brett Lewis 

Leslie Lewis 

Jackie Lewis-Penner 

Lori Leyert 

Kam Li 

Daniel H. Lichtenwald 

Jerry Lieermann

David Lien 

Karen Lillebo 

Elizabeth Lim 

Nathan Limprecht

Richard Lind 

Penny & John Lind

John Lindberg 

Carl A. Linde 

Paula Lindsay 

Janet Lingren

Mona Linstromberg 

Richard Lintermans 

Elaine Lipson 

Tamara Lischka

Robert Litak 

Anahata (Patricia) Little 

J.A. Littooy 

Eleanor Livingston 

Sara Livingston

Nicholai P. Lliinsky 

Tara Lloyd 

Mikelle L. Loar 

Cliff Lobaugh 

Dianne Lobes 

Deborah Lockwood 

Otto Loenneker

Leslie Logan 

Ray & Pat Logan 

Corina Logan 

Stephen London

Paul Loney 

Nichole Long 

Jolie Lonner 

Dave & Laura Loomis 

Jonathan Lotz

Kim Louvring 

Lorrie Anne Loveman 

Jeffrey Lowe 

Andrew Lowley 

Jim Lowrie 

Lane Lubbe 

Lisa Lucas 

John Ludwig 

Paul Lufkin 

Pepper Lumina

Freya Lund 

Mark Lundgren 

Krista Luoto 

Richard Luther 

Didy & Martin Lutz 

Jakki Lutz 

David Luxem 

Abigail Lynam 

Dennis Lynch 

Susan Lynch

Karen Lynch 

Pamela Jean Lynch 

Roberta Lyon 

Sanford Mabel 

B.C. Macdonald

Linda Macias 

Tammy Mackey

Craig Mackie 

Merry Mackinnon 

Sheila Macmanus 

Geoff Macnaughton 

Julie Macpherson 

Diann Macrae 

Nancy B. & Kenneth L. Macy 

Erin Madden 

Laurra Maddock 

Michael Madias 

Roger Madison 

Elaine Mahaffey

Daniel Maiden 

Beth Maizes 

Suzanne Malek 

Jim Malinowski 

Gail Mallimson 

Anthony Mallott 

Doug Malone 

Rhonda Maloney 

Andy Malucelli 

Ivan & Carter Maluski 

Sophia Mamoyac 

Lloyd Mancl 

Hannah Mandala 

Francis W. Mangels 

Richard M. Man, III 

Mike Maniller 

Jake Mann 

Richard Paul Mann, II 

Ken Mantel 

Joanna Marek 

Brent & Lawrence Margolin

Gail Mariansky 

Alan S. Markee 

Isaac Markehe 

79
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

Elizabeth Markell 

Craig P. Markham 

Krista Markovic 

Sunrise & Karen Marks 

Manuel Marks 

Richard Marlatt

David R. Marr 

Ben Marra 

Mary P. Marsh 

Don Marsh 

Karen Marshall 

Roy Marshall 

Kelsey Marshall 

Lisa Marshall 

Rick Marshall 

Larry Marson 

Mike Marston 

Felicia Martin 

Laura O. Martin

M. Kathleen Martin 

Dennis Martin

Beth Martin 

Chris Martin

Christopher Martin 

Denis Martynowych 

Alexis Marzolf 

Jackie Mason

Paul J. Mason 

Theresa & Moriah C. Mason

Christine Masters 

Jared Matas 

C. Mark Mathews 

Gina Mathias 

Mary Ann & W.V. Matthews 

Jonathan Matthews 

Patricia Matthiesen 

Tara Mattis 

Megan Mattison 

Victoria Maturo 

T.L. Maul

Bill Maxwell 

Daniel Maymar 

Misha Maynerick 

John Bernard Mazzariello 

James C. & Marylou G. McAdoo

Kristine McCabe 

Richard W. McCarthy 

Frances McChesney 

Vannessa McClelland 

Malcolm McClinton 

Kevin McCloskey 

Melissa McClure 

Marianne McColly 

Teresa McCormick 

Tom & Janet McCormick 

Mari & Frank McCracken 

Brian McCredie 

Linda McDaniels 

Timothy McDermond 

Jennifer A. McEwen 

Shelly McFarland 

Marilyn McFarlane 

Pamela McGillonay 

Tim McGivern 

Robyn J. McGlade 

Colleen McGlone 

Gail McGlone 

Jill McGrath 

Dave McGraw 

William D. McGrew 

Dan McGuire 

Paul K. McGuire 

Shannon McKean 

Leigh McKeirnan 

Kathryn McKenzie 

Brie-Anne McKernan 

Jamie McKinney 

Joseph McKinnon 

John McLaughlin 

Kriss McLaughlin 

Marilee McLean 

S. McLennan 

Justin McLoed 

Bill & Carol McMeekin 

Kris McMillan 

Irene McNamara 

John McNeely 

Loriann McNeill 

Joshua McNett 

Thomas McNicholas 

Christy Mcquillan 

Loyal A. Mehrhoff 

Linda Meier 

Glen T. Meili 

Edward Mello 

Elizabeth R. Meluk 

Carol Mendelsohn 

Libby Mendenhall 

Karen Menehan

Michelle Merciere 

Ed Meredly 

Robert Merriott 

Regna Merritt 

Theodore C. Mertig 

Colleen Meservey 

Jacqui Metzgel 

Bruno C. Meyer

Ronald Meyer 

Marc Meyer 

Joyce & Shira Meyerowitz 

Tracy Michaels 

Susan Michaels 

Reid Mickelsen 

Leah Mickelson

Corinne Middendorf 

Travis Miecnikowski 

David Mildrexler 

Stephen Mildrexler 

Brad Miller 

Jennifer Miller 

Bonnie E. Miller 

Hannah E. Miller 

Ron & Jill Miller 

John Miller 

David Miller Engel 

Joseph L. Miller, Jr. 

Daniel Millerson

Dale D. Mills 

Donna Ewing & Sue Minahan 

Karen Minc 

Don Minnerly 

Don Minore 

Gary R. Minton

Leigh & Carol Mintz 

Dawn Misawic 

Ashley & Zoe Mitchell 

Angela Mitchell 

Amis Mittelman

Osborn Moe 

Albert Moehl 

David Moen 

Helen Moller 

G.L. Monahan 

Mitch Monetti 

Mary Monrey 

William Montgomery 

Dan Montgomery 

Jeremy Montz 

Steven Moore 

Bill Moore 

Bruce Moore 

Kevan Moore 

Anthony Moore 

Mardell Moore 

Erin Moore 

Diane Moore 

Marie Louise Morandi Long Zwicker 

Damon Moreli 

Paul Morgan 

Jason Morgan 

Patrick Moriarty 

Stuart Mork 

Larry Morningstar 

Daniel & Andrea Morphis 

Don Morrill 

Thomas G. Morris

Mat Morris 

Jim Morris 

Soula Morris 

Bradley Morris 

Curtis A. Morris 

David Morrsion

Scott E. Mortenson 

Tim L. Mosby 

Kari Mosden 

Dottie Moseley 

Mary Beth Moser 

Maria Moses 

Susie Moskowitz 

Robert Moss 

80
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

81

Paul Moss 

Jason Motsko 

Michelle Moyer 

.J Fraser Muirhead 

Marilyn & William Mull 

Jim Mulligan 

Joanne Mulloy 

Ellen Multauk 

Tony Murczek 

Bonnie Murdock 

Elizabeth Murphy 

Michael H. Murphy 

Adam Murphy 

Melissa Murray 

Ragen Murray 

Linda & John Murtfeldt 

Ryan Murtfeldt 

Bruce Murtha 

Rochelle L. Musa 

Devon Musgrave 

Ralph Myer 

Karen Myers 

Susan B. Nachimson 

Alex Nachman 

Keri Nadler 

Dina Najman 

Rich Nawa 

Christy Neal 

Katrina Neber 

Joshua Neckerson 

John Neergaard 

Margaret B. Neerman 

Andrew Neerman 

Grace Neff 

Fred Neil 

Roy Nelsen 

Debra Nelson 

Ronald & Janet Nelson 

Matthew D. Nenninger 

Ruth Nesbitt 

Kerry H. Neuville 

David Nevins 

Beth L. Newberry 

Ray Newcombe 

Ray Newkirk 

Sabrina Newman 

Ivy Newman 

Carol Newton 

Deborah Nicely 

Luma Nichol 

Allan Nichols 

Carol Nichols 

Sarah Nichols 

Leslie Nicholson 

Natalie Nicklett 

Mark Nielson 

Bob Nisbet 

Laura Nobel 

Madeline & Scott Noe 

Mary Jane Nolan 

Chris Norden 

Craig Nordling 

John Norem 

Brenda Nores 

Kari Marie Norgaard 

Gayle Norie 

Bradford Norman 

Joan Norman 

Richard Norris 

Dick North 

J.D. Northrup 

Elizabeth Norton 

Timothy Novak 

Clayton Novak 

Emily Nuchols 

Sarah A. Nunn 

J.M. Nurius 

Joseph Nyderek 

Kenneth O. Fulham 

Nicole E. Oakland 

Deborah B. Oatey 

Michael Ober 

Michael O'Brien 

Sarah Ocasek 

Annie Ocean 

Dolphine Oda 

Jane Odin 

Juliana O'Donnell 

Patricia O. O'Donnell 

Jennifer O'Donnell 

Johanna Ogdahl 

Nanette Oggiono 

K. Oglesby 

Janice Ogsbury 

Kathryn O'Halloran 

Conan O'Harrow 

Karin Olefsky 

Rose Oliver 

William & Helga Olkowski 

Jodie Olofson 

Jerry Oltion 

Jeff Omundson 

Jim O'Neil 

David O'Neil 

Beth Opazo 

Andrew J. Orahoske 

Lauren Orton 

Oliver Osborn 

Mara Osborne-Koch 

Michael C. O'shea 

Amie Osowski 

Donna Osseward 

Alex Ossola 

Ben Osterberg 

Mady Ostwaldii 

Donal O'Sullivan 

Doug Oswald 

Marjorie Ann Ottenberg 

Kristin Otto 

Tracy Ouellette 

Jan Overstreet 

Sean Owen 

Robert Owens 

James Packman 

Gordon Frederick Padelford 

Kathleen Page 

Michael Palandri 

Janine Panna 

Sue Pappalardo 

Erika C. Para 

Claudio G. Parazzoli 

Amalia Parecki 

Andrew Park 

Tari Parker 

Wayne Parker 

Jerry Parker 

Amy Parks 

Susan Parr-Krupinski 

Luanne Pasik 

Roger F. Pates 

Kristi Patten 

Craig Patterson 

Bruce Patterson 

Nellie D. Patterson 

Anne Paulet 

Marc Paulman 

Jean Paulson 

Stephanie Payette 

Anna Beth Payne 

G.L. Pearce 

David Pearson 

Mary Pease 

Chauney Peck 

Brian Peck 

Michael Pedersen 

John R. Pedersen 

Judy Pegg 

Rachel Pelican 

Greg Pelletier 

Rodd Pemble 

Johann M. Pena 

Jeanne Pendergast 

Rich & Rosemary Pennell 

Deanna Penwell 

Myra K. Perala 

Keith Perchemlides 

Todd C. Peres 

Tamra Perez 

Elaine & Ed Perkins 

Frances Perlman 

David & Edward Perlow 

Claire Perricelli 

John C. Perry 

Sarah Perry 

Eileen Perry 

Richard S. Perry 

Michael Pesa 
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

82

Brian Peterman 

Richard M. Peters 

Thom Peters 

Susan Peterson 

Tate Peterson 

Susan Peterson 

Sean Peterson 

Everett Peterson 

Robert Pfeffer 

Stephanie T. Phan 

Michael Phelps 

Carolita Phillips 

John F. Phillips 

Donna-Lee Phillips 

Ruth M. Pickering 

Sarah Pideisen 

Matthew Pidgeon 

Michael M. Piehl 

Ryan Pierce 

David Pilz 

Jay Pine 

Nicole Pines 

Ron Pio 

Carol Pippin 

Jackie Plankers 

Jim Plato 

Bob Plummer 

Emily Plummer 

Sarah Plymate 

David Poese 

David Pogel 

Kyle Pogue 

Nicholas Polato 

Tessa Poncelet 

Michael L. Pond 

Mabel P. Pool 

William T. Pope 

Kalista Popp 

Delores Porch 

Curt Porter 

Chelsea Portnoy 

Carol Porto 

Andrew Posner 

Harry Potter 

Thomas D. Potter 

Alan Potter 

Karen Potter 

Nancy Powell 

Jaquelyn Power Kleiner 

Wendy Powers 

Julian Powers 

Eve Powers 

John E. Poynter 

Carl Pratt 

Carly Pratt 

Charlie Press 

Jocelyn Preston 

Jenifer Preston 

Jennifer Price 

Joy Prideaux 

Carol Pridgeon 

Sarah Prince 

Tom Pringle 

Morgan Pritchard 

Sean Prive 

Gradey Proctor 

H.D. "Dutch" Propst 

Guy Prouty 

Christine Puddicombe 

Bob Pullum 

Sandy Pyonin 

Tamara M. Quandt 

Harry Quarles 

Erin Questad 

T. James Quilter 

Ginger Quintanilla 

Dana Rabhin 

Richard Radliff 

Sara Raffa 

Dorli T. Rainey 

Bonnie Raitt 

Barbara Rajabi 

Ajay Ramachandran 

Ronald Ramey 

Mary Ramos 

Leila Rand 

D.A. Randall 

Timothy S. Randle 

Maryanne Raney 

Steve Rankin 

Alan Ransenberg 

James Ranson 

Jason Rasco 

Jennifer Raven 

Wendy Ravensbergen 

David Rawlins 

Gary E. Rayor 

Peg Reagan 

Paul A. Rebers 

Sherry Redd 

Carol Reed 

Audrey J. Reed 

Marcy Reed 

Ian Reeve 

Cherie Reeves-Rutledge 

Robyn Regula 

Brian Reif 

Fran Reifschneider 

Debbie Reisert 

Deborah Reiter 

L. Reiter 

Kerry Rempel 

Laura Rengel 

Kent Renno 

Michael S. Rentz 

Marc Resnick 

Simon Resnik 

Deborrah Reth 

Dwayne C. Reuklie 

Sigrid Reymond 

Cathy Reynolds 

Jonelle Reynolds 

A. Gordon Reynolds 

Travis Rhoades 

Ann F. Rhoads 

Jon Rhodes 

Fred Ribeck 

Adira Riben 

Ken Rice 

Kiva Rice 

Michael Rice 

Beth Rich 

Louis Richard 

Paul Richard 

Jeff Richardson 

Merle Richlen 

Heather Richman 

Dennis Richman 

Pamela Richter 

Kelli Riddle 

Erin Riddle 

Mona R. Rieger 

Rhiannon Ries 

Angela Rife 

Laura Rife 

Ben Riggan 

Michael L. Rilla 

Peter Rimbos 

Roberta Rinehart 

Jill Ripley 

Clayton Rippey 

Adam Rissien 

Beatrice Ritchie 

Kate Ritzenberg 

Jared Roach 

Elizabeth Roberts 

Jason Roberts 

Melissa Roberts 

Danielle Robillard-Flower 

Sara Robinette 

Darlene Robinette 

Adam & Nicole Robinson 

Peggy Robinson 

Sumner Robinson 

Keegean Robinson 

Christopher Robinson 

Bruce M. Robison 

Rhonda Robles 

Karlee Rockey 

Althea Rodgers 

Nick Rodin 

Jeffry Rodin 

Lisa H. Roe 

Robert J. Rogers 

Lila Rogers 

Jim Rogers 

Ann Rogers 

Alexis Roholt 

Terry Rohtrock 

A. Rojek 
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

83

Santa Role 

Jody Rolnick 

Leslie H. Romer 

Richard Romito 

Linda Root 

John H. Roscoe 

Rett Roscoe 

Janaki Rose 

Tom Rose 

Michael Rose 

Becky & Shelly Rosedale 

Suzanne Rosemarin 

Paul W. Rosenberger 

Liese G. Rosenblum 

Larry Rosenthal 

Marlene Ross 

Hilary & Ken Ross 

Leslie Rossmell 

Bethany Roth 

Portia & Israel Rotkin 

Wolfgang Rougle 

Matt Roundtree 

Paul Roush 

Dwight Rousu 

David Rouzer 

Freeman Rowe 

Stephen Roxborough 

Tucker Ruberti 

Andrew Rubin 

Sonseeahray Rucker 

Donald Rude 

Lyle Rudensey 

Dave & Ruthe Rugh 

R.B. Rumain 

Karen Ruppert 

Brent Rusert 

Samuel R. Rushforth 

Jay & Jean Rusmore 

Monica Russell 

Robert Russell 

Michael Russell 

Jeremy Russell 

Fay Ruth 

Cheryce Rutkai 

Gail Ryall 

Michael P. Ryan 

Amy Ryder 

Nicholas Sabb 

J. Saber 

B. & R. Sabersky 

Carol Sadusky 

John Saemann 

Ellen Safier 

Terradan Sagewynd 

Maryse Sagewynd 

Viola Saima Barklow 

Ocean Saiter 

Cil Salas 

Janee Sales 

Tammy Salinas 

Kay Sallivan 

Chris & Liesl Sallquist 

Samantha & Daniel Saltzman 

Pan Sammons 

Ivan Samuels 

Blair Samuelson 

Molly Sanders 

Gail Sanford 

P. Sandoval 

Steven B. Sands 

Suzanne Sandstrom 

Ben Sanrit 

Ari Saposh 

Peter Saraceno 

George Sardina 

Robert A. Sarff 

Karla A. Sarter 

Vincent & Biefke Vos Saulino 

Janet W. Savides 

Lesley Sax 

Rosemary Sayre 

David Scanlon 

Michael Sceniak 

Mike Schade 

C. Thomas Schaefer 

Stacy Schaefer 

Amber Schaeffer 

James Schaffer 

Don Schaller 

Nancy & Philip Schary 

Julie Schauffer 

Duane Scheeringa 

James E. Scheib 

Sharon E. Scheib 

Sandi Scheinberg 

Joy Scherzinger 

Ronald F. Scheuerman 

Melanie Schick 

Johnathan Schiff 

Erich Franz Schimps 

Robert Schlesinger 

Elaine Schlinger 

Thor Schmeusser 

John Schmidt 

Mary Ann Schmidt 

Matthew Schmookler 

Kent Schneeveis 

Chris Schneider 

David L. Schneider 

Robert Schnelle 

Gail Schnitzer 

Barry Schoenwetter 

V. Schottlander 

Robert M. Schraaf 

Richard Schramm 

John Schraufnagel 

Dan Schrehoh 

Marjorie Schubert 

Richard Schuh 

Tina Schulstad 

William R. Schultz 

Patricia & Dutch Schulze 

Kathryn Schutte 

Bob Schutzner 

Karen Schwartz 

Andrew W. Schwarz 

Andrew Schwarz 

Carl H. Schwarzenberg 

Luann Schweitzer 

Barbara J. Scot 

Deborah Scott 

Steve Scott 

Donald Seaman 

Colleen Searcy 

Linda Sebring 

Jarl Secker-Jensen 

Reed Secord 

Patricia Seffens 

Jenny Young Seidemann 

Meynard Seider 

Leslie Seki 

Andy Selters 

E. Semon 

Hazel Running Strong Heart Senter 

Linda & Gene & Sarah Sentz 

Robert Sequoia 

Lupine Seran 

Karen Sessel 

Edward Shacklett 

Astrid Shadle 

John Shafer 

Rafe Shaffer 

Peter A. Shank 

Baron Shanklin 

David Shapiro 

Natalie Shapiro 

Gena Shapiro 

John J. Sharkey 

Norm Sharp 

Tehya Shea-Minger 

Gary Murphy Sheets 

Kathryn Sheibley 

Matthew Shellenberger 

Edward & Betty Shelley 

Duane Shelton 

Shunil R. Shenoy 

C. Shepard 

Hope Sheppard 

Ronald Sher 

Sarah Sherburn-Zimmer 

Elisa Shere 

Edward & Susan T. Sherman 

Corinne Sherton 

Gilbert A. Shibley 

Roseahnna Shirley 

Dan Shoe 

Erick Shore 
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

84

Jerry Shultz 

Terence M. Shumaker 

Helene Siegal 

Craig Siegel 

Robert J. Siegel 

Jeremy Siegfried 

Sarah Siler 

Marjorie Sill 

Danny Silver 

Ilene Silver 

Richard Silverman 

Alan Silverman 

Ian Silvernail 

Eileen Simkin 

James Simmons 

Sue Simmons 

Philip Simon 

Dan Simpson 

Tyana Simsich 

Ann Sinclair 

Kate Sirkin 

J. Sitnick 

Gordon Sivley 

Helen Sizemore 

Karen Jeanne Sjogren 

Rolf Skar 

Judy Bluehorse Skelton 

Howard Slater 

Francis D. Slider 

Tina Smedley 

Brent D. Smith 

Dan Smith 

Doug Smith 

Gary Smith 

Jack C. Smith 

Jacquelyn Smith 

Jeff Smith 

Jennifer R Smith 

Julie Smith 

K. Smith 

Kimberly Smith 

Morton Smith 

Petra Smith 

Regan Smith 

Richard W. Smith 

Rick Smith 

Ronald E. Smith 

Rory W. Smith 

Ryan Michael Smith 

Sharon Smith 

Shauna Smith 

Todd C. Smith 

Veronica Smith 

Isaiah Smithson 

Katherine Smolski 

Lois Snedden 

Carolyn Snegoski 

Sharon Snider 

Ann Sniedze 

Barry Snitkin 

Frank Snocker 

Steven Snyder 

Erin J. Snyder 

Naomi Sobelson 

Walt Socha 

Harlan Solomon 

Curt Sommer 

Richard H. Sommer 

Dobby Sommer 

Shirley Sonnichsen 

Anna Sontag 

Kurt Sontag 

Aurora Sosa 

Paul Souders 

Amy Souers 

Nick Southall 

Adam Southerland 

Michael R. Spadafora 

Samuel D. Sparck 

Nancy Spears 

David K. Speer 

Grace Speigel 

John R. Spence 

Joyel Spoden 

Richard Spotts 

Allison Spreadborough 

Mitchell Sprung 

Jeff Sprung 

Laura Srygley 

Jeanne St. John 

Stanley Stahl 

J.W. Stalach 

Isaac Standen 

Elizabeth Stanek 

Janice Stanger 

Jody Stanton 

Sharon Stanton 

Jeri Stastny 

O .Jeffery Stebbins 

Stacy Stech 

Jim Steele 

Debbie Steele 

Patricia Steele 

Jann Steelhammer 

Trygve P. Steen 

Richard Stellner 

Debbie Stempf 

Kate Stenberg 

Kim Stephenson 

Kim Stephenson 

Robert Stepp 

Lewis Sternberg 

Brook Steussy-Edfeldt 

Philip Stevenson 

Lynda D. Stevenson 

John Stewart 

Geneve Stewart 

Jesse Stewart 

Mickie Stewart 

Jeff Stewart 

Janet L. Stewart 

Andre & Cynthia Stewart-Rinier 

Stacy Stiegleiter 

Meghan Still 

Julie A. Still 

S.j. Stockman 

Vivian Stockman 

Jackie Stocks 

Wade Stoddard 

Meghan Stoll 

Eric Stone 

Ned W. Stone 

Gregg Storwick 

Jennifer Stout 

Benjamin B. Stout 

Jeff Strang 

Andrew Stratton 

Patsy Stratton 

Erica Straus 

Kyle Strauss 

Robert Strebeck 

Sally A. Streeter 

Simone Streeter 

Bill Strickland 

Ann Huntington Strieter 

Jean Stril 

Emilia & Tara Strogon 

Hans Stroo 

Jen Sturgill 

Carleen Sturman 

Meera Subramanian 

Renee Red Gesse & Such 

Francie Sullivan 

Bethany Sullivan 

Jennifer Surdy 

D. Sutter 

Chris Sutton 

Arland Swanson 

J. Swanson 

John R. Swanson 

Linda Swanson-Davies 

Roberta Swearingen 

Eddy Sweet 

William Sweet 

Wesley Sweitzer 

Tracy Swenson 

Catherine Syverson 

Doe Tabor 

Adam Tabrys 

Alan Taeger 

Patti Taksa 

Laura Talga 

Trevor Talley 

Mindi Tambellini 

Mona Tanaka 

Kimberly Tanner 

Deloris Tarzan 

Ted Tash 

Ann Tattersall 

Edward S. Taub 
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

Susannah Wood Tavernier Sylvia Troy Mary Wahl 

A. Marc Taye Jake Truen Chris Walbrecht 

Barbara L. Taylor Jerry Tuler Gregory A. Walbrecht

Dan Taylor Patricia H. Tuley Randy Walcott 

Ted Taylo,r Jr. Jeanne Turgeon Sarah Wald 

Ariana Taylor-Stanley Helen Turner Carolyn Waldow 

Aldrin Teganeanu Kelli Turner Lisa Wale 

Saundra Thixton Philip Turner Dorothy Walker 

Terra L. Thomas David Turnoy Janet & Jack Walker

Dean Thomas Kathleen Tyau Nancy Walker 

Arden Thomas Laura Tyler Nancy & Beau Walker 

Jim Thomas Wayne Ude Valerie Wall 

Stephanie Thomas Pam Uhlein Barrie Wallace 

Karen Thomas Sarah Uhlemann Nancy O. Wallace 

Richard J. Thomas Barbara Ullian Vivian Wallach

Amy M. Thomas Ted Ullman Linda Wallard 

Ted Thomas Courtney A. Ulmer Kristen Wallway 

Catherine Thomasson Jessie Unger Robert & Allison Walser 

Nikki Thompson Krag Unsoeld Katie Walsh 

Kara Thompson Chris Uranek Stephen Walsh 

Gina Thornburg David Ursino Terry Walsh 

Rebecca Thornhill Lori Valentine William D. Walsh

Jean Thornton Cheryl L. Vallone Patricia A. Sunny Walter 

George Thornton Anne Valsamakis April Walton 

Dianna Thrasher Alice Van Leunen Jennifer Walts 

Nicloe Tilly Will Van Vaetos Esther Wanning 

Patricia L. Timberlake Ron Van Vlac Karissa & Kelsey Wans 

Erin & Nathan Timmreck William G. Van Vliet Eillen Ward 

Rick Tingle D. Vanderslice John Ward 

Mark Tipperman Mark Vannaford Edward Waring 

David Tobias Georgiana Vargo Carole Warner 

Debby Todd Geri Orchard Vasak Donna Warner 

Dennis Tokaruk Stephen Vaughan Joseph Warren 

Chirag Tolia Kevin Vaughan-Brubaker Rachel Warsaw 

Brad Toman Lisa Vaughn Valerie Wartelle 

Myron Tomkins Scott R. Veirs John F. Warth 

Mike Tong Kathy & Stan Vejtasa Barry B. Washam

Barbara Tonsberg Virginia Velasquez Cruz Alison Wasserman 

Rachelle Torgman Joan Velikanje Bruce Wateringtree 

Kim Tostenson L. Venditto Matt Watkins 

Vidya Tourdot Michele Verdeille David Watson 

Michael Town Heidi Verhaaren Sherrell Watson

Denise Townsend Aaron Viles Vicki Watson 

Kelly B. Townsend Elizabeth Villarreal Janice Watten 

Roger & Anne Tracy Dan Villaume Bob Weaver 

Ron Tragesser, Jr. John Vinson Dean Webb 

Gene Trapp Joanne Vinton Gary Webb 

Matt Trappe Laura Vitale Sara Weber 

Savanah Tre Kristin Vogel Noreen Wedman 

Kirk Treakle Virginia Volk-Anderson James Weekley 

Laura Tregoning Joseph E. Volpe Cynthia Weeks 

Steven J. Trent Christopher Vondrasek Jenny Weeks 

Nancy Trent William Vorachek Robert Wehrman 

Ellen Trescott Gretchen Vos Sigrid I. Weidenweber 

Kent Tresidder Jessie Vosti Michael Weimann 

Sue Trevathan Helene S. Vreeland Sheila P. Weinberg 

David Tripp Kristi Waddell Alyson Weiner 

Marvin Trotter David H. Wagner Karen Weiner 

Adam Troy Meghan Wagner Susan Weinger 

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Piper Weinkey 

Michael Weinsaft 

Dan Weinstein 

Heather A. Weinsten 

Karn Weisbard 

Doron Weisbarth 

Stuart Weisberg 

Joan F. Weisenbloom 

Keith Weisenburg 

Connie Weiss 

Darrel J. Weiss 

Rob Weiss 

Russell Weisz 

Donna Weitling 

Joanna Welch 

Greely Wells 

Sally Wells 

Todd Wells 

William Welsch 

Darren J. Welsh 

Deborah Weltsachs 

Lorien Wendt 

Valerie Wenzel 

Susan Werner 

David & Julie Wertz 

Vera Westbrook 

Steven Westburk 

Brett Westby 

Devon Westerholm 

Effie E. Westervelt 

Louis Westling 

Valerie Weston 

Mary R. Westring 

Tim Wetmiller 

Ben Wetzler 

Genevieve Wexler 

Wilma Wheeler 

Brook Whelchel 

Monica Whipple 

Christen Whisenhunt 

Bonnie White 

C. Nicole White 

Dee White 

Harry & Karen White 

Jeffery S. White 

Lois White 

Lornie White 

Lynn & Joan White 

Sue Ellen White 

Sandra Whiting 

Andrew Whitmarsh 

Jill M. Whitmarsh 

Sheila Whitmore 

Crista Whittington 

Den Mark Wichar 

Michael Wichman 

Andy Wickstrand 

Gloria Wiemann 

Gail Wiener 

David Wiggins 

Bylund V. Wik 

Stacy Wikle 

Mark E. Wilbert 

Pamela Wilcox 

Kathryn Wild 

Christian Wilke 

Robert & Malu Wilkenson 

John Wilkinson 

Earl Willey 

Alex Williams 

Aunum Williams 

Christopher Williams 

Barbara Williams 

David C. Williams 

George M. Williams 

John David Williams 

Karen Williams 

Keith Williams 

Kristi Williams 

Lynda Williams 

Michael T. Williams 

Ryan Williams 

Seanna Williams 

Terese Williams 

Michael Williamson 

Jennifer S. Willis 

Michael Willis 

Christian Williss 

Katharine J. Wilmering 

Andrea Wilson 

Forest J. Wilson 

Jan Wilson 

John Wilson 

Reed M Wilson 

Sharon L. Wilson 

April Winchell 

Nick Windmiller 

Rachel Winer 

Patrick Wingard 

Heidi M. Winkenwerder 

April Winters 

Gerald & Robin Wisdom 

Ryan Wise 

Heather Wise 

Ron Wishnoff 

Tim Withee 

Mary Joan Wittermood 

Paul Wittrock 

Robert A. Witzeman 

Cliff Woglom 

Shirley Wold 

Andrea Wolf 

Elise Wolf 

Esther B. Wolf 

Rachel Wolf 

Gerry Wolfe 

Peggy Wolff 

Fritz E. Wollett 

Gordon H. Wood 

Ilsa Snow Wood 

Sybil Wood 

Laura Woodry 

James Woods 

Lee Woods 

Becky Woodworth 

Wendy Woolery 

Lawrence Worcester 

Richard Worm 

Joan Wozniak 

Owen Wozniak 

Dawn Wright 

Jan Wroncy 

Bernadette Wulf 

Lars Wultt 

Bryan Wyberg 

David A. Wynn 

Wenfens Xu 

Bill Yake 

Carol Yasuda-Terrones 

Ted Yellman 

Joseph Yetter 

Ronald Yockim 

Bill Yocum 

Fachelle & Jerry Yoskowitz 

Russ Youmans 

Emily Jean Young 

Eric Young 

Jack Young 

Jeremy Young 

Thomas Young 

Michele A Youngblood 

Joe Yuska 

Darin Zabriskie 

Diana Zacharia 

Ben Zack 

Barbara Zackey 

Peter Zadis 

Kelly Zalocusky 

Trinity Zan 

Amy Zarrett 

Vytautas Zdanyas 

Robert C. Zeigler 

Mark J. Zellmer 

Christa E. Zielke 

Henry S. Zimmerman 

Tom Zimoski 

Diane Zipper 

Nitzan Ziv 

Robert H. Zlokower 

Mike Zotter 

Kathryn Zuber 

E.B. Zukoski 

Suzanne Zuniga
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

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References 

Cude, Curtis. 2001. Oregon Water Quality Index Summary Report for Water Years 

1992 – 2001. Oregon Department of Environmental Quality, Laboratory Division, 

Water Quality Monitoring Section. 

Johnson, K.N., S. Crim, K. Barber, M. Howell, and C.Cadwell. 1993. Sustainable harvest 

levels and short-term timber sales for options considered in the Report of the Forest 

Ecosystem Management Assessment Team: methods, results, and interpretations. On 

file with: Regional Ecosystem Office, P.O. Box 3623, Portland, Oregon 97208. 102 p. 

Reeves, Gordon, D. Hohler, D. Larsen, D. Busch, K. Kratz, K. Reynolds, K. Stein, T. 

Atzet, P. Hays and M. Tehan. 2003. Aquatic and Riparian Effectiveness Monitoring 

Plan for the Northwest Forest Plan. Gen. Tech. Rep. PNW-GTR-577. Portland, OR: U.S. 

Department of Agriculture, Forest Service, Pacific Northwest Research Station. 70 p. 

USDA Forest Service and USDI Bureau of Land Management. 1994a. Final 

Supplemental Environmental Impact Statement On Management Of Habitat For LateSuccessional And Old-Growth Forest Related Species Within The Range Of The 

Northern Spotted Owl (Northwest Forest Plan). Portland, Oregon.

USDA Forest Service and USDI Bureau of Land Management. 1994b. Record Of 

Decision On Management Of Habitat For Late-Successional And Old-Growth Forest 

Related Species Within The Range Of The Northern Spotted Owl (Northwest Forest 

Plan). Portland, Oregon. 

USDA Forest Service and USDI Bureau of Land Management. 2000a. Final 

supplemental environmental impact statement for Amendments to the Survey and 

Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines. 

Portland, Oregon. 

USDA Forest Service and USDI Bureau of Land Management. 2001. Record of Decision 

and Standards and Guidelines for Amendments to the Survey and Manage, Protection 

Buffer, and other Mitigation Measures Standards and Guidelines. Portland, Oregon. 

USDA Forest Service and USDI Bureau of Land Management. 2003. Draft 

Supplemental Environmental Impact Statement To Remove Or Modify The Survey 

And Manage Mitigation Measures Standards And Guidelines. Portland, Oregon. 

USDA/USDI/USFWS/EPA. 1995. Ecosystem Analysis at the Watershed Scale: The 

Federal Guide for Watershed Analysis. Portland, Oregon. 

USDA/USDI. Interagency Regional Monitoring Reports (1996-2001). See Appendix D 

for detailed monitoring references. 
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy

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Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

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List of Preparers 

Primary Interdisciplinary Team 

Joyce Casey 

AB, Economics, Hamilton College 

MS, Environmental Science, SUNY College of Environmental Science and Forestry 

Joyce Casey has 15 years’ experience with Forest Service. Joyce has been a writereditor on several environmental impact statements. She was a principal writer for the 

Mt. Hood National Forest Plan and also did the socio-economic analysis for that 

document. Joyce worked in the Forest Service Regional Office in Portland for eight 

years. During this time, she coordinated implementation of the Northwest Forest Plan 

and was a policy advisor to the Regional Forester on the Interior Columbia Basin 

Ecosystem Management Project. She has worked in the Forest Service Washington, DC 

headquarters office for the past 4 years, during which time she provided analysis and 

support to improving the Forest Service’s partnership policies. 

Rochelle Desser 

AS, Geo-technology, Flathead Valley College 

Hutchins School of Interdisciplinary Studies, Sonoma State University 

Rochelle Desser has 16 years experience with the Forest Service and 7 years as a private 

forestry contractor. She was the writer-editor and IDT Leader for many environmental 

assessments and environmental impact statements on the Siskiyou National Forest. 

She currently works nation-wide as an Environmental Coordinator for TEAMS 

Enterprise. 

Chester Novak 

BS, Watershed Science, Forestry, University of Montana 

Chester Novak has 23 years experience with the Bureau of Land Management , 

including extended details to the Forest Service and National Resource Conservation 

Service. Early in his career he worked as a soil scientist in Montana and Wyoming, 

Rocky Mountain region. During the past 13 years, Chester has been District 

Hydrologist for the Bureau of Land Management in Salem Oregon. During this time, 

Chester has provided soil and water analysis for 2 Resource Management Plans and a 

recent Seed Orchard EIS. He specializes in water quality effectiveness monitoring and 

development of broad-scale hydrography using geographic information systems. 
Final Supplemental Environmental Impact Statement 

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Ken Wieman 

BS, Biological Aspects of Conservation, Geography – Fluvial Geomorphology, 

University of Wisconsin Madison 

Ken Wieman has 15 years experience with the Forest Service. His Forest Service career 

started at Mt. St. Helen’s National Volcanic Monument, where he focused on stream 

restoration and stream inventory in the post-volcanic eruption era. He has worked as 

an aquatics resource specialist on many planning teams including two environmental 

impact statements. During the past 9 years, he has been District Fish Biologist at the 

Mt. Adams Ranger District focusing on Threatened and Endangered Species recovery 

efforts including stream monitoring and evaluation and watershed restoration projects. 

Kelly Wolcott 

BS, Ecology, Evergreen State College 

MS, Forest Ecology and Wildlife Biology, University of Washington, College of Forest 

Sciences 

Kelly Wolcott has been a wildlife biologist and National Wildlife Refuge Manager with 

the federal government for more than 18 years. He has provided leadership in 

streamlined consultations and implementation of the Northwest Forest Plan in 

Northern California for over five years while working for both the U.S. Fish and 

Wildlife Service and the Forest Service. Prior to working with the Northwest Forest 

Plan, Kelly also managed three National Wildlife Refuges, worked for the U.S. 

National Park Service, the Costa Rican National Park Service, ran an environmental 

education center, and worked as a biologist for several independent consulting firms. 

Other Contributors 

Chris Cadwell 

Katherine Farrell 

Les McConnell 

Roger Nesbit 

Richard Phillips 

Owen Schmidt 

Fay Shon 

 
Final Supplemental Environmental Impact Statement 

Proposal to Amend Wording About the Aquatic Conservation Strategy 

INDEX 

Adaptive Management ................................................................................................ 43, 44, 45 

Alternative 9........................................ 11, 26, 28, 33, 42, 44, 45, 50, 51, 52, 54, 55, 59, 60, 61 

Clean Water Act................................................................................................................ 45, 47

Coquille Forest .............................................................................................................. 4, 10, 61 

Endangered Species Act........................................................................ 7, 17, 45, 46, 47, 51, 54 

Environmental Justice ............................................................................................................. 60 

FEMAT ............................................................................................................. 3, 12, 14, 45, 54 

Monitoring............................................................................................................. 14, 21, 43, 44 

NOAA Fisheries............................................................................................................ 9, 51, 61 

O&C............................................................................................................................ 11, 52, 53

PCFFA v. NMFS................................................................................................. 7, 8, 12, 42, 54 

Standards And Guidelines............................................................. 14, 15, 17, 19, 21, 26, 27, 29 

Survey And Manage........................................................................................ 11, 25, 42, 52, 58 

Timber Sales.................................................................................. 6, 8, 9, 13, 42, 43, 49, 51, 61 

US Fish And Wildlife Service........................................................................................... 51, 61 

Vegetation Management ................................................................................................... 11, 59 

Watershed Analysis........................................... 8, 10, 12, 14, 17, 18, 20, 21, 23, 28, 44, 45, 46 

Watershed Restoration .................................................................... 8, 12, 17, 18, 21, 27, 45, 46 

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