United States 

Department 

of Agriculture

Forest Service

Pacific Southwest 

Region

R5-MB-212

January 2010

Final Environmental

Impact Statement

Eddy Gulch Late-Successional Reserve

Fuels/Habitat Protection Project

Salmon River and Scott River Ranger Districts

Klamath National Forest

Siskiyou County, California

final
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Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Abstract iii 

Eddy Gulch Late-Successional Reserve Fuels / Habitat Protection Project 

Final Environmental Impact Statement, Klamath National Forest 

Lead Agency: USDA Forest Service 

Responsible Official: Patricia A. Grantham, Forest Supervisor, Klamath National Forest 

1312 Fairlane, Yreka, CA 96097-9549 

For Information 

Contact: 

Connie Hendryx, Klamath National Forest, Salmon/Scott River Ranger District 

11263 N. Highway 3, Fort Jones, CA 96032 

(530) 468-1281 

Abstract: The Eddy Gulch Late-Successional Reserve Fuels / Habitat Protection Project Final Environmental 

Impact Statement (EIS) documents the analysis of the no-action alternative and two action alternatives. 

Purpose and Need. The purpose of the project is to protect late-successional habitat used by the northern 

spotted owl and other late-successional-dependent species, to protect communities, and create safer emergency 

access routes. The project is needed to reduce excessive fuel hazards, where recent surveys for this project 

determined that 73 percent of the entire LSR would support active or passive crown fires. 

Alternative A: No Action. This alternative is the continuation of the current level of management and public 

use—this includes road maintenance, dispersed recreation (hunting, fishing, camping, and hiking), mining, and 

watershed restoration projects and a 7,200-acre modeled wildfire. 

Alternative B: Proposed Action. Alternative B proposes 25,969 acres of landscape-level treatments to protect 

late-successional habitat and communities. Within those acres, 16 Fuel Reduction Zones (FRZs), totaling 

8,291 acres, would be constructed to increase resistance to the spread of wildfires to adjacent watersheds. The 

8,291 acres include 931 acres in 42 M Units (thinning units) and 7,383 acres in fuel reduction areas (outside the 

M Units) to reduce ground and ladder fuels. The proposal includes 17,524 acres of Prescribed Burn Units 

(Rx Units) located outside the FRZs to increase resiliency to wildfires and protect habitat for the NSO and other 

wildlife species that are dependent on late-successional forests. There would be 44 miles of Roadside (RS) 

treatments along emergency access routes treated in FRZs and Rx Units (treatments would be similar to the 

FRZ or Rx Unit the route passes through) and 16 miles (154 acres) of RS treatments outside of FRZs and 

Rx Units—a total of 60 miles of RS treatments along emergency access routes. 

Alternative C: No New Temporary Roads Constructed. Approximately 1.03 miles (5,443 feet) of new 

temporary roads would not be constructed. As a result, no fuel-reduction treatments in 99 acres would occur in 

portions of seven M Units, which reduces the M Units to 832 acres. There would be 822 fewer acres treated in 

Rx Units because no treatment would occur in a portion of two M Units. The inability to treat the 921 acres 

would result in vulnerable areas that could allow wildfires to escape to other areas of the LSR. 

Public and agency reviewers provided the Forest Service with their comments during the 45-day review period 

for the draft EIS (the review period ran from July 24 through September 8, 2009). Edits were made to the final 

EIS (and related resource reports) based on public and agency comments. No changes were made to the two 

action alternatives (Alternative B: Proposed Action or Alternative C: No New Temporary Roads Constructed), 

and no additional action alternatives were developed. 

Public and agency comments, and Forest Service responses to comments, can be found in Section B.2 of 

Appendix B of this final EIS. Full copies of public and agency comment documents are contained in 

Section B.3 of Appendix B. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Summary v

Summary 

Background ______________________________________________ 

Prior to European settlement the Klamath Mountains experienced frequent (every 12–19 years) 

mixed-severity fires. The highest-intensity fires occurred on the upper third of slopes and on south 

and west aspects, while the lowest-intensity fires occurred on the lower third of slopes and on north 

and east aspects. The result was that ridgetops and south and west aspects had scattered remnants of 

older trees among a matrix of younger stands, while the lower third of slopes and east and west 

aspects supported stands characterized by large-diameter trees with a multilayered closed canopy, 

snags, and downed logs (late-successional habitat) (Taylor and Skinner 1998; Skinner et al. 2006). 

Settlement of the area and an effective fire-exclusion policy have significantly modified the fire 

regime and forest structure. The number of acres burned by small fires on the Salmon River and Scott 

River Ranger Districts has declined steadily since 1930, while the number of large fires that escaped 

initial attack increased between 1970 and 1999. Studies have determined that 67 percent of the Eddy 

Gulch Late-Successional Reserve (LSR) is characterized as Fire Regime Condition Class 3, where the 

fire regime has been significantly altered from its historical range, and there is a high risk of losing 

key ecosystem components (Creasy 2008). 

A total of 23 northern spotted owl (NSO) activity centers have been identified within the 

boundary of the Eddy Gulch LSR (20 of which are in or overlapping the project Assessment Area), 

and 62 percent were occupied during the most recent surveys (2008). A 7,200-acre wildfire (as 

modeled under Alternative A—no action) could destroy or significantly degrade multiple NSO 

activity centers. The Salmon River Community Wildfire Protection Plan (CWPP) identified several 

wildland-urban interface (WUI) areas adjacent to communities, municipal watersheds at risk, and 

emergency access routes where excessive fuels should be reduced in the Eddy Gulch LSR. The 

CWPP is consistent with the Healthy Forests Restoration Act, and that Act requires the Forest Service 

to consider CWPPs in project planning. Climate change could directly affect the current distribution 

of plants and wildlife as a result of warmer temperatures, and could also dry forest fuels earlier and 

extend the fire season, resulting in more frequent fires. 

Purpose and Need _________________________________________ 

The purpose of the Eddy Gulch LSR Project is to protect late-successional habitat used by the 

NSO (Strix occidentalis caurina) and other late-successional-dependent species, to protect 

communities, and create safer emergency access routes. The project is needed to reduce excessive 

fuel hazards, where recent surveys for this project determined that 73 percent of the entire LSR would 

support active or passive crown fires. Two objectives were developed for the project based on current 

conditions in the Assessment Area. 

Objective 1: Habitat Protection—Protect existing and future late-successional habitat from 

threats of wildfire that occur inside and outside the Eddy Gulch LSR. 

Need for Action (Existing Conditions). The Eddy Gulch LSR Project is needed to reduce 

excessive fuel hazards to protect and conserve late-successional habitat. Current conditions have 

created the following problems: 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

vi Summary

1. Due to policies that required the control of all fires and excluded fire from the ecosystem, 

there have been changes in stand structures, including higher densities of ground and 

ladders fuels such as brush, small trees, and shade-tolerant tree species. 

2. Most of the mid- and late-successional conifer stands in the Assessment Area are choked 

with small trees (less than 10 inches diameter at breast height [dbh]). Additionally, tree 

mortality will continue to increase in response to current competition for resources and 

warmer temperatures, which contribute to higher fuel loads. 

3. Fire modeling, using current conditions, indicates that under 90th percentile weather 

conditions 

 flame lengths during a wildfire would be from 11 to 20 feet, contributing to crown fire 

behavior; 

 the rate of fire spread would range between 30 and 60 feet per minute, affecting the 

ability of suppression crews to contain fires; and 

 73 percent of the entire Eddy Gulch LSR (61,900 acres) would experience 

active/passive crown fires that would reduce or destroy habitat suitability for the NSO 

(including designated critical habitat) and other late-successional-dependent species. 

Objective 2: Community Protection—Reduce wildfire threat to communities and municipal 

water supplies and ensure public and firefighter safety. 

Need for Action (Existing Conditions). The Eddy Gulch LSR Project is needed to reduce 

wildfire risk to communities by reducing fuel hazards and provide people with safe passage by 

reducing fuel hazards along emergency access routes that occur in the Eddy Gulch LSR. 

1. Current fuel conditions are increasing the wildfire risk to residents, property, infrastructure, 

and municipal watersheds. Communities near the LSR would be at risk of high losses. 

2. During a wildfire, emergency access routes (described in the Salmon River CWPP) may 

not be safe or passable because fuel loading and hazard trees along 60 miles of specifically 

identified road segments could potentially block primary escape routes in the event of a 

wildfire—this would compromise the safety of local residents who would need to evacuate 

ahead of the fire and potentially prevent firefighters from reaching the fire area to initiate 

and sustain suppression activities. 

3. Vegetation treatments are needed to reduce fuel loading and continuity and to provide 

strategic locations where firefighters can safely work. Current conditions would be unsafe 

for firefighters because there are no fuelbreaks in place to serve as safe areas from which to 

fight fires, and fires would have the opportunity to grow very large. 

4. In the event of a wildfire, much of the vegetation and ground cover would be removed 

from seven municipal watersheds, which would affect water quality for local residents who 

depend on these areas. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Summary vii

Alternative Development ____________________________________ 

Alternative A: No Action 

The no-action alternative complies with Council on Environmental Quality regulations for 

implementing the National Environmental Policy Act (40 Code of Federal Regulations 

[CFR] 1502.14(d)). It is not a baseline condition but rather a description of future circumstances 

without implementation of the Eddy Gulch LSR Project. The no-action alternative is described in this 

environmental impact statement as continuation of the current level of management and public use—

this includes road maintenance, dispersed recreation (hunting, fishing, camping, and hiking), mining, 

watershed restoration projects, and a simulated 7,200-acre wildfire, where a majority of the fire was 

characterized by a stand-replacing crown fire. The time frame for analysis is considered to be 

20 years. Given the fuel hazard in the Eddy Gulch LSR and current predictions of climate change, it 

is assumed at least one wildfire will escape initial attack during the 20-year period and burn under 

90th percentile weather conditions (defined as 10 percent of the days in the historical weather 

database that had lower fuel moisture and higher wind speeds compared to the rest of the days). An 

analysis of a wildfire for three days that escaped initial attack in the Eddy Gulch LSR Project 

Assessment Area indicates that fire would burn 7,200 acres. Of those 7,200 acres, 1,355 acres 

(19 percent) would be surface fire; 5,065 acres (70 percent) would be passive crown fire; and 

780 acres (11 percent) would be active crown fire. These crown fires would result in extensive tree 

mortality, approaching 100 percent, over 81 percent of the total burned area. 

Alternative B: Proposed Action (Forest Service Preferred Alternative) 

Alternative B proposes to treat 25,969 acres of landscape-level treatments in the Eddy Gulch LSR 

Project Assessment Area to protect late-successional habitat and communities. Of the 25,696 acres 

proposed for treatment, 8,291 acres would be in Fuel Reduction Zones (FRZs); 17,524 acres would be 

in Prescribed Burn Units (Rx Units); and 154 acres would be in Roadside (RS) treatments along 

emergency access routes that do not pass through an FRZ or Rx Unit. 

Fuel Reduction Zones 

Alternative B proposes to construct 16 FRZs totaling 8,291 acres to increase resistance to the 

spread of wildfires to adjacent watersheds. The 8,291 acres include 931 acres in 42 M Units (thinning 

units) and 7,383 acres in fuel reduction areas (outside the M Units) to reduce ground and ladder fuels. 

The FRZs would be strategically located on ridgetops to increase resistance to the spread of wildfires. 

The FRZs would be wide enough to capture most short-range spot fires, and ground, ladder, and 

crown fuels would be reduced so as to change crown fires to surface fires within the treated areas. 

The FRZs would provide safe locations for fire-suppression personnel to conduct fire-suppression 

actions during 90th percentile weather conditions, and they would serve as anchor points for 

additional landscape-level fuel treatments, such as underburning. 

 M Units in FRZs. Forty-two M Units, totaling 931 acres, would be treated in the FRZs 

consistent with the range of natural variation. A “Designation by Description” prescription 

with variable spacing would be used to retain the largest trees generally within 14–28 feet 

of the next adjacent largest conifer tree. Tree removal would thin from below, removing 

trees 8–28 inches diameter at breast height (dbh). No trees larger than 20 inches dbh would 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

viii Summary

be removed in M Unit 8, M Unit 24, M Unit 31, and M Unit 43 to retain large trees in NSO 

habitat. Additional emphasis would be given to retaining desired conifer species and all 

hardwoods. Post-treatment canopy cover would range from 32 to 50 percent. Snags and 

coarse woody debris would be reduced, where needed, to ensure firefighter safety; 

however, Standards and Guidelines in the Klamath National Forest Land and Resource 

Management Plan (Klamath LRMP) would be achieved on a landscape level. Tractor 

yarding would occur on 361 acres and cable yarding on 570 acres. Following completion of 

thinning, all slash in tractor units would be piled and burned, and all slash in cable units 

would be lopped and scattered and broadcast burned. Slash and other ground fuels would 

be removed to achieve post-treatment flame lengths of less than 2 feet, with fuel loads 

maintained to achieve flame lengths of less than 4 feet over time. Crown base heights 

would be 8–15 feet to minimize crown fires. 

 Fuel Reduction Areas in FRZs. The “fuel reduction areas” in FRZs are areas outside of 

M Units and total 7,383 acres. Ground and ladder fuels (conifer trees up to 10 inches dbh) 

would be masticated on 3,184 acres on slopes less than 45 percent. Prescriptive burning, 

outside of M Units, would be used on 5,107 acres on slopes greater than 45 percent. 

Mortality of intermediate, dominant, and codominant trees would not exceed 10 percent in 

a burn block; however, mortality may be higher in plantations and in areas with forest fuel 

concentrations, which could result in small openings—all openings will not exceed 

10 percent of any unit. Post-treatment flame lengths would be less than 2 feet, with fuel 

loads maintained to achieve flame lengths of less than 4 feet over time. Crown base heights 

would be 8–15 feet to minimize crown fires. 

Plantations would be thinned to a 20-foot by 20-foot spacing, using mastication on slopes 

less than 45 percent. On slopes greater than 45 percent, plantations would be prescribed 

burned, except in eight strategic plantations in five FRZs where hand thinning, pruning 

(maintaining 60 percent canopy cover), and pile and burn would be necessary to maintain 

the integrity of the FRZs. Those treatments would occur on 56 acres in FRZ 2, 17 acres in 

FRZ 3, 28 acres in FRZ 5, 49 acres in FRZ 9, and 9 acres in FRZ 14. 

Prescribed Burn Units 

 Alternative B proposes 11 Rx Units, totaling 17,524 acres to increase resiliency to wildfires 

and protect habitat for the NSO and other wildlife species that are dependent on latesuccessional forests. The units range in size from approximately 250 to 4,300 acres and 

would be generally located between the FRZs. Most of the Rx Unit treatments would occur 

on south-facing aspects where fuels dry faster, and treatments would support the role of the 

FRZs. The Rx Units were designed and located in areas containing U.S. Fish and Wildlife 

Service priority protection areas, which include clusters of NSO Activity Centers or are 

important to maintain connectivity in the LSR. Broadcast burning, ignited by hand or with 

“ping pong” balls from a helicopter, would be used to remove ground and small ladder 

fuels (less than 4 inches dbh) and to achieve post-treatment flame lengths of less than 

2 feet, with fuel loads maintained to achieve flame lengths of less than 4 feet over time. 

Implementation of prescribed burns would not be consistent across each Rx Unit, but rather 

small patches of heavier fuels would be maintained in burn areas, mimicking the range of 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Summary ix

natural variation that was created by the pre-European fire regime. Prescribed burning 

would result in some mortality of intermediate, dominant, and codominant trees. Mortality 

would be highest in the smaller intermediate trees, and total mortality would not exceed 

10 percent in a burn block. Most mortality would occur to individual trees scattered 

throughout the entire burn area; however, small openings may also occur where groups of 

3 to 5 trees could be killed when high concentrations of surface fuels occur. Mortality 

would be lower in mid-successional and late-successional stands where trees are larger, the 

bark is thicker, and the branches are higher on trees. The sum of all openings in a burn unit 

would not exceed 10 percent of any unit. Snags and coarse woody debris densities would 

be consistent with Standards and Guidelines contained in the Klamath LRMP. Roads, 

topographic features, and hand-cut control lines would control prescribed fire size. Existing 

landings would be used if burning is ignited from a helicopter. Burns may be accomplished 

when air quality, weather, and fuel moisture conditions could be met. 

Roadside Treatments Along Emergency Access Routes 

The RS treatments are proposed along 60 miles of emergency access routes; 44 of the 60 miles 

would receive the same treatment as the FRZ or Rx Unit the route passes through. The following are 

the RS treatments proposed along 16 miles (approximately 154 acres) of emergency access routes that 

do not pass through FRZs or Rx Units: 

 RS 1 treatments would consist of hand thin and pile burn of trees up to 6 inches dbh on 

slopes greater than 45 percent (43.1 acres). 

 RS 2 treatments would involve mastication to remove trees less than 10 inches dbh on 

slopes less than 45 percent (40.6 acres). 

 RS 3 treatments are in Riparian Reserves and would only consist of mastication, hand thin, 

and pile burn (69.5 acres). 

Generally, the RS treatments would occur along the following roads: 

 National Forest System (NFS) Road 39 from County Road 1CO2 up to the northeast corner 

where it intersects the boundary of FRZ 15; 

 NFS Road 40N61 (Whites Gulch) from the intersection with Road 39 to the county road; 

and 

 the south side of NFS Road 40N54 from the intersection of the county road east to the 

intersection of 40N35. 

All hazard trees would be identified and removed in accordance with Klamath National Forest 

Hazard Tree Policy—Safety Provisions on National Forest System Roads (USFS 2005). To maintain 

the canopy cover requirements listed in the Salmon River CWPP, only small fuels within 50 feet of 

the road would be removed. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

x Summary

Proposed Temporary Roads and Landings 

The construction of new temporary roads and the use of former logging access routes are 

proposed to access treatment units. 

 Approximately 1.03 miles (5,433 feet) of new temporary roads would be used to access all 

or portions of seven M Units. All of these temporary roads would be closed (ripped and 

mulched, as needed) following thinning. 

 Approximately 0.98 mile (5,177 feet) of former logging access routes would be re-opened 

(vegetation removed and bladed) to access all or portions of five M Units. These routes 

would be water-barred and closed immediately after thinning is completed. 

 Five short spurs, each less than 100 feet long, would be bladed for tractor or cable yarding 

operations in two units. 

 Existing landings will be used. The interdisciplinary team considered using whole-tree 

yarding to reduce slash treatments, but it would require larger landings and additional 

clearing and was therefore not considered further. 

 Existing skid trails will be used. There may be short sections of skid trails that could be 

over 35 percent slope and that use the scarps (the steeper slope) to connect one flat bench 

to another flat bench. Please refer to the Soil RPMs in Section 2.9.4 below. 

Alternative C: No New Temporary Roads Constructed 

Alternative C responds to public concerns regarding the environmental and economic effects of 

constructing new temporary roads. Alternative C is similar to the Proposed Action but approximately 

1.03 miles (5,443 feet) of new temporary roads identified in the Proposed Action would not be 

constructed. As a result, no fuels treatments would occur in portions of seven M Units. This reduces 

the total acres of treatments in M Units from 931 under Alternative B to 832 under Alternative C. 

Fuels treatments could not be carried out in those M Units because of excessive treatment costs, high 

existing dead crown fuel loadings, and potential heat damage to the overstory if these untreated units 

were prescribed burned. 

 The FRZs would continue to total 8,291 acres; however, 99 acres in M Units would remain 

untreated. The total number of acres treated by tractor yarding would remain at 361 acres, 

but the acres of cable yarding would be reduced from 570 under Alternative B to 471 under 

Alternative C. 

 Reducing the 99 acres of M Units treated would also reduce the number of acres treated in 

two Rx Units (an 822-acre reduction) because excessive fuels remaining in M Units would 

preclude safely burning portions of the two Rx Units. Thus, approximately 921 acres would 

still be susceptible to a crown fire. The inability to treat the 921 acres would result in 

vulnerable areas that could allow wildfires to escape to other areas of the LSR. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Summary xi

Decision to be Made________________________________________ 

The Responsible Official (decision maker) for this action is the Klamath National Forest 

Supervisor. The decision maker will consider how well each alternative meets the objectives 

(purposes) of the Eddy Gulch LSR Project and addresses the significant issue described below. The 

decision maker will decide whether to implement an action or take no action. After the final EIS is 

completed, a Record of Decision will then be issued and will contain the rationale for the decision 

and a discussion of any applicable mitigation measures (referred to as “resource protection measures” 

in this final EIS). 

Public Involvement_________________________________________ 

Collaboration and Scoping 

Planning for this project was initiated in September 2007. Extensive collaboration meetings were 

held in local communities in and adjacent to the Eddy Gulch LSR between September 2007 and 

March 2008. The Notice of Intent to prepare the draft EIS for the Eddy Gulch LSR Project appeared 

in the Federal Register on April 1, 2008. The Notice of Intent described the purpose and need for the 

project and summarized the Proposed Action. The scoping letter (in the form of a project newsletter) 

was mailed to the approximate 1,200 members on the project mailing list. A project website 

(www.eddylsrproject.com) was developed to help keep people informed about the project and to 

make fact sheets, newsletters, meeting announcements, and other documents (such as the draft and 

final EISs) easily available. 

Meetings and conversations were held with the United States Fish and Wildlife Service and 

National Marine Fisheries Service (both agency offices are located in Yreka, California) to gather 

suggestions and comments about the project. 

Significant Issue. Public and agency comments received during collaboration and scoping 

efforts identified only one significant issue, which was in regard to construction of new temporary 

roads to access some of the treatment units. Alternative C was developed in response to public 

concerns regarding the environmental and economic impacts of constructing new temporary roads. 

Draft EIS Review Period 

The 45-day review period for the draft EIS ran from July 24, 2009 to September 8, 2009. Seven 

comment documents were received, and most comment documents identified individual concerns. 

Responses were developed for 68 individual comments. The exact words of each respondent were 

used rather than summaries of the person’s words to ensure accuracy and objectivity. Public and 

agency comments, and Forest Service responses to comments, can be found in Section B.2 of 

Appendix B of this final EIS. Full copies of public and agency comment documents are contained in 

Section B.3 of Appendix B. 

Comparison of Alternatives__________________________________ 

Table S-1 provides a comparison of the three alternatives. 
xii Summary Table S-1. Comparison of alternatives by project objectives, resource indicators, and effects on resources. Indicators (By Project Objective) Alternative A (No Action) Alternative B (Proposed Action) 

(N

R

Objective 1: Habitat Protection Protect existing and future late-successional habitat from threats of wildfire that occur inside and outside the Eddy Gulch LSR. Late-successional habitat would be threatened by wildfires Large portions of late-successional habitat would be protected from wildfires Fewer acr

habitat wowildfires  Acres that are (1) resistant to the spread of, or (2) resilient to the effects of a wildfire (1) 0 acres (2) 2,890 acres (1) 8,291 acres (2) 17,524 acres (1) 8,192 

(2) 16,702 

 Percent of fire type (1) surface or (2) crown fire in the entire LSR (1) 27 percent (2) 73 percent (1) 77 percent (2) 23 percent (1) 75 pe

(2) 25 pe

 Percent of NSO habitat in the LSR adversely affected by wildfire 100 percent of NSO core areas 50 percent of NSO core areas 55 percen Conifer stands resemble historic range of conditions 2,890 acres Treatments will move 25,815 acres of conifer stands in the direction of historic range of conditions Treatment

of conifer historic ra

Objective 2: Community Protection Reduce wildfire threat to communities and municipal water supplies and ensure public and firefighter safety. Communities and municipal water supplies would be threatened by wildfires Treatments would reduce the threat from wildfires to communities and municipal water supplies Treatment

from wildfmunicipal 

 Acres of WUI treated 0 acres 800 acres 800 acres  Miles of emergency access routes treated 0 miles 60 miles 60 miles  Acres of FRZs (fuelbreaks) constructed 0 acres 8,291 acres 8,291 acre Important infrastructure protected None Repeater site, Eddy Gulch Lookout, campgrounds Campgrou Acres of municipal watersheds treated 0 acres 9,850 acres 9,850 acre Changes in emissions 29,300 tons of PM10, PM2.5, and carbon monoxide emitted from a wildfire 80 percent reduction in emissions 80 percen
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Contents xiii

Chapter 1: Purpose and Need for Action 

1.1 Introduction...............................................................................................................................................1-2 

1.1.1 Project Location............................................................................................................................1-2 

1.1.2 Background...................................................................................................................................1-2 

1.1.3 Terms............................................................................................................................................1-3 

1.1.4 Concerns for the Eddy Gulch LSR ...............................................................................................1-3 

1.1.5 Climate Change ............................................................................................................................1-4 

1.2 Environmental Impact Statement Goal and Project Objectives.................................................................1-5 

1.2.1 Environmental Impact Statement Goal.........................................................................................1-5 

1.2.2 Importance of Defining Project Objectives ..................................................................................1-5 

1.3 Purpose of and Need for the Eddy Gulch Late-Successional Reserve Project ..........................................1-6 

1.4 Other Objective .......................................................................................................................................1-11 

1.5 Summary of the Proposed Action............................................................................................................1-11 

1.6 Management Direction, Policies, and Laws that Influence the Scope of this 

 Environmental Impact Statement ............................................................................................................1-12 

1.6.1 Klamath National Forest Land and Resource Management Plan ...............................................1-12 

1.6.2 Healthy Forests Restoration Act.................................................................................................1-13 

1.6.3 Klamath National Forest Forestwide Late-Successional Reserve Assessment...........................1-14 

1.6.4 National Forest Management Act...............................................................................................1-14 

1.6.5 National Environmental Policy Act............................................................................................1-15 

1.7 Decision to Be Made...............................................................................................................................1-15 

1.8 Project Schedule......................................................................................................................................1-15 

1.9 Public Participation and Information.......................................................................................................1-15 

1.9.1 Project Website...........................................................................................................................1-15 

1.9.2 Project Mailing List....................................................................................................................1-16 

1.9.3 Project Newsletters and Fact Sheets ...........................................................................................1-16 

1.9.4 Citizen and Agency Collaboration under the Healthy Forests Restoration Act..........................1-16 

1.9.5 Scoping Process under the National Environmental Policy Act.................................................1-18 

1.9.6 Draft EIS Review Period ............................................................................................................1-21 

1.10 Permits, Licenses, and Other Consultation Requirements .......................................................................1-21 

Chapter 2: Proposed Action and Alternatives 

2.1 Introduction...............................................................................................................................................2-1

2.2 Description of the Alternatives Considered in Detail................................................................................2-1

2.3 Terms ........................................................................................................................................................2-2

2.4 Alternative A: No-Action Alternative.......................................................................................................2-2

2.5 Alternative B: Proposed Action ................................................................................................................2-2

2.5.1 Identifying Treatment Locations ..................................................................................................2-3

2.5.2 Developing of the Proposed Action..............................................................................................2-5
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

xiv Contents

2.5.3 Designated Land Allocations and Critical Habitat..................................................................... 2-17

2.5.4 Implementation Sequence for the Proposed Action................................................................... 2-18

2.6 Alternative C: No New Temporary Roads Constructed ......................................................................... 2-19

2.7 Alternatives Considered but Eliminated from Detailed Study ............................................................... 2-20

2.8 Summary Comparison of Alternatives ................................................................................................... 2-20

2.9 Resource Protection Measures ............................................................................................................... 2-22

2.9.1 Wildlife...................................................................................................................................... 2-22

2.9.2 Fisheries..................................................................................................................................... 2-24

2.9.3 Water Resources ........................................................................................................................ 2-26

2.9.4 Soils ........................................................................................................................................... 2-27

2.9.5 Geology ..................................................................................................................................... 2-28

2.9.6 Botany........................................................................................................................................ 2-29

2.9.7 Heritage Resources .................................................................................................................... 2-31

2.9.8 Air Quality................................................................................................................................. 2-31

2.9.9 Scenery ...................................................................................................................................... 2-31

2.9.10 Recreation.................................................................................................................................. 2-32

2.10 Seasonal Constraints on Operations in the Eddy Gulch LSR Project Assessment Area ......................... 2-32 

Chapter 3: Affected Environment and Environmental Consequences 

3.1 Introduction .............................................................................................................................................. 3-1 

3.1.1 Terms........................................................................................................................................... 3-1 

3.1.2 Definitions for Evaluating Effects ............................................................................................... 3-2 

3.1.3 Council on Environmental Quality Guidance on Cumulative Effects Analysis .......................... 3-2 

3.1.4 Reasonably Foreseeable Future Projects in the Vicinity of the Eddy Gulch LSR Project........... 3-3 

3.2 Forest Vegetation ..................................................................................................................................... 3-4 

3.2.1 Introduction ................................................................................................................................. 3-4 

3.2.2 Methodology................................................................................................................................ 3-4 

3.2.3 Affected Environment (Existing Conditions) .............................................................................. 3-8 

3.2.4 Desired Stand Conditions .......................................................................................................... 3-16 

3.2.5 Environmental Consequences.................................................................................................... 3-19 

3.3 Fire, Fuels, and Air Quality.................................................................................................................... 3-29 

3.3.1 Introduction ............................................................................................................................... 3-29 

3.3.2 Methodology: Fire and Fuels..................................................................................................... 3-29 

3.3.3 Affected Environment (Existing Conditions): Fire and Fuels ................................................... 3-35 

3.3.4 Desired Conditions for the Assessment Area ............................................................................ 3-40 

3.3.5 Environmental Consequences: Fire and Fuels........................................................................... 3-43

3.3.6 Methodology: Air Quality ......................................................................................................... 3-52 

3.3.7 Affected Environment (Existing Conditions): Air Quality........................................................ 3-54 

3.3.8 Environmental Consequences: Air Quality................................................................................ 3-54 

3.4 Wildlife and Habitat ............................................................................................................................... 3-57 

3.4.1 Introduction ............................................................................................................................... 3-57 

3.4.2 Methodology.............................................................................................................................. 3-57 

3.4.3 Affected Environment (Existing Conditions) ............................................................................ 3-63 

3.4.4 Desired Conditions .................................................................................................................... 3-71 

3.4.5 Environmental Consequences.................................................................................................... 3-72 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Contents xv

3.5 Aquatic Resources.................................................................................................................................3-111 

3.5.1 Introduction ..............................................................................................................................3-111 

3.5.2 Methodology.............................................................................................................................3-111 

3.5.3 Affected Environment (Existing Conditions) ...........................................................................3-114 

3.5.4 Environmental Consequences...................................................................................................3-121 

3.6 Soils and Geology .................................................................................................................................3-149 

3.6.1 Introduction ..............................................................................................................................3-149 

3.6.2 Methodology: Soils...................................................................................................................3-149 

3.6.3 Methodology: Geology.............................................................................................................3-151 

3.6.4 Affected Environment (Existing Conditions): Soils .................................................................3-153 

3.6.5 Environmental Consequences: Soils.........................................................................................3-153 

3.6.6 Affected Environment (Existing Conditions): Geology ...........................................................3-161 

3.6.7 Environmental Consequences: Geology...................................................................................3-163 

3.7 Botanical Resources and Noxious Weeds .............................................................................................3-173 

3.7.1 Introduction ..............................................................................................................................3-173 

3.7.2 Methodology: Botanical Resources..........................................................................................3-173 

3.7.3 Affected Environment (Existing Conditions): Botanical Resources ........................................3-175 

3.7.4 Environmental Consequences: Botanical Resources ................................................................3-180 

3.7.5 Methodology: Noxious Weeds .................................................................................................3-209 

3.7.6 Affected Environment (Existing Conditions): Noxious Weeds................................................3-209 

3.7.7 Environmental Consequences: Noxious Weeds .......................................................................3-212 

3.8 Social Values.........................................................................................................................................3-218 

3.8.1 Introduction ..............................................................................................................................3-218 

3.8.2 Methodology.............................................................................................................................3-218 

3.8.3 Affected Environment and Environmental Consequences .......................................................3-218 

3.9 Short-term Uses and Long-term Productivity .......................................................................................3-229 

3.10 Unavoidable Adverse Effects................................................................................................................3-230 

3.11 Irreversible and Irretrievable Commitment of Resources .....................................................................3-230 

3.12 Cumulative Effects................................................................................................................................3-231 

3.13 Climate Change.....................................................................................................................................3-231 

3.14 Energy Requirements, Conservation Potential, Depletable Resource Requirements............................3-232 

3.15 Prime Farmland, Rangeland, and Forest Land ......................................................................................3-232 

3.16 Possible Conflicts with Other Land Use Plans......................................................................................3-232 

3.17 Other Required Disclosures ...................................................................................................................3-232 

Chapter 4: Consultation and Coordination 

4.1 Preparers and Contributors........................................................................................................................4-1 

4.1.1 Contractor Interdisciplinary Team Members................................................................................4-1 

4.1.2 U.S. Fish and Wildlife Representative for Collaboration and Consultation .................................4-3 

4.1.3 Forest Service Inspectors and Resource Specialists .....................................................................4-3 

4.2 Federal, State, and Local Agency Collaboration and Consultation...........................................................4-5 

4.2.1 Federal, State, and Local Agencies...............................................................................................4-5 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

xvi Contents

4.3 Tribal Consultation................................................................................................................................... 4-8 

4.3.1 Coordination Meetings ................................................................................................................ 4-8 

4.3.2 Other Tribal Communication..................................................................................................... 4-10 

4.4 Distribution of this Final Environmental Impact Statement.................................................................... 4-10 

Chapter 5: Acronyms, Glossary, Literature Cited, and Index 

Acronyms ........................................................................................................................................................... 5-1 

Glossary.............................................................................................................................................................. 5-4 

Literature Cited................................................................................................................................................. 5-20 

Index ................................................................................................................................................................. 5-36 

Figures 

3-1. Photo taken in 1935—view area is east of Eddy Gulch Lookout.......................................................... 3-10 

3-2. Photo taken in 1992—same view area as Figure 3-1 ............................................................................ 3-10 

3-3. Photo taken in 1935—view area is west of Eddy Gulch Lookout......................................................... 3-11 

3-4. Photo taken in 1992—same view area as Figure 3-3 ............................................................................ 3-11 

3-5. Fires in the Salmon River and Scott River Ranger Districts from 1970 to 2005................................... 3-37 

3-6. Changes in fire size on the Salmon River and Scott River Ranger Districts since 1920....................... 3-38 

3-7. Three randomly selected examples of wildfire simulations in the Assessment Area 

under Alternative A............................................................................................................................... 3-44 

3-8. Displays fire spread in an untreated area and effectiveness of constructing an FRZ and fire 

spread in a treated Rx Unit.................................................................................................................... 3-48 

Tables 

1-1. Treatment needs for the Eddy Gulch LSR Project .................................................................................. 1-9 

2-1. Proposed mechanical and prescribed burn treatment acres in FRZs ....................................................... 2-8 

2-2. Proposed thinning treatments for habitat and community protection.................................................... 2-11 

2-3. General thinning prescriptions at five years post treatment .................................................................. 2-13 

2-4. Proposed new temporary roads, former logging access route updates, and short spurs........................ 2-13 

2-5. Proposed Rx Units................................................................................................................................. 2-16 

2-6. Changes in M Unit treatment acres between Alternatives B and C with the elimination of 

new temporary roads............................................................................................................................. 2-19 

2-7. Comparison of alternatives by project objectives, resource indicators, and effects on resources ......... 2-21 

2-8. Percent of FRZs and Rx Units that would not be affected by LOPs ..................................................... 2-33 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Contents xvii

3-1. Median and range of median fire return intervals (years) for sites by aspect and slope position 

for plots on Thompson Ridge, Klamath Mountains, California................................................................ 3-8 

3-2. Current abundance of forest successional stages and canopy cover in the Assessment Area ..................3-13 

3-3. Current stand structure on ridgetops where proposed M Units are located..............................................3-13 

3-4. Desired stand structure for the upper third of slopes, as described in the forestwide 

LSR assessment .......................................................................................................................................3-17 

3-5. General thinning prescriptions immediately after thinning......................................................................3-18 

3-6. Stand structure for M Units: comparison of current and 5- and 30-year stand data for 

Alternatives A, B, and C ..........................................................................................................................3-20 

3-7. Eddy Gulch LSR strata data and stand structure: current, 30-year desired conditions, 

and 30-year conditions post-thinning in M Units and with no treatment.................................................3-21 

3-8. Percent species by strata: current, no thinning, and with thinning...........................................................3-22 

3-9. Average spacing between trees ................................................................................................................3-25 

3-10. Desired conditions for forest stands on the upper third of slopes compared with stand 

conditions at five years post-treatment ....................................................................................................3-26 

3-11. Examples of fuel models that represent a majority of the Assessment Area and pose the 

high hazard in the Assessment Area ........................................................................................................3-30 

3-12. Examples of protection targets identified in the SFA ..............................................................................3-31 

3-13. Plantations inside and outside the Eddy Gulch LSR Assessment Area ...................................................3-32 

3-14. Indicators and their measurements to describe effects among the alternatives........................................3-33 

3-15. Relationship between flame length and potential for success of active suppression ...............................3-34 

3-16. Percent of acres within each FRCC, Eddy Gulch LSR ............................................................................3-35 

3-17. Fire and fuels indicators and their measurements ....................................................................................3-38 

3-18. Fire adjective rating chart ........................................................................................................................3-39 

3-19. Acreages by fire type based on current conditions in the Eddy Gulch LSR ............................................3-40 

3-20. Current and desired fire behavior and fuel profile under 90th percentile weather conditions 

for Eddy Gulch LSR Project Assessment Area........................................................................................3-41 

3-21. Changes in tree mortality in forest stands in the Eddy Gulch LSR at 20 and 30 years 

into the future...........................................................................................................................................3-43 

3-22. Change in crown bulk density and mortality in M Units as a result of treatments under 

Alternative B............................................................................................................................................3-46 

3-23. Changes in fuel indicators in FRZs under Alternative B .........................................................................3-47 

3-24. Changes in fire type in the Assessment Area, resulting from implementation of Alternative B..............3-49 

3-25. Acres of municipal watersheds treated and 0.25-mile WUI around communities in the 

Eddy Gulch LSR Assessment Area..........................................................................................................3-50 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

xviii Contents

3-26. Changes in fire type in the Assessment Area, resulting from implementation of Alternative C............. 3-51 

3-27. Attainment designations for Siskiyou County compared to national standards ...................................... 3-53 

3-28. Selected emissions from a wildfire in the Assessment Area................................................................... 3-54 

3-29. Selected annual emissions from prescribed burning in the Eddy Gulch LSR......................................... 3-55 

3-30. Estimated amount of fugitive dust generated annually by the three alternatives proposed 

for the Eddy Gulch LSR Project ............................................................................................................. 3-55 

3-31. Wildlife species of special interest with the potential to occur in or near the Eddy Gulch LSR, 

Siskiyou County, CA .............................................................................................................................. 3-59 

3-32. Minimum NSO habitat requirements compared to current conditions.................................................... 3-65 

3-33. Current stand structure on ridgetops where proposed M Units are located............................................. 3-66 

3-34. Northern goshawks in the Eddy Gulch LSR Project Assessment Area................................................... 3-70 

3-35. NSO core areas, in or overlapping the Assessment Area, that are susceptible to the 

simulated wildfire under the no-action alternative.................................................................................. 3-74 

3-36. Breakdown of NSO habitat within M Units, pre- and post-treatment..................................................... 3-85

3-37. Acres of proposed thinning in M Units in occupied NSO habitats ......................................................... 3-86 

3-38. Analysis area 7th-field watersheds, proposed treatment acres, and miles of fish-bearing 

streams .................................................................................................................................................. 3-113 

3-39. Summary of past road development by 7th-field watershed ................................................................. 3-118 

3-40. CWE model results for the no-action alternative with modeled wildfire scenario................................ 3-123 

3-41. CWE model results for Alternative B combined with the North Fork Roads 

Stormproofing Project........................................................................................................................... 3-130 

3-42. Direct effects of Alternative B on geologic resources and hazards....................................................... 3-167 

3-43. Indirect effects of Alternative B on geologic resources and hazards .................................................... 3-168 

3-44. Locations of treatment units and roads underlain by ultramafic rocks.................................................. 3-169 

3-45. Alternative B GEO risk ratio data from the CWE model run of October 20, 2008 .............................. 3-170 

3-46. Summary of target Sensitive species and assessment methods, in the Eddy Gulch 

LSR Project Assessment Area .............................................................................................................. 3-174 

3-47. Summary of Forest Service Sensitive plant species sites within Eddy Gulch LSR Project 

proposed treatment units ....................................................................................................................... 3-176 

3-48. Summary of noxious weed sites in the Eddy Gulch LSR Project proposed treatment units, 

August 2008 .......................................................................................................................................... 3-210 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Contents xix

Appendices 

Appendix A: Maps

Map A-1. Vicinity of the Eddy Gulch LSR Project. 

Map A-2. Protection areas identified in the Salmon River CWPP. 

Map A-3. USFWS priority protection areas. 

Map A-4a. Proposed treatment units in the south portion of the Eddy Gulch LSR Project Assessment Area. 

Map A-4b. Proposed treatment units in the north portion of the Eddy Gulch LSR Project Assessment Area. 

Map A-4c. Roadside treatments along emergency access routes that do not pass through an FRZ or Rx Unit. 

Map A-5a. NSO activity centers, core areas, and home ranges in relation to proposed treatment units—south 

portion of Assessment Area. 

Map A-5b. NSO activity centers, core areas, and home ranges in relation to proposed treatment units—north 

portion of Assessment Area. 

Map A-6a. View 1: Alternative B–configuration of treatment units with construction of 1.03 miles of new 

temporary roads and Alternative C–configuration of treatment units without construction of 

1.03 miles of new temporary roads. 

Map A-6b. View 2: Alternative B–configuration of treatment units with construction of 1.03 miles of new 

temporary roads and Alternative C–configuration of treatment units without construction of 

1.03 miles of new temporary roads. 

Map A-7. Eddy Gulch LSR successional stages. 

Map A-8. Historical ignitions and large fires in the Eddy Gulch LSR. 

Map A-9a. Surface and crown fire activity, eye level 2–3 mph winds. 

Map A-9b. Surface and crown fire activity, eye level 3–6 mph winds. 

Map A-10a. Alternative B: Distribution of Fuels Treatments, South Portion of Assessment Area. 

Map A-10b. Alternative B: Distribution of Fuels Treatments, North Portion of Assessment Area. 

Map A-11a. Alternative C: Distribution of Fuels Treatments, South Portion of Assessment Area. 

Map A-11b. Alternative C: Distribution of Fuels Treatments, North Portion of Assessment Area. 

Map A-12a. Locations of Riparian Reserves and plantations in the south portion of the Eddy Gulch LSR 

Project Assessment Area. 

Map A-12b. Locations of Riparian Reserves and plantations in the north portion of the Eddy Gulch LSR 

Project Assessment Area. 

Map A-13a. Fish Distribution, HUC 7 Watersheds, and Riparian Reserves, south portion of Assessment Area. 

Map A-13b. Fish Distribution, HUC 7 Watersheds, and Riparian Reserves, north portion of Assessment Area. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

xx Contents

Appendix B: Public and Agency Comments on the Draft EIS and Forest Service Responses to Comments. 

Appendix C: Klamath National Forest Hazard Tree Policy Safety Provisions on National Forest System Roads 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Document Structure xxi

Document Structure 

The preparation of this Eddy Gulch Late-Successional Reserve Fuels / Habitat Protection Project 

Final Environmental Impact Statement is in compliance with Council on Environmental Quality 

regulations (40 Code of Federal Regulations 1500-1508) for implementing the National 

Environmental Policy Act and with other relevant federal and state laws and regulations. This final 

environmental impact statement (EIS) discloses the direct, indirect, and cumulative effects that would 

result from the Proposed Action and alternatives. This document is organized into five chapters: 

 Chapter 1. Purpose and Need for Action. This chapter explains why the Eddy Gulch LateSuccessional Reserve (LSR) Project is needed and summarizes current and desired 

conditions in the LSR. This chapter also summarizes public collaboration efforts and the 

scoping process that took place for the project. 

 Chapter 2. Proposed Action and Alternatives. This chapter provides a detailed description 

of the no-action alternative (Alternative A), the Proposed Action (Alternative B), and an 

alternative to the Proposed Action (Alternative C). Alternative C was developed based on a 

significant issue raised by the public during collaboration meetings and the scoping 

process. This chapter describes the resource protection measures that would be employed 

to mitigate adverse effects. 

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

the existing conditions (affected environment) for 16 resource topics. The treatments and 

activities that make up the Proposed Action stem from the need to shift existing conditions 

toward desired conditions. This chapter describes the environmental effects that would 

occur from taking no action (Alternative A) or from implementing Alternative B or C. 

 Chapter 4. Consultation and Coordination. This chapter contains the list of preparers for 

this final EIS and describes the agency and tribal consultation that occurred. 

 Chapter 5. This chapter contains the acronym list, glossary, literature cited, and index. 

 Appendix A. This appendix contains the maps referenced in this final EIS. 

 Appendix B. Public and agency comments on the draft EIS and Forest Service responses 

to comments. 

 Appendix C. Klamath National Forest Hazard Tree Policy Safety Provisions on National 

Forest System Roads 

The project record contains additional documentation and data that support the planning and 

analysis process for this project. The project record is located at the Klamath National Forest 

Supervisor’s Office, 1312 Fairlane Road, Yreka, CA, 96097-9549, 530.842.6131. 

This final EIS, the individual resource reports, and the biological assessments / biological 

evaluations are available for review on the project website: http://www.eddylsrproject.com. 
Chapter 1 

Purpose and Need for Action 
Welcome 

You are now in the “Purpose and Need for Action” chapter. Here 

are the topics you can read about. 

1.1 Introduction............................................................................................1-2 

1.2 Environmental Impact Statement Goal and 

Project Objectives..................................................................................1-5 

1.3 Purpose of and Need for the Eddy Gulch Late-Successional 

Reserve Project.......................................................................................1-6 

1.4 Other Objective....................................................................................1-11 

1.5 Summary of the Proposed Action.....................................................1-11 

1.6 Management Direction, Policies, and Laws that Influence 

the Scope of this Environmental Impact Statement.......................1-12 

1.7 Decision to Be Made ...........................................................................1-15 

1.8 Project Schedule...................................................................................1-15 

1.9 Public Participation and Information ...............................................1-15 

1.10 Permits, Licenses, and Other Consultation Requirements............1-21 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 1: Purpose and Need for Action 1-1

Chapter 1. Purpose and Need for Action 

SUMMER 2008—another season marked by hot, dry conditions and a staggering number of 

wildfires in northern California. The spring and summer of 2008 were the driest recorded in northern 

California. The persistence of moderate to severe drought conditions across parts of the West have 

aided in perpetuating a region of extreme fire potential. 

The 2008 fire season in the Klamath National Forest began in mid-June. The lightning storm 

during the weekend of June 21–22, 2008, was an epic event that started more than 3,000 fires in 

California and kicked off the fire season much earlier than usual (R. Moore, Regional Forester). The 

following is an excerpt from a June news release from the Klamath National Forest: 

Yreka, CA (June 24, 2008). The evening of June 19 was very 

busy for Klamath National Forest firefighters as they launched 

initial attacks on 23 fires that began with lightning strikes during 

the storms that moved through the area. The fires occurred 

forestwide. There were four starts on the Happy Camp Ranger 

District, 16 between the Salmon/Scott Ranger Districts, and three 

on the Goosenest Ranger District. 

On June 20 Klamath fire managers turned over the Happy Camp 

fires to the Southern Oregon and Northern California (ORCA) 

incident management team, due to the size, complexity and 

expected duration of those fires. 

That was just the beginning—additional fires ignited and continued to burn into August. 

Fact: July began with a number of wildfires in 12 states, most 

notably California and Arizona. By the middle of the month, 

many of the fires raging across northern California remained 

largely uncontained. As July came to a close, a dozen large fires 

continued to burn in northern and central California. 

Fact: As August came to a close, 21 large fires were burning in 

11 states, primarily northern California, southern Oregon, and 

southern Idaho. By mid-October, over 200,000 acres burned on 

the Klamath National Forest. 

(http://www.ncdc.noaa.gov/oa/climate/research/2008/fire08.html) and (KNF pers. comm. 2008) 

There is nothing that can be done to prevent weather-related fire starts, but there are many actions 

that can be taken to reduce their severity. The Klamath National Forest is proposing the Eddy Gulch 

Late-Successional Reserve Fuels / Habitat Protection Project (Eddy Gulch LSR Project) on the 

Salmon River and Scott River Ranger Districts to provide protection against, and to reduce the 

number of acres that would be burned by large stand-replacing wildfires. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

1-2 Chapter 1: Purpose and Need for Action

1.1 Introduction _________________________________________ 

1.1.1 Project Location 

The Eddy Gulch LSR is on the Salmon River and Scott River Ranger Districts, Klamath National 

Forest, Siskiyou County, California (see Map A-1). (Note: All maps for this final environmental 

impact statement [EIS] are located in Appendix A.) The LSR is located mostly west of Etna Summit, 

south of North Russian Creek and the town of Sawyers Bar, east of Forks of Salmon, and north of 

Cecilville. The LSR is about 61,900 acres in size, making it one of the largest LSRs on the Klamath 

National Forest. The LSR encompasses much of the area between the North and South Forks of the 

Salmon River, as well as the headwaters of Etna Creek. Elevations range from 1,100 feet to about 

8,000 feet. The terrain is generally steep and dissected by sharp ridges and streams. There are a few 

private inholdings in the LSR and along the main Salmon River and other stream corridors adjacent to 

the LSR. 

The legal description for the Eddy Gulch LSR includes the following (all Mount Diablo 

Meridian): 

T38N, R11W, Sections 2-5, 8-10, and 17-19 

T38N, R12W, Sections 1-3, 9-16, and 22-24 

T39N, R10W, Sections 2-10, 15-21, and 29-31 

T39N, R11W, Sections 1-18, 20-29, and 32-36 

T39N, R12W, Sections 11-14, 23-25, and 36 

T40N, R10W, Sections 3-5, 8-11, and 13-35 

T40N, R11W, Sections 24-27 and 34-36 

T41N, R10W, Sections 2-5, 8-17, 20-24, 26-29, and 31-34 

T42N, R10W, Sections 28-29 and 32-35 

1.1.2 Background 

The northern spotted owl (NSO) (Strix occidentalis caurina) was listed as threatened in 1990, and 

the Northwest Forest Plan (USDA, USDI 1994a) identified standards and guidelines and allocated 

lands for LSRs by amending federal land management plans within the range of the NSO. The 

“federal land management plan” for the forest is the Klamath National Forest Land and Resource 

Management Plan (Klamath LRMP) (USFS 1995). LSRs, in combination with other land allocations 

and standards and guidelines, were established to maintain a functional, interactive, late-successional 

and old-growth forest ecosystem. They were designed to serve as habitat for late-successional and 

old-growth-related species, including the NSO. The Klamath National Forest prepared a forestwide 

LSR assessment (Klamath National Forest Forestwide Late-Successional Reserve Assessment) 

(USFS 1999), which describes resources and issues in LSRs on the forest and presents a management 

strategy for attainment of LSR goals and objectives. 

Prior to European settlement, fires ignited by lightning or native Americans were a frequent and 

effective source of disturbance that shaped forest stands in the Eddy Gulch area. These fires occurred 

every 8–16 years and did not burn uniformly but had a mixed severity, with the highest intensity on 

ridgetops and the lowest intensity on the lower third of the steep slopes. As a result, fuels were 

frequently reduced, mature forest cover was scattered on the ridgetops, and stands on the lower third 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 1: Purpose and Need for Action 1-3

of the slopes were characterized by large, well-spaced trees (Taylor and Skinner 1998). Gold was 

discovered in about 1850 in the area that is now the Eddy Gulch LSR. Over the next four to five 

decades, miners removed much of the vegetation in the vicinity of the mining activities for tunnel 

timbers and structures and often burned the rest to expose the mineral resource (examples would be 

the lower portion of Whites Gulch and areas around Black Bear Ranch). The mining-related activities 

resulted in fewer old trees scattered throughout the landscape and fewer stands over 130 years of age. 

With the creation of the Klamath National Forest shortly after the turn of the century, and the 

emphasis on fire suppression beginning about 1910, not only have forests returned to much of the 

potential forest land in the LSR, but most stands contain many more young trees and other understory 

vegetation (along with limbs, logs, and other understory fuels) than would be present under historical 

conditions. These stand conditions provide habitat for certain late-successional-forest-related species, 

but conversely, they also place at least portions of the LSR and surrounding areas, including local 

communities, at risk of high-intensity, large-scale fires (a primary concern) and high levels of insect 

mortality. The LSR experiences about five fire starts per year that require suppression action, either 

initiating in the LSR or spreading into the LSR from surrounding areas. Late-successional habitat, 

watershed health, private property values, and public safety are the major concerns about wildfire in 

the LSR. 

1.1.3 Terms 

Throughout this final EIS, acres presented will be identified (or apparent from context) as 

applying to one of the following areas: 

Eddy Gulch LSR — the entire 61,900-acre LSR. 

Assessment Area — the 37,239-acre portion of the Eddy Gulch LSR west of Etna Summit 

where various treatments are proposed. All inventoried roadless areas that occur in the LSR were 

excluded from planning efforts and are therefore not part of the Assessment Area. 

Treatment Unit — the acres proposed for some type of on-the-ground treatment under a 

particular alternative. 

Analysis Area — the area around treatment units considered in the effects analysis (the analysis 

area may be larger than the LSR Assessment Area). The analysis area varies by resource. 

The following sections list the project objectives, the underlying purpose and need for taking 

action, legislation and policy direction for the objectives, and measurement indicators. The 

measurement indicators are used to describe, quantify, and compare how well the Proposed Action 

and alternatives (including no action) would meet the project objectives and address issues. 

1.1.4 Concerns for the Eddy Gulch LSR 

Concern—the high amount of fuels present. Policies requiring the control of all fires have 

excluded fire from the landscape, resulting in changes to stand structures and higher densities of 

ground and ladder fuels such as brush, small trees, and shade-tolerant tree species. The successful 

implementation of these policies has removed the historic role of fire as a thinning agent (USFS 1995, 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

1-4 Chapter 1: Purpose and Need for Action

1999) and mechanism for regulating the volume of ground fuels. The increased accumulations of 

dead and down woody material and organic debris (duff and litter) have led to larger and more intense 

wildfires in the Klamath Mountains. These intense wildfires have the potential to permanently 

damage soil, degrade watersheds, and remove a high proportion of all vegetation over large areas, 

thereby slowing natural recovery and increasing impacts. The primary concern is what the results of 

current (2008) fire modeling show—that under 90th percentile weather conditions and using current 

heavy fuel loads, 73 percent of the LSR would experience active/passive crown fires, which could 

potentially reduce or destroy habitat suitability for the NSO and other late-successional-dependent 

species. But, of greatest importance during these severe fire events is the threat to human life and 

property. 

Concern—loss of high-quality NSO habitat. The forestwide LSR assessment (USFS 1999) 

determined that, of the 45,220 acres in the Eddy Gulch LSR capable of supporting late-successional 

forest conditions, 42 percent of the acres were late-successional and 37 percent were midsuccessional. These stands support more than the forestwide LSR assessment goal of 20 NSO pairs, 

as well as a variety of other late-successional-forest-related species. However, recent data from the 

LSR indicate the NSO population has not increased for several years (USFWS 2008). The major 

concern in the LSR is this habitat being destroyed by large high-intensity fire (USFS 1999). Indeed, 

the loss of high-quality NSO habitat to wildfires in the Klamath Mountains during the past decade has 

been troublesome (USFWS 2008). 

Concern—damage to communities and municipal watersheds. Cecilville and Sawyers Bar, 

two communities near the Eddy Gulch LSR, were listed in the Federal Register (2001) as 

communities at risk from a wildfire. The Klamath National Forest was a signatory agency to the 

approved Salmon River Community Wildfire Protection Plan (CWPP) (SRFSC 2007). Additionally, 

Black Bear Ranch and Rainbow cooperative fire plans (SRFSC 2002; SRFSC 2003) have been 

prepared. These plans include recommendations to reduce fuel hazards in the wildland-urban 

interface (WUI) in seven municipal watersheds and to provide for safe ingress and egress by reducing 

fuel hazards along emergency access routes that occur in the Eddy Gulch LSR. 

Crown fires could substantially damage communities at risk, remove vegetation, and degrade 

municipal watersheds. Crown fires could prevent the use of emergency access routes required to 

evacuate local residents and allow suppression crews to enter the area. Additionally, there are no 

fuelbreaks that would allow suppression crews to safely work to control the spread of a wildfire. 

1.1.5 Climate Change 

Growing bodies of knowledge have described recent climate changes, and new policies by 

developed nations are acknowledging that our climate is changing. However, climate change is not a 

recent phenomenon. For example, temperatures were below the modern mean (defined as 1928–

1988 A.D.) for nearly the entire period from 1450 to 1850 A.D. (Graumlich 1993). Although some 

intervals of this period were wet (1550–1650 and the early to mid-Eighteenth Century), others were 

remarkably dry (including 1834–1883 A.D., which was the fifth-driest 50-year period of the past 

millennium). Stine (1996) provides additional evidence for a cool and dry climate prior to 1850 and 

concludes that the first half of the Twentieth Century was the third wettest period in the last 

1,000 years. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 1: Purpose and Need for Action 1-5

Diaz (2002) described changes in physical systems, especially water regimes, as climates change 

in the modern period: “Glaciers are retreating, snowpacks are melting earlier, and runoff is less, 

leaving the Mediterranean-based Sierra Nevada summers effectively longer and drier.” Extensive 

modeling of the effects of climate change has been completed for the state of California 

(http://www.climatechange.ca.gov/). Unless changes in existing policies are implemented, there is a 

general consensus that increased concentrations of carbon dioxide will contribute to future increases 

in temperature. The effects of these climate changes on precipitation patterns in California are not as 

clearly understood (Lenihan et al. 2006); however, there is agreement that increased temperatures will 

result in less precipitation arriving as snow and an earlier melting of the snow that does accumulate. 

In response to these climate changes, it is predicted that during this century, mixed-evergreen 

forests (Douglas-fir associations, madrone, and ponderosa pine–black oak) will expand their range 

(due to warmer temperatures) and replace lower-elevation conifer forests. The warmer temperatures 

will also result in replacement of subalpine and alpine communities with other communities (Lenihan 

et al. 2006). Warmer temperatures will dry forest fuels sooner in the year, resulting in longer fire 

seasons, larger fires, and more acres burned (Lenihan et al. 2006; Westerling and Bryant 2006). In 

some areas conifer forests will be replaced by shrub associations, and where fire frequencies increase 

in shrub associations, they will be replaced by grasslands (Lenihan et al. 2006). This could result in a 

reduction in conifer tree vegetation, the dominant vegetation in the Eddy Gulch LSR, and an increase 

in mixed-evergreen forests. 

In response to these changes, resource managers should consider adaptive strategies that 

incorporate activities that increase resistance to change (forestalling impacts or protecting valued 

resources) and activities that increase resilience to impacts (improving the capacity of ecosystems to 

return to a desired condition after disturbance) (Millar et al. 2007). Fuelbreaks can effectively 

increase resistance to the spread of wildfires by modifying fire behavior; they also serve as safe areas 

for suppression crews to work. Large-scale reductions in ground fuels can modify wildfire behavior 

and reduce the loss of vegetation, rendering those areas more resilient to change and allowing them to 

return to their ecosystem function faster than untreated areas. 

1.2 Environmental Impact Statement 

Goal and Project Objectives ____________________________ 

1.2.1 Environmental Impact Statement Goal 

The overall goal of the Eddy Gulch LSR Project EIS is to present an ecosystem-based approach 

for ensuring the safety of persons and communities and protecting and conserving conditions of latesuccessional-forest ecosystems, which serve as habitat for late-successional-associated species. 

1.2.2 Importance of Defining Project Objectives 

Objectives are specific statements of purpose that support the goals an alternative must meet, to a 

large degree, for the planning and environmental analysis process to be considered a success. Meeting 

objectives to a large degree is part of what makes an alternative “reasonable.” Objectives also support 

the purpose of a project and help resolve the need for action. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

1-6 Chapter 1: Purpose and Need for Action

The proposed action must meet the minimum proposal objectives (fulfill the need) and must be 

environmentally acceptable. Likewise, any alternatives that are developed must meet the minimum 

proposal objectives and environmental standards or be dropped from detailed analysis. 

The decision maker will use the proposal objectives, together with environmental issues, as 

evaluation criteria to select the alternative that best fulfills the proposal’s objectives and satisfactorily 

meets environmental guidelines. 

1.3 Purpose of and Need for the 

Eddy Gulch Late-Successional Reserve Project ___________ 

Two primary objectives are presented for the Eddy Gulch LSR Project based on the purpose and 

need for the project, differences between existing and desired resource conditions in the Eddy Gulch 

LSR, pertinent laws, and Forest Service direction. 

The two objectives are as follows (no priority is assumed): 

1. Habitat Protection—Protect existing and future late-successional habitat from threats of 

wildfire that occur inside and outside the Eddy Gulch LSR. 

2. Community Protection—Reduce wildfire threat to communities and municipal water 

supplies and ensure public and firefighter safety. 

These objectives guided the development of the proposed treatments and activities designed to 

maintain or establish a trend toward desired natural and social resource conditions. 

The following section summarizes the need for action (based on existing conditions) and desired 

conditions to demonstrate the link between those conditions and the purpose (objectives) of the Eddy 

Gulch LSR Project. Detailed descriptions of current conditions for 16 resource topics are contained in 

“Chapter 3: Affected Environment and Environmental Consequences.” Chapter 3 also provides 

detailed descriptions of the desired conditions for the three core resources: forest vegetation, fire and 

fuels, and wildlife habitat. 

Objective 1: Habitat Protection—Protect existing and future late-successional 

habitat from threats of wildfire that occur inside and outside the Eddy Gulch LSR.

Need for Action (Existing Conditions). The Eddy Gulch LSR Project is needed to reduce 

excessive fuel hazards to protect and conserve late-successional habitat. Current conditions have 

created the following problems: 

1. Due to policies that required the control of all fires and excluded fire from the ecosystem, 

there have been changes in stand structures, including higher densities of ground and 

ladders fuels such as brush, small trees, and shade-tolerant tree species. 

2. Most of the mid- and late-successional conifer stands in the Assessment Area are choked 

with small trees (less than 10 inches diameter at breast height [dbh]). Additionally, tree 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 1: Purpose and Need for Action 1-7

mortality will continue to increase in response to current competition for resources and 

warmer temperatures, which contribute to higher fuel loads. 

3. Fire modeling, using current conditions, indicates that under 90th percentile weather 

conditions: 

 flame lengths during a wildfire would be from 11 to 20 feet, contributing to crown fire 

behavior; 

 the rate of fire spread would range between 30 and 60 feet per minute, affecting the 

ability of suppression crews to contain fires; and 

 approximately 73 percent of the entire Eddy Gulch LSR (61,900 acres) would 

experience active/passive crown fires that would reduce or destroy habitat suitability 

for the NSO (including designated critical habitat) and other late-successionaldependent species. 

Desired Conditions. The desired conditions are reduced fire behavior and increased resistance to 

the spread of wildfires (which together would improve suppression capability) throughout the LSR. 

Desired conditions include the following: 

1. Safe, effective zones are available for firefighters to contain wildfires (such as fuelbreaks 

that can resist the spread of wildfires) and ground fuels are reduced over large areas of 

existing or future late-successional habitat (that is, resilience to disturbance will be 

increased). 

2. Conifer stands more closely resemble the historic range of conditions that resulted from the 

pre-European settlement historic fire regime (Skinner et al. 2006). 

3. There will be reduced fire behavior throughout the LSR, so fires of less severity are more 

likely to serve their historic roles as both a thinning agent for maintaining ground fuels and 

one of decomposition (USFS 1995). During a wildfire 

 flame lengths will be from 2 to 4 feet, allowing options for suppression strategies; 

 the rate of spread will be less than 20 feet per minute; and 

 no more than 11 percent of the treated acres in the LSR will experience passive/active 

crown fire. 

4. The amount of NSO nesting and roosting habitat is being maintained. 

Measurement Indicators—Acres that are resistant to the spread of or resilient to the effects of a 

wildfire; the percent of fire type (surface or passive or active crown fire); percent of NSO habitat 

adversely affected by wildfire; and conifer stand conditions (tree size and canopy cover). 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

1-8 Chapter 1: Purpose and Need for Action

Objective 2: Community Protection—Reduce wildfire threat to communities and 

municipal water supplies and ensure public and firefighter safety. 

Need for Action (Existing Conditions). The Eddy Gulch LSR Project is needed to reduce 

wildfire risk to communities by reducing fuel hazards and provide people with safe passage by 

reducing fuel hazards along emergency access routes that occur in the Eddy Gulch LSR. 

1. Current fuel conditions are increasing the wildfire risk to residents, property, infrastructure, 

and municipal watersheds. Communities near the LSR would be at risk of high losses. 

2. During a wildfire, emergency access routes (described in the Salmon River CWPP) may 

not be safe or passable because fuel loading and hazard trees along 60 miles of specifically 

identified road segments could potentially block primary escape routes in the event of a 

wildfire—this would compromise the safety of local residents who would need to evacuate 

ahead of the fire and potentially prevent firefighters from reaching the fire area to initiate 

and sustain suppression activities. 

3. Vegetation treatments are needed to reduce fuel loading and continuity and to provide 

strategic locations where firefighters can safely work. Current conditions would be unsafe 

for firefighters because there are no fuelbreaks in place to serve as safe areas from which to 

fight fires, and fires would have the opportunity to grow very large. 

4. In the event of a wildfire, much of the vegetation and ground cover would be removed from 

seven municipal watersheds, which would affect water quality for local residents who 

depend on these areas. 

Desired Conditions. 

1. There is a reduction in fuel hazards and fire behavior in WUI areas. 

2. Fuel loading along the emergency access routes is such that wildfire behavior will be 

reduced—this will improve opportunities for evacuation for local residents and access for 

firefighters during wildfires. 

3. A wildfire will not affect water quality in municipal watersheds. 

4. Strategically placed fuelbreaks are in place to resist the spread of wildfires. 

5. Important infrastructure will be protected during a wildfire. 

6. Degradation of air quality will be reduced during a wildfire because fuels are at levels that 

will limit the intensity and size of wildfires, which will result in a reduction in emissions. 

Measurement Indicators—Acres of WUI treated, miles of emergency access routes treated, acres 

of fuelbreaks constructed, important infrastructure protected, acres of municipal watersheds treated, 

and changes in emissions. 

Table 1-1 summarizes the need for treatments in the Eddy Gulch LSR Project Assessment Area. 
Chapter 1: Purpose and Need for Action 1-9 Table 1-1. Treatment needs for the Eddy Gulch LSR Project. Current Conditions Desired Conditions Need How Prop

Addresses T

Fire suppression has resulted in high levels of ground and ladder fuels. Under these conditions, most of the Assessment Area would be subject to crown fire under extreme weather conditions. Such a wildfire would spread quickly (30–60 feet / minute). There are few areas where fire behavior would allow suppression forces to safely work, so a wildfire would spread quickly throughout much of the Assessment Area. Throughout the Assessment Area, ground and ladder fuels are at levels that support surface fires with low spread rates, allowing firefighters to safely engage in suppression operations. Change fire behavior from crown fire to primarily surface fire; provide safe locations for firefighters to work. Fuel reduction treatment

fuel on the forest floor. Tnumbers of small trees wsurface fires to become will change fire behavior surface fire within treaterates. Fuel reduction trelocated zones will providsuppression forces can Indicator: Acres resist

Fire suppression has resulted in high levels of ground and ladder fuels. Under these conditions, most of the Assessment Area would be subject to crown fire under extreme weather conditions. Ground and ladder fuels are at levels that support surface fires. Change fire behavior from crown fire to primarily surface fire. Fuel reduction treatmen

change fire behavior from surface fire within treateIndicator: Percent of fi

Fire suppression has resulted in high levels of ground and ladder fuels. Conditions are such that fires can burn intensely, killing many trees and increasing risk of losing critical NSO habitat components over 73 percent of Eddy LSR. Ground fuels and ladder fuels are at levels that allow fires to burn without killing large numbers of trees throughout the LSR. Change fire behavior from crown fire to primarily surface fire in the LSR. Fuel reduction treatmen

change fire behavior witfire to primarily surface fNSO habitat adversely aIndicator: Percent of Naffected by wildfire Fire suppression has resulted in high densities of small trees (less than 10 inches dbh) in mid- and late- successional stands. Mortality is occurring and will continue to increase, creating high fuel loads and increasing risk of losing critical NSO habitat components over 73 percent of Eddy LSR. Ladder fuels (small trees) in mid- and late-successional stands are at levels that allow fires to burn without killing large numbers of trees throughout the LSR. Reduce the number of small trees in mid- and late-successional stands. Reduce overall basal area. Thinning treatments will 

will reduce fuel loads anthe remaining trees. Indicator: Conifer stanclosure and basal area Fire suppression has resulted in high levels of ground and ladder fuels within the WUI areas. Under extreme weather conditions, these areas would be subject to crown fire, which would both prohibit effective suppression action and increase the risk to life and property. Ground and ladder fuels are at levels that support surface fires. Change fire behavior in the WUI from crown fire to primarily surface fire. Fuel reduction treatmenwithin the WUI from crowfire. Indicator: Acres of WU
Table 1-1. Treatment needs for the Eddy Gulch LSR Project (continued). 

1-10 Chapter 1: Purpose and Need for Action Current Conditions Desired Conditions Need How Prop

Addresses T

Fire suppression and past harvest have resulted in high levels of ground and ladder fuels along emergency access routes that local residents would use for evacuation during wildfire, and suppression crews would use to enter the area. Fire behavior (primarily crown fire) would render these routes dangerous or unusable for evacuation. Fire behavior along emergency access routes is primarily surface fire rather than crown fire. There are no hazard trees that might fall and block access during a wildfire event. Change fire behavior from crown fire to primarily surface fire. Fuel reduction treatmen

along emergency accesprimarily surface fire. Reensure that these trees dduring emergency situatrender these access rouand allow ingress and egIndicator: Miles of emetreated There are no fuelbreaks (the FRZs) within the Assessment Area where firefighters can safely work during suppression operations. Without effective suppression action, fires have an opportunity to grow very large. FRZs are constructed in strategic locations, allowing firefighters to safely engage in suppression operations. Construct FRZs in strategic locations across the landscape. Firefighters can use FRZ

suppression activities. Indicator: Acres of FRZ

Fire suppression has resulted in high levels of ground and ladder fuels in the areas surrounding important infrastructure outside of WUI (the Eddy Gulch lookout and repeater sites). Conditions are such that fires can burn intensely, and the facilities would be at high risk of damage or destruction. Ground and ladder fuels in areas adjacent to identified infrastructure targets are at levels that support surface fires. Change fire behavior from crown fire to primarily surface fire near identified infrastructure targets. Fuel reduction treatmen

in areas adjacent to iden

Indicator: Important in

High-intensity wildfire can burn through seven municipal watersheds, eliminating vegetation and soil cover that is important to maintaining water quality for local residents. Ground fuels and ladder fuels are at levels that allow fires to burn through municipal watersheds while leaving a high percentage of vegetation and ground cover intact. Change fire behavior from crown fire to primarily surface fire. Fuel reduction treatmen

within treated units from surface fire. This will resand vegetation. Indicator: Acres of mu

Wildfire, once it escapes control, can burn for weeks or even months. Emissions produced during wildfire events can degrade air quality and affect the health of local residents. Type and duration of emissions is dependent on the type of vegetation burned, weather patterns, and the ability of firefighting forces to suppress the fire. Emissions from a wildfire are reduced from those expected under the current situation due to lower amounts of fuels available, and the smaller size of the fire (due to effective suppression operations). Change expected wildfire size, intensity, and duration so that emissions from a wildfire are reduced from those expected under current conditions. Fuel reduction treatment

fuel that burns in a wildfitreated units will change surface fire. Creation of suppression forces to efThese factors will limit thwildfire, which will reduca wildfire event. Indicator: Changes in e
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 1: Purpose and Need for Action 1-11

1.4 Other Objective_______________________________________ 

The Notice of Intent (FR 2008) to prepare an EIS for the Eddy Gulch LSR Project identified a 

third objective for the project. That objective was titled, “Objective 3: Habitat Development—

Promote the continued development of late-successional characteristics.” Objective 3 was deleted 

after more intensive field reviews were conducted, and it was determined that none of the units 

initially proposed for treatment to promote habitat development would satisfy the evaluation criteria, 

as described below: 

 10 units, totaling 337 acres, did not meet habitat criteria for the NSO because the unit was 

not large enough to contain an NSO activity center, it was not located in a watershed with a 

concave topography or on the lower half of the slope, or it was not located near a stream; 

 5 units, totaling 114 acres, were greater than 150 years old, or thinning would not 

accelerate their development within 30 years; 

 2 units, totaling 6 acres, were small and isolated, and it would not be cost-effective to treat 

them; and 

 2 units (M4 and M21) are in proposed Fuel Reduction Zones (FRZs), and the prescriptions 

were changed to FRZ treatments rather than habitat-development treatments. 

1.5 Summary of the Proposed Action________________________ 

The Proposed Action is designed to improve and protect the LSR’s ability to meet its designated 

objectives of providing habitat for late-successional forest-related species and protecting WUI values. 

The interdisciplinary team (ID team) identified 25,969 acres of treatments to protect latesuccessional habitat and communities. Three primary treatment types were identified in the Eddy 

Gulch LSR Assessment Area: FRZs, Prescribed Burn Units (Rx Units), and Roadside (RS) treatments 

along emergency access routes, which are described below. 

 FRZs—strategically located on ridgetops to increase resistance to the spread of wildfires. 

The FRZs would be wide enough to capture most short-range spot fires, and ground, 

ladder, and crown fuels are reduced so as to change crown fires to surface fires within the 

treated areas. The FRZs would provide safe locations for fire-suppression personnel to take 

fire-suppression actions during 90th percentile weather conditions, and they serve as 

anchor points for additional landscape-level fuel treatments, such as underburning. 

- Proposed Action. Construct 16 FRZs totaling 8,291 acres to increase resistance to 

wildfires. The 8,291 acres includes 931 acres in 42 M Units (thinning units) and 

7,383 acres in fuel reduction areas (outside the M Units) to reduce ground and ladder 

fuels. 

 Rx Units—a series of landscape-level treatments (ranging from 250 to 4,300 acres in size) 

designed to increase resilience to wildfires by reducing ground and ladder fuels. Most of 

these treatments would occur on south-facing aspects where fuels dry faster, and treatments 

would support the role of the FRZs. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

1-12 Chapter 1: Purpose and Need for Action

- Proposed Action. Implement 17,524 acres of Rx Units to increase resiliency to 

wildfires. 

 RS treatments—along 60 miles of emergency access routes identified in the Salmon River 

CWPP and designed to facilitate emergency access for residents to evacuate and for 

suppression forces to safely enter the LSR in the event of a wildfire. 

- Proposed Action. Treat 44 miles of emergency access routes in FRZs and Rx Units 

(treatments would be similar to the FRZ or Rx Unit the route passes through) and 

16 miles (154 acres) of RS treatments outside of FRZs and Rx Units—a total of 

60 miles of RS treatments along emergency access routes. 

Additional descriptions of the treatments are provided in Chapter 2 of this final EIS. Where land 

use objectives (LSR, Riparian Reserves, and WUI) overlap, treatments were designed to meet each 

objective to the fullest extent possible. 

1.6 Management Direction, Policies, and Laws that Influence 

the Scope of this Environmental Impact Statement ________ 

National Forest management is guided by various laws, regulations, and policies that provide the 

framework for all levels of planning, including regional guides, land and resource management plans, 

and site-specific documents, such as an EIS. The higher-level documents are incorporated by 

reference and can be obtained from the Klamath National Forest or online at 

http://www.fs.fed.us/r5/klamath. 

1.6.1 Klamath National Forest Land and Resource Management Plan 

The Eddy Gulch LSR is managed as part of a system of multiple-use as directed by the Klamath 

LRMP, which provides both forestwide and management area direction. Forestwide direction, which 

applies to all management areas, is located on pages 4-3 through 4-66 of the Klamath LRMP (USFS 

1995). Management areas have distinct management goals, management requirements, and desired 

conditions. The proposed project lies within “Special Habitat–Late-Successional Reserves” 

(Management Area 5) and “Riparian Reserves” (Management Area 10). (Note: all page references in 

this final EIS refer to the version of the Klamath LRMP that includes all amendments as of 

November 21, 2001 

[http://www.fs.fed.us/r5/klamath/projects/forestmanagement/forestplan/index.shtml]). 

1.6.1.1 Riparian Reserves and Key Watersheds 

The Klamath LRMP includes the Aquatic Conservation Strategy (ACS) (Klamath LRMP 

Chapter 4, page 4-6), of which Riparian Reserves are a component. Specific direction for 

management of Riparian Reserves is found in the ACS and in the Klamath LRMP Standards and 

Guidelines for Management Area 10 (Chapter 4, pages 4-25 to 4-27 and pages 4-106 to 4-114). The 

Standards and Guidelines are designed to protect the unique functions (such as stream shade, 

sediment filtering, and large wood recruitment to the stream) of near-stream areas and preserve their 

integrity by not engaging in activities that disturb soils or destabilize slopes within Riparian Reserves. 

Adoption of the ACS through the Northwest Forest Plan Record of Decision (USDA, USDI 1994a) 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 1: Purpose and Need for Action 1-13

and the Klamath LRMP set the framework for significant changes in the way ecosystems are 

managed, conserved, and restored. Among these changes is the application of focused and prioritized 

restoration and protection in areas with the highest likelihood of recovery and retention of highquality aquatic habitat. 

The Riparian Reserves are designated along all intermittent and perennial stream courses, seeps, 

springs, lakes, and unstable areas and cover about 8,624 acres (14 percent) of the Eddy Gulch LSR. 

Within the Riparian Reserves, riparian-dependent resources receive primary emphasis and special 

Standards and Guidelines apply (USFS 1995). 

The concept of Key Watersheds is another component of the ACS. Key Watersheds act as refugia 

for endangered salmonids and other aquatic and riparian-dependent species. The project Assessment 

Area lies within the Salmon River watershed, which is a Key Watershed. Guidelines require 

watershed analysis prior to major projects and no net increase in road miles. Because the Eddy Gulch 

LSR is in several watersheds, several watershed analyses and their resultant recommendations apply. 

Portions of the discussions about existing and desired conditions, as well as identification of the need 

for the Proposed Action, came from these analyses. 

1.6.2 Healthy Forests Restoration Act 

The 2003 Healthy Forests Restoration Act (HFRA) (US Cong. 2003) was passed to reduce 

wildfire risk to communities, municipal watersheds, and at-risk federal lands (Sec. 2 [1]). The act 

identifies CWPPs as collaborative efforts to identify and prioritize fuel reduction treatments on 

federal and nonfederal lands (Sec. 101[3]). Federal agencies are required to consider CWPP projects 

in environmental analyses, either as a part of the proposed action or as an alternative (Sec. 104[d] 

[3]). Projects on federal lands receive priority funding if those projects protect at-risk communities or 

watersheds or implement CWPPs (Sec. 103[a]). All of the Eddy Gulch LSR Project is designed to 

reduce wildfire risk to communities, municipal watersheds, and federal lands occupied by a 

threatened species; additionally, the project considers projects in an approved CWPP. 

Section 104 of the HFRA establishes special procedures when agencies prepare environmental 

assessments or EISs for authorized hazardous-fuel-reduction projects. Except for the act’s 

authorization to analyze fewer alternatives than required under the National Environmental Policy Act

(commonly referred to as “NEPA”) (HFRA Sections 104(c) and (d)), most of the requirements of 

Section 104 are consistent with normal NEPA practices. Section 104(e) of the HFRA requires 

agencies to provide notice of the project and conduct a public meeting when preparing authorized 

hazardous-fuel-reduction projects. Section 104(f) encourages meaningful public participation during 

preparation of authorized hazardous-fuel-reduction projects. The U.S. Department of Agriculture 

Forest Service and U.S. Department of the Interior Bureau of Land Management shall facilitate 

collaboration when they are preparing authorized hazardous-fuel-reduction projects. As appropriate, 

collaboration should include representatives from tribes, local representatives from federal and state 

agencies, local governments, landowners, other interested persons, community-based groups, and 

other nongovernmental organizations (USDA, USDI 2004). 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

1-14 Chapter 1: Purpose and Need for Action

1.6.3 Klamath National Forest Forestwide 

Late-Successional Reserve Assessment 

The Record of Decision on Management of Habitat for Late-Successional and Old-Growth Forest 

Related Species Within the Range of the Northern Spotted Owl (USDA, USDI 1994b) established a 

network of LSRs and accompanying management standards and guidelines. The network of reserves 

is intended to provide old-growth-forest habitat, provide for populations of species that are associated 

with late-successional and old-growth forests, and help ensure that diversity of late-successional 

species will be conserved. This direction and Standards and Guidelines for management of LSRs was 

incorporated into the Klamath LRMP and can be found in several sections of the document, including 

forestwide Standards and Guidelines and Management Area 5 direction (Chapter 4 of the Klamath 

LRMP). 

The 1999 forestwide LSR assessment was prepared for 11 LSRs in the Klamath National Forest, 

and it is a management tool intended to be used before habitat manipulation activities are designed 

and implemented. The purpose of the forestwide LSR assessment was to develop a management 

strategy for the LSRs and to provide information to decision makers who are managing for attainment 

of LSR goals and objectives. 

The assessment covers the history and inventory of vegetative conditions, a list of latesuccessional-forest-associated species, a history and description of current land uses, a fire 

management plan, criteria for developing appropriate treatments, identification of treatment areas, a 

proposed implementation schedule, and proposed monitoring and evaluation components. Objective 1 

for the Eddy Gulch LSR Project is to “protect existing and future late-successional habitat from 

threats of wildfire that occur inside and outside the Eddy Gulch LSR.” This objective was adapted 

from Objectives 1, 3, and 6 of the forestwide LSR assessment. 

1.6.4 National Forest Management Act 

The National Forest Management Act of 1976 provides specific management requirements that 

need to be addressed when implementing timber harvest activities on National Forest System lands. 

The regulations include specific guidelines designed to ensure that timber will be harvested from 

National Forest System lands only where 

 there is assurance that such lands can be adequately restocked within five years after 

harvest; 

 soil, slope, or other watershed conditions will not be irreversibly damaged; 

 protection is provided for streams, streambanks, shorelines, lakes, wetlands, and other 

bodies of water from detrimental changes in water temperatures, blockages of water 

courses, and deposits of sediment, where harvests are likely to seriously and adversely 

affect water conditions or fish habitat; and 

 the harvesting system to be used is not selected primarily because it will give the greatest 

dollar return or the greatest unit output of timber (16 USC 1604 (g)(3)(E)). 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 1: Purpose and Need for Action 1-15

1.6.5 National Environmental Policy Act 

NEPA requires all federal agencies to initiate interdisciplinary planning that considers and 

discloses environmental effects in their decisions. To meet NEPA requirements, federal agencies 

must prepare a detailed statement that describes the effects of federal actions; this can be 

accomplished through an EIS, environmental assessment, or categorical exclusion. The U.S. 

Environmental Protection Agency reviews and comments on these documents prepared by other 

federal agencies. 

1.7 Decision to Be Made___________________________________ 

The Responsible Official (decision maker) for this action is the Klamath National Forest 

Supervisor. The decision maker will consider how well each alternative would meet the objectives 

(purposes) described above in Section 1.4 and addresses the issues described below under the 

summaries for the collaboration (Section 1.9.4.1) and scoping (Section 1.9.4.2) processes, and thus, 

would best meet the need. The decision maker will decide whether to implement an action or take no 

action. After the final EIS is completed, a Record of Decision will then be issued and will contain the 

rationale for the decision and a discussion of any applicable mitigation measures (referred to 

“resource protection measures” in this final EIS). 

1.8 Project Schedule______________________________________ 

The Responsible Official expects to make a decision on this project during the spring of 2010, 

with implementation to begin in 2011, and project activities continuing for 10 years. 

1.9 Public Participation and Information _____________________ 

NEPA and the Council on Environmental Quality (CEQ) regulations that implement the act, 

require public participation during the environmental analysis process. The HFRA goes a step further, 

however, by encouraging citizen collaboration at the earliest stage of project planning, not just during 

NEPA’s required “scoping” period. The collaboration and scoping efforts conducted on behalf of the 

Eddy Gulch LSR Project are described in Sections 1.9.4 and 1.9.5. 

It was important at the start of the Eddy Gulch LSR Project to provide tools for ensuring that 

people interested in the project could stay informed and involved. Those tools include a project 

website, comprehensive mailing list, newsletters, fact sheets, and presentations. 

1.9.1 Project Website 

One of the first actions in October 2007 was to create a website for the project so public 

information materials, project updates, and meeting announcements would be available to everyone 

interested in the project (the website address is http://www.eddylsrproject.com). The website currently 

contains the project newsletters, fact sheets, Stewardship Fireshed Analysis, Notice of Intent, and 

Proposed Action, scoping summary, the draft EIS, this final EIS, and the related resource reports. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

1-16 Chapter 1: Purpose and Need for Action

1.9.2 Project Mailing List 

The project mailing list currently contains approximately 1,200 names. The list, in part, draws 

upon knowledge of the towns and neighborhoods described in the Salmon River CWPP. County 

records were searched (by zip code) to ensure the mailing list contains all residents, property owners, 

and businesses in proximity to the Eddy Gulch LSR who could be most affected by the proposed 

project. 

1.9.3 Project Newsletters and Fact Sheets 

Newsletters. The newsletters served as an important tool for keeping people informed about the 

early progress of the Eddy Gulch LSR Project. The first issue was distributed in November 2007, and 

the second issue was mailed in March 2008. The newsletters have been uploaded to the project 

website. 

Fact Sheets. Two fact sheets have been placed on the project website: one provides background 

on the creation of LSRs, and the other provides a glossary of terms related to fire and fuels. 

1.9.4 Citizen and Agency Collaboration 

under the Healthy Forests Restoration Act 

The HFRA modified certain NEPA requirements for urgent fuels treatment projects in listed 

species habitat and at-risk communities, reducing, for example, the number of alternatives requiring 

evaluation, but adding an extended community collaboration process to help identify community 

concerns and issues. Although the act made some NEPA procedures more efficient, the act did not 

reduce an agency’s obligation to complete appropriate environmental evaluation, nor did it 

shortchange the right of the public to understand agency proposals and provide their views to federal 

agencies on matters affecting public lands. 

Collaboration with communities and the public is the cornerstone of “A Collaborative Approach 

for Reducing Wildland Fire Risks to Communities and the Environment: 10-Year Comprehensive 

Strategy Implementation Plan” (US Cong. 2006). While some procedural requirements have been 

expedited, all existing environmental statutes remain in place. 

1.9.4.1 Collaboration Meetings 

The collaboration process for the Eddy Gulch LSR Project began with a meeting on 

September 25, 2007, with Siskiyou County, the U.S. Fish and Wildlife Service (USFWS), and 

National Marine Fisheries Service (NMFS). Fourteen collaboration meetings were held between 

September 2007 and March 2008. District Ranger Ray Haupt hosted a field trip to the project 

Assessment Area on May 23, 2008. District Ranger Haupt initiated formal consultation with the 

Yurok Tribe, the Quartz Valley Indian Reservation, and the Karuk Tribe through letters dated 

October 15, 2007, and a letter to the Shasta Tribe dated March 12, 2008. He also met formally with 

Karuk Tribal leaders on September 13, 2007; December 10, 2007; June 12, 2008; and September 30, 

2008, to discuss the Eddy LSR Project. 

The communities closest to the Eddy Gulch LSR (such as Sawyers Bar and Forks of Salmon) 

were the focus when scheduling workshops and community dialogues. Meetings were also held in 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 1: Purpose and Need for Action 1-17

other communities such as Yreka, Orleans, Happy Camp, and Fort Jones. The intent was to make 

meeting attendance convenient for people in order to encourage greater participation. Attendance at 

each collaboration meeting ranged from 6 to 20 people. Collaboration meetings were also held with 

the USFWS and NMFS, Siskiyou County, and the Siskiyou County Firesafe Council in Yreka (see 

“Chapter 4: Consultation and Coordination”). 

Microsoft PowerPoint presentations were prepared for the first few meetings in late fall / early 

winter of 2008. The presentations and subsequent discussions centered on the creation and purpose of 

LSRs under the Northwest Forest Plan, the importance of protecting LSR resources, and current 

conditions in the Eddy Gulch LSR. The Salmon River CWPP was reviewed and discussed in order to 

understand community needs and how that information could be folded into objectives developed for 

the Eddy Gulch LSR Project. A PowerPoint presentation was also prepared to present the results of 

the Stewardship Fireshed Analysis that was conducted for the Eddy Gulch LSR Project. 

People’s suggestions and comments were used to develop the initial purpose (objectives) of the 

project, identify various problems in and surrounding the LSR, and design the early version of the 

Proposed Action. Activities at subsequent collaboration meetings included reviewing maps and giving 

people opportunities to draw on the maps and point out emergency access roads and other areas of 

concern. The Klamath National Forest is appreciative of the Salmon River Fire Safe Council’s 

collaborative efforts—especially Jim Villeponteaux’s and Petey Brucker’s contributions to the 

development of this project. Objective 2 for the Eddy Gulch LSR Project (refer to Section 1.4 above) 

supports the issues and ideas expressed in the CWPP and public collaboration meetings. 

Collaboration meetings in late winter focused on preliminary treatment areas and treatment types 

and on documenting participants’ concerns and suggestions for the initial design of the Proposed 

Action. Comments were used to adjust the Proposed Action to create the version that would 

eventually be distributed for review during the scoping process. 

1.9.4.2 What Was Learned During Collaboration 

The discussions during the collaboration meetings were very valuable—participants voiced 

concerns, asked questions, and offered suggestions for the project, which aided in the development of 

the Proposed Action. Some of the comments are summarized below. 

 Coarse woody debris must be maintained. 

 Consider 60 percent canopy closure. 

 Old-growth characteristics must be protected and maintained. 

 Consider 80 percent canopy closure on north-facing slopes and 60 percent on south-facing 

slopes. 

 Owls that are present must be protected. 

 Don’t plan treatments that can’t feasibly be maintained. 

 Implement multiparty monitoring before, during, and after project implementation. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

1-18 Chapter 1: Purpose and Need for Action

 Do not build temporary roads; road issues are sedimentation, sliding, and mass wasting. 

 Describe the amount of acres and average size of trees in the plantations; plantations 

should be a priority for thinning; consider pile and burn and leaving slash; consider the 

amount of dollars to treat plantations. 

 Pull in a variety of ways to tie in components such as tanker sites, key emergency access 

routes, and private land interface areas; use the Salmon River CWPP in project planning. 

 This draft EIS should address the dollars needed for pre-commercial thinning in a 

plantation; there is concern about slash left after pre-commercial thinning. 

 Will there be subsistence firewood opportunities for public and commercial firewood? 

 Underburning needs to be considered. 

 Describe what logging systems will be used. 

 Collaborative stewardship should be considered for this project. 

 Bring fire back to the landscape. 

 Look at the role of the hardwood component in stands and how hardwoods are used in 

stand structure. 

 Need to make a distinction between dominant canopy and sub canopy. 

1.9.5 Scoping Process under the National Environmental Policy Act 

Scoping is described in the CEQ’s NEPA implementing regulations as an early and open process 

to ensure that the full range of issues related to a proposed action are addressed and that all significant 

issues are identified. Scoping also provides the opportunity for agencies, elected officials, members of 

the public, and American Indian tribes to present additional background and technical information. 

Prior to the HFRA, public participation was initiated during the scoping process—after a federal 

agency had developed its proposed action. For the Eddy Gulch LSR Project, early citizen and agency 

collaboration was used as a valuable tool in helping to develop the Proposed Action. The Proposed 

Action was refined using suggestions and comments received from the public and agencies during the 

scoping process. 

In the final set of collaboration meetings in early March 2008, participants stated they did not feel 

the need for meetings during the scoping period. They preferred a field trip to the Eddy Gulch LSR to 

visit some of the proposed treatment units. That field trip occurred on October 29, 2008, led by 

District Ranger Ray Haupt. 

1.9.5.1 What Was Learned During Scoping 

The purpose and need for the Eddy Gulch LSR Project and the Proposed Action were the topics 

of the second project newsletter, which was used as the formal “scoping letter” to the public and 

agencies. The newsletter provided two methods for people to submit comments: email or regular 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 1: Purpose and Need for Action 1-19

mail. Seven documents were received during the scoping period—three by regular mail and four by 

email. Of the seven documents, one asked about the date for close of the comment period and another 

asked if there was a map of “burn units produced in topographic format.” These two documents were 

inquiries and not considered comment documents, although the senders did receive an email response 

to acknowledge receipt of their correspondence. The other five comment documents expressed issues 

or suggestions. 

The CEQ regulations that implement NEPA guide federal agencies in handling nonsignificant 

issues by directing them to “identify and eliminate from detailed study the issues which are not 

significant or which have been covered by prior environmental review” (CEQ Section 1506.3; 

40 CFR 1501.7). Nonsignificant issues are those that are (1) already addressed by law, regulation, 

forest plan, or other higher level decision; (2) beyond the scope of the purpose and need described in 

the Notice of Intent; (3) not connected to the proposed action; (4) conjectural and not supported by 

scientific or factual evidence; or (5) irrelevant to the decision to be made. 

The project website (http://www.eddylsrproject.com) contains the full “Scoping Outcome 

Summary” under the link “Citizen Collaboration and Scoping Process.” Below are excerpts from 

some of the issues expressed during the scoping process. 

Significant Issue. One significant issue was identified during scoping: 

Construction of temporary roads

Comment Temporary roads can allow for more effective and efficient management 

of the publics land. They can provide for better economics and in many 

cases reduce environmental impacts as compared to alternative treatments 

such as long skids and large clearings for helicopter landings. 

Comment: We also ask that serious consideration be made for including temporary 

road construction that will assist with the implementation of this project. 

Comment: We believe that upon examining a roadless alternative, you will conclude 

that a fair cost/benefit analysis will strongly suggest a road-free project is 

the superior course of action. 

Comment: Please note that while new road construction is often described by the 

agency as “temporary,” that all new road construction results in long-term 

impacts to soil health and productivity. 

Comment: The NEPA document must anticipate risks posed by building new roads, 

including the possibility of road failure and resulting damage to 

downstream resources. 

Outcome. Based on the above comments, “Alternative C: No New Temporary Roads 

Constructed” was developed to exclude temporary road construction that could increase erosion and 

adversely affect downstream resources. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

1-20 Chapter 1: Purpose and Need for Action

Relevant Issues. The following are some of the relevant issues that were voiced during scoping: 

Comment: Project Feasibility—consider the feasibility of implementing the large 

amount of prescribed burn acres and consider the limited operating periods 

and restrictions. 

Comment: Canopy Closure—comments regarding canopy closure differed, with one 

commenter preferring 25 to 45 percent to ensure treatment effectiveness, 

and the other preferring 60 percent on south aspects and 80 percent on 

north aspects. 

Comment: Canopy Closure and Treatment Effectiveness—we believe in order for 

these treatments to be totally effective, both ground and aerial vegetation 

needs to be treated. Canopy closure needs to be open, 25 to 40 percent, 

and the treatments need to provide for long-term effectiveness. There will 

be many instances when larger diameter trees (greater than 12 inches dbh) 

will need to be removed in order to fully meet your roadside and FRZ 

objective. 

Comment: Timeframe and Long-Range Desired Conditions—when developing the 

prescriptions we ask that you identify the long-range desired condition, 

how long you want the proposed treatments to be effective, and then 

design the Rx [prescription] to meet the desired condition and time frame 

for the LSR land allocation. It must be clearly identified in the analysis if 

the proposed treatments will achieve these long-range desired conditions 

or if future treatments will be necessary to meet the stated goals. 

Comment: Diameter Limits—as this is an HFRA project within LSR, we highly 

recommend disclosing diameters of trees, especially over 24 inches that 

would be marked for extraction. 

Comment: Diameter Limits—our organizations have advocated small diameter 

thinning as a positive way to improve forest health and maintain an 

ecologically and economically sensible timber economy. While we 

recognize the value and encourage the thinning of ground and ladder fuels, 

we encourage the Forest Service to resist the temptation to remove larger 

diameter trees. 

Comment: Stand Density Index—blanket SDI [stand density index] marking 

guidelines do not always adequately address fuels issues. Please be as 

specific as possible in draft EIS as to what marking guidelines / Rx is [are] 

for each stand and also the amount of volume in each stand. 

Comment: Snags and LWD [large woody debris] / CWD [coarse woody debris]—

please make sure that LWD that is currently down does not get removed or 

disturbed, and that guidelines for both snags and LWD / CWD are 

followed, perhaps even greater than guidelines. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 1: Purpose and Need for Action 1-21

Comment: Cumulative Impacts / Threshold of Concern—the Eddy Gulch LSR 

Project should contain project features and mitigation measures that are 

designed to minimize and/or reduce cumulative impacts to below 

thresholds of concern. 

1.9.6 Draft EIS Review Period 

The 45-day review period for the draft EIS ran from July 24, 2009 to September 8, 2009. Seven 

comment documents were received, and most comment documents identified individual concerns. 

Responses were developed for 68 individual comments. The exact words of each respondent were 

used rather than summaries of the person’s words to ensure accuracy and objectivity. Public and 

agency comments, and Forest Service responses to comments, can be found in Section B.2 of 

Appendix B of this final EIS. Full copies of public and agency comment documents are contained in 

Section B.3 of Appendix B. 

Edits were made to the final EIS (and related resource reports) based on public and agency 

comments. No changes were made to the two action alternatives (Alternative B: Proposed Action or 

Alternative C: No New Temporary Roads Constructed), and no additional action alternatives were 

developed. 

1.10 Permits, Licenses, and Other 

Consultation Requirements_____________________________ 

No federal permits, licenses, or entitlements are necessary to implement the proposed project. The 

USFWS and NMFS must approve biological assessments, consistent with the federal Endangered 

Species Act. State requirements, based on federal laws, and administered by the County Agricultural 

Commissioner for air and water quality management, will be followed. These requirements include 

burning only on permissive burn days or receiving a special variance prior to ignition. Smoke permits 

are required from the Siskiyou County Air Pollution Control District. Timber Harvest Activity 

Waivers are required from the California Regional Water Quality Control Board. 

The Forest Service consulted with federal (USFWS and NMFS) agencies during the development 

of this final EIS. Details of these consultations, and consultations with federally recognized tribes and 

interested and affected tribes, are in “Chapter 4: Consultation and Coordination.” 
Chapter 2 

Proposed Action and Alternatives
Welcome 

You are now in the “Proposed Action and Alternatives” chapter. Here 

are the topics you can read about. 

2.1 Introduction............................................................................................2-1

2.2 Description of the Alternatives Considered in Detail ......................2-1

2.3 Terms.......................................................................................................2-2

2.4 Alternative A: No-Action Alternative.................................................2-2

2.5 Alternative B: Proposed Action...........................................................2-2

2.6 Alternative C: No New Temporary Roads Constructed................2-19

2.7 Alternatives Considered but Eliminated from 

Detailed Study ......................................................................................2-20

2.8 Summary Comparison of Alternatives..............................................2-20

2.9 Resource Protection Measures...........................................................2-22

2.10 Seasonal Constraints on Operations in the 

Eddy Gulch LSR Project Assessment Area .....................................2-32 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 2: Proposed Action and Alternatives 2-1

Chapter 2. Proposed Action and Alternatives 

2.1 Introduction__________________________________________ 

The United States Department of Agriculture (USDA) Forest Service, Klamath National Forest, 

Salmon River and Scott River Ranger Districts is proposing treatments in the Eddy Gulch LateSuccessional Reserve (LSR) Assessment Area to reduce the threat of stand-replacing wildfire that 

could eliminate or significantly reduce habitat suitability for late-successional species and at-risk 

fisheries or destroy or degrade private property, municipal watersheds, and infrastructure. 

The Proposed Action has been designed to meet the purpose of the Eddy Gulch LSR Project 

(summarized below in two objectives) and to satisfy the need for action by using mechanical and 

prescribed burn treatments to reduce fuels and minimize the threat of stand-replacing wildfire. The 

two objectives (first identified in Chapter 1) are as follows (no priority is assumed): 

 Habitat Protection—Protect existing and future late-successional habitat from threats of 

wildfire that occur in the Eddy Gulch LSR. 

 Community Protection—Reduce wildfire threat to communities and municipal water 

supplies and ensure public and firefighter safety. 

These objectives helped guide the development of proposed treatments and activities to maintain 

or establish a trend towards desired resource and social conditions. The desired and existing 

conditions are summarized in “Chapter 1: Purpose and Need,” with details provided in the various 

resource sections in Chapter 3 and the individual resource reports. 

2.2 Description of the Alternatives Considered in Detail ________ 

The Council on Environmental Quality (CEQ) regulations for implementing the National 

Environmental Policy Act (NEPA) require federal agencies to rigorously explore and 

objectively evaluate all reasonable alternatives and to briefly discuss the reasons for eliminating any 

alternatives that were not developed in detail (40 Code of Federal Regulations [CFR] 1502.14). The 

Proposed Action for the Eddy Gulch LSR Project considered projects identified in the Salmon River 

Community Wildfire Protection Plan (CWPP), as required by the Healthy Forests Restoration Act

(HFRA) (US Cong. 2003). A second action alternative (Alternative C), which does not include 

construction of 1.03 miles of temporary roads, was developed in response to public comments 

received during collaboration meetings (HFRA Sec. 104[c]) and the NEPA-required scoping 

process. The three alternatives analyzed in this final environmental impact statement (EIS) are 

 Alternative A: No Action 

 Alternative B: Proposed Action (Forest Service Preferred Alternative) 

 Alternative C: No New Temporary Roads Constructed 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

2-2 Chapter 2: Proposed Action and Alternatives

2.3 Terms ______________________________________________ 

Eddy Gulch LSR — the entire 61,900-acre LSR. 

Assessment Area — the 37,239-acre portion of the Eddy Gulch LSR west of Etna Summit 

where various treatments are proposed. All inventoried roadless areas that occur in the LSR were 

excluded from planning efforts and are therefore not part of the Assessment Area. 

Treatment Unit — the acres proposed for some type of on-the-ground treatment under a 

particular alternative. 

Analysis Area — the area around treatment units considered in the effects analysis (the analysis 

area may be larger than the Assessment Area). The analysis area varies by resource. 

2.4 Alternative A: No-Action Alternative _____________________ 

The no-action alternative complies with CEQ regulations for implementing NEPA 

(40 CFR 1502.14(d)). It is not a baseline condition but rather a description of future circumstances 

without implementation of the Eddy Gulch LSR Project. The no-action alternative is described in this 

final EIS as continuation of the current level of management and public use—this includes road 

maintenance, dispersed recreation (hunting, fishing, camping, and hiking), mining, watershed 

restoration projects, and a simulated 7,200-acre modeled wildfire, where a majority of the fire was 

characterized by a stand-replacing crown fire. The time frame for analysis is considered to be 

20 years. Given the fuel hazard in the Eddy Gulch LSR and current predictions of climate change, it 

is assumed at least one wildfire will escape initial attack during the 20-year period and burn under 

90th percentile weather conditions (defined as 10 percent of the days in the historical weather 

database that had lower fuel moisture and higher wind speeds compared to the rest of the days). An 

analysis of a wildfire for three days that escaped initial attack in the Eddy Gulch LSR Project 

Assessment Area indicates that fire would burn 7,200 acres. Of those 7,200 acres, 1,355 acres 

(19 percent) would be surface fire; 5,065 acres (70 percent) would be a passive crown fire; and 

780 acres (11 percent) would be an active crown fire. These crown fires would result in extensive tree 

mortality, approaching 100 percent, over 81 percent of the total burned area. 

2.5 Alternative B: Proposed Action _________________________ 

One goal of the Eddy Gulch LSR Project was to identify protection targets—those areas that 

would be threatened by wildfire. The areas of concern in the Klamath National Forest are the 

wildland-urban interface (WUI) areas, municipal watersheds, and emergency ingress and egress 

routes identified in the CWPP; northern spotted owl (NSO) nest sites and habitat; and other important 

resources and historic features as described in Sections 2.5.1.1–2.5.1.4 of this chapter. The protection 

targets were considered during design of the proposed treatments. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 2: Proposed Action and Alternatives 2-3

2.5.1 Identifying Treatment Locations 

The proposed treatment locations and treatment types were developed in response to protection 

targets 

 identified through the Stewardship Fireshed Analysis (SFA) process that was conducted for 

the Eddy Gulch LSR Project and the citizen collaboration workshops for the SFA and Eddy 

Gulch LSR Project; 

 provided by the United States Fish and Wildlife Service (USFWS) in Yreka, California; 

and 

 identified in the Salmon River CWPP, Black Bear Ranch Cooperative Fire Safe Plan, and 

Rainbow Cooperative Fire Safe Plan. 

Numerous Forest Service documents guided development of this Proposed Action; those are the 

 Klamath National Forest Land and Resource Management Plan (Klamath LRMP) 

(USFS 1995a) 

 Klamath National Forest Forestwide Late-Successional Reserve Assessment (forestwide 

LSR assessment) (USFS 1999) 

 Upper South Fork Ecosystem Analysis (USFS 1994) 

 North Fork Salmon Ecosystem Analysis (USFS 1995b) 

 Callahan Ecosystem Analysis (USFS 1997) 

 Final Biological Assessment for Prescribed Fire and Fuels Hazard Reduction 2007–2011 

Klamath National Forest (USFS 2007) 

 Programmatic Biological Assessment and Evaluation for Pre-commercial Thin and Release 

Actions and Fuel Hazard Reduction Actions on the Klamath National Forest (USFS 2001) 

 Klamath National Forest Hazard Tree Policy—Safety Provisions on National Forest 

System Roads (USFS 2005) 

2.5.1.1 Stewardship Fireshed Analysis for the Eddy Gulch LSR 

The SFA provides a detailed discussion about the SFA process. The process was developed by the 

Pacific Southwest Regional Office of the USDA Forest Service fuels management staff. It was 

designed to promote the collaborative development of treatments for a large landscape. Its intent is to 

bring together diverse disciplines, stakeholders, and the Forest Service management team to develop 

projects that conserve forests and the communities in and adjacent to the forest from catastrophic 

(standing-replacing) wildfires. The SFA process was used to develop modeling schemes for the Eddy 

Gulch LSR Project in order to mimic historic wildfire and weather. Once the weather data and the 

problem fire (see Section 2.5.2.1 below) scenario were well developed, the interdisciplinary team (ID 

team) was able to see what effects a wildfire would have on the Eddy Gulch LSR and the protection 

targets. During citizen collaboration meetings, the fire behavior modeling gave the public an 

opportunity to comment on where they felt treatments should be applied. The modeling also showed 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

2-4 Chapter 2: Proposed Action and Alternatives

the ID team where a wildfire would likely affect the LSR. This information assisted with development 

of the Proposed Action. 

The ID team then looked at logical locations and types of treatments that could be implemented in 

the Eddy Gulch LSR Project Assessment Area. The prescriptions for these treatments were again 

tested with the problem fire to provide the ID team with an idea of how effective the treatments 

would be in reducing wildfire losses. The SFA for the Eddy Gulch LSR Project is on the project 

website (http://www.eddylsrproject.com). 

The Problem Fire. Another goal of the SFA was to identify the problem fire. The problem fire is 

not a single modeled wildfire but rather a combination of attributes that include historic weather, 

historic large fire behavior and conditions, existing fuels and topography, historic ignitions that would 

contribute to fire spread and severity of wildfires, historic response capability (suppression), and 

Geographic Area Command priority. To identify the problem fire, the SFA process required the use 

of fire behavior models (FARSITE, FLAMMAP), a weather and fire history analysis tool 

(FIREFAMLY Plus), and ArcGIS, a Geographic Information System (GIS) software. The problem 

fire identified the potential fire behavior in the Eddy Gulch LSR landscape and how fire would affect 

vegetation and private property. This modeling, and extensive fire experience of the modeler, also 

provided the ID team with the opportunity to test proposed vegetation treatment prescriptions against 

the problem fire in order to analyze treatment effectiveness in reducing wildfire effects and potential 

resource losses. 

2.5.1.2 U.S. Fish and Wildlife Priority Protection Areas 

The USFWS in Yreka, California, identified four priority protection areas (Map A-3). These areas 

contain either large blocks of high-quality NSO habitat, provide for small NSO population clusters in 

the Eddy Gulch LSR, or are important for connectivity at a larger scale. Two of the areas (FWS-2 and 

FWS-4 on Map A-3) are entirely within the Eddy Gulch LSR Project Assessment Area and would 

benefit from treatments to protect these areas from wildfire. The majority of one other area (FWS-1) 

lies in designated roadless areas (which are excluded from the Eddy Gulch LSR Project), but the 

small portion of it that does lie within the Eddy Gulch LSR Project Assessment Area would benefit 

from the proposed treatments. The fourth area (FWS-3) lies completely within designated roadless 

areas and is not close enough to any proposed treatment unit to benefit from treatments identified in 

the Proposed Action. 

2.5.1.3 Salmon River CWPP 

The CWPP (SRFSC 2007) identifies community and individual water sources (watersheds and 

intake structures) for which water quality, and the structures themselves, could be degraded by 

wildfire. Two communities, Cecilville (south of the Assessment Area) and Sawyers Bar (north of the 

Assessment Area), were listed in the Federal Register (2001) as communities at risk from a wildfire. 

These communities and related infrastructure could be adversely affected by a fire starting outside the 

Eddy Gulch LSR or emanating from the LSR. 

The Salmon River CWPP, dated October 30, 2007, identified the following five types of 

protection areas (these are identified on Map A-2 in Appendix A). 

 0.25-mile buffers—public property surrounded by private property (CWPP page 30). 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 2: Proposed Action and Alternatives 2-5

 Municipal watersheds—Eddy Gulch, Black Bear Ranch property (Argus and Callahan 

gulches), Cecilville (Crawford Creek), Whites Gulch, Counts Gulch, Rainbow property 

(Music Creek). 

 Property buffers—these are 200-foot buffers on public property surrounding private 

properties. 

 Special areas—areas below upslope private properties that are located high on slopes, as 

well as culturally or biologically significant areas (CWPP page 30) that are at risk from fire 

spreading up toward the property. 

 Emergency access routes—200 feet above and below the road; prescription policy 

number 3 (CWPP page 30). 

2.5.1.4 Black Bear Ranch Cooperative Fire Safe Plan 

The Black Bear Ranch Cooperative Fire Safe Plan (SRFSC 2002) states that the “Black Bear 

Ranch property is at high risk of being burned over in a wildfire. The houses lie at the bottom of the 

upper half of the watershed. This slope position is considered a high risk in terms of fire behavior. 

Access would be particularly threatened in the case of a fire coming from above.” 

2.5.1.5 Rainbow Cooperative Fire Safe Plan 

The Rainbow Cooperative Fire Safe Plan (SRFSC 2003) states that the Rainbow property is at 

“high risk of being burned over in a wildfire. The houses are near the top of the ridge with much fuel 

below. Access and egress would be particularly threatened in the case of a fire coming from below.” 

2.5.2 Developing of the Proposed Action 

The ID team identified 25,969 acres of landscape-level treatments to protect late-successional 

habitat and communities. Three primary treatment types were identified in the Assessment Area: Fuel 

Reduction Zones (FRZs), Prescribed Burn Units (Rx Units), and Roadside (RS) treatments along 

emergency access routes—these are described below. 

 FRZs—strategically located on ridgetops to increase resistance to the spread of wildfires to 

adjacent watersheds. The FRZs would be wide enough to capture most short-range spot 

fires, and ground, ladder, and crown fuels would be reduced so as to change crown fires to 

surface fires within the treated areas. The FRZs would provide safe locations for firesuppression personnel to conduct fire-suppression actions during 90th percentile weather 

conditions, and they would serve as anchor points for additional landscape-level fuel 

treatments, such as underburning. 

– Proposed Action. Construct 16 FRZs totaling 8,291 acres to increase resistance to 

wildfires. The 8,291 acres include 931 acres in 42 M Units (thinning units) and 

7,383 acres in fuel reduction areas (outside the M Units) to reduce ground and ladder 

fuels. 

 Rx Units—a series of landscape-level treatments (ranging from 250 to 4,300 acres in size) 

designed to increase resilience to wildfires by reducing ground and ladder fuels. Most of 

these treatments would occur on south-facing aspects where fuels dry faster, and treatments 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

2-6 Chapter 2: Proposed Action and Alternatives

would support the role of the FRZs. The Rx Units were designed and located in areas 

containing USFWS priority protection areas, which include clusters of NSO Activity 

Centers or are important to maintain connectivity in the LSR. 

– Proposed Action. Implement 17,524 acres of Rx Units to increase resiliency to 

wildfires and protect habitat for the NSO and other wildlife species that are dependent 

on late-successional forests. 

 RS treatments—along 60 miles of emergency access routes identified in the Salmon River 

CWPP and designed to facilitate emergency access for residents to evacuate and for 

suppression forces to safely enter the LSR in the event of a wildfire. 

– Proposed Action. Treat 44 miles of emergency access routes in FRZs and Rx Units 

(treatments would be similar to the FRZ or Rx Unit the route passes through) and 

16 miles (approximately 154 acres) of RS treatments outside of FRZs and Rx Units—

a total of 60 miles of RS treatments along emergency access routes. 

Additional descriptions of the treatments are provided below. Where land use objectives (LSR, 

Riparian Reserves, and WUI areas) overlap, treatments were designed to meet each objective to the 

fullest extent possible. 

2.5.2.1 Fuel Reduction Zones 

The ID team selected the locations of FRZs based on SFA modeling results and considered the 

following questions when determining the most effective locations for constructing the FRZs: 

 Based on FLAMMAP and FARSITE fire behavior modeling and data on past fire history, 

where are the areas with the greatest likelihood of high-intensity fire? 

 How could the Eddy Gulch LSR be protected from fires originating outside the LSR? 

 What areas have the highest number of protection targets, such as WUI areas, evacuation 

routes, watersheds, important infrastructure (such as repeater sites, Eddy Gulch Lookout), 

NSO habitat, and USFWS priority protection areas? 

 What high-elevation ridges (above the inversion layer—about 4,800 feet) would serve as 

the best locations for prohibiting wildfire from spreading into an adjacent watershed? 

 What ridges have prominent geographical features that could serve as natural barriers for 

fire spread? 

 Are there access points (roads) to the ridges for implementing treatments within an FRZ? 

 What locations would provide the greatest potential for continuity of treatments within an 

FRZ and the potential to create continuity to the other proposed FRZs? 

 How could habitat in the inventoried roadless areas be protected? 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 2: Proposed Action and Alternatives 2-7

Sixteen FRZs, totaling 8,291 acres, would be constructed (see Maps A-4a and A-4b). The FRZs 

have two components: 

 M Units—thinning treatments in conifer and hardwood stands where crown, ladder, and 

ground fuels would be reduced; and 

 Fuel reduction areas—outside M Units, where ground and ladder fuels would be reduced. 

Table 2-1 summarizes the purpose of each FRZ and size of each component in an FRZ. Where 

emergency access routes pass through FRZs, the treatment would be the same as that component of 

the FRZ. All hazard trees along emergency access routes will be identified and removed according to 

the Klamath National Forest Hazard Tree Policy—Safety Provisions on National Forest System 

Roads (USFS 2005). 

The construction of the FRZs would generally be consistent with “Activity Design Criterion 9: 

Shaded Fuelbreak,” as described in the forestwide LSR assessment (USFS 1999). The exception to 

Criterion 9 is that forest canopy cover may be less than 40 percent in FRZs. 

M Units in Fuel Reduction Zones. Forty-two M Units, totaling 931 acres, would be treated in 

the FRZs consistent with the range of natural variation (see Tables 2-1 and 2-2 and Maps A-4a and 

A-4b). A “Designation by Description” prescription with variable spacing would be used to retain the 

largest trees generally within 14–28 feet of the next adjacent largest conifer tree. Tree removal would 

thin from below, removing trees 8–28 inches diameter at breast height (dbh). No trees larger than 

20 inches dbh would be removed in M Unit 8, M Unit 24, M Unit 31, and M Unit 43 to retain large 

trees in NSO habitat. Additional emphasis would be given to retaining desired conifer species and all 

hardwoods. Post-treatment canopy cover would range from 32 to 50 percent (Table 2-3). Snags and 

coarse woody debris would be reduced, where needed, to ensure firefighter safety; however, Klamath 

LRMP Standards and Guidelines would be achieved on a landscape level. Tractor yarding would 

occur on 361 acres and cable yarding on 570 acres. Following completion of thinning, all slash in 

tractor units would be grapple piled and burned, and all slash in cable units would be lopped and 

scattered and broadcast burned. Slash and other ground fuels would be removed to achieve posttreatment flame lengths of less than 2 feet, with fuel loads maintained to achieve flame lengths of less 

than 4 feet over time. Crown base heights would be 8–15 feet to minimize crown fires. 

Fuel Reduction Areas in Fuel Reduction Zones. The “fuel reduction areas” in FRZs are areas 

outside of M Units and total 7,383 acres. Ground and ladder fuels (conifer trees up to 10 inches dbh) 

would be masticated on 3,184 acres on slopes less than 45 percent. Prescribed burning would result in 

some mortality of intermediate, dominant, and codominant trees. Mortality would be highest in the 

smaller intermediate trees, and total mortality would not exceed 10 percent in a burn block. Most 

mortality would occur to individual trees scattered throughout the entire burn area; however, small 

openings may also occur where groups of 3 to 5 trees could be killed when high concentrations of 

surface fuels occur. Mortality would be lower in mid-successional and late-successional stands where 

trees are larger, the bark is thicker, and the branches are higher on trees. Following prescribed 

burning, the treated area would resemble conditions of an historic fire regime; that is, a mosaic of 

vegetation, consisting of large areas of mid- and late-successional forest, interspersed with more open 

conifer stands mixed with hardwoods or younger stands created by disturbances. The sum of all 

openings in a burn unit would not exceed 10 percent of any unit. Post-treatment flame lengths would 

be less than 2 feet, with fuel loads maintained to achieve flame lengths of less than 4 feet over time. 

Crown base heights would be 8–15 feet to minimize crown fires. 
2-8 Chapter 2: Proposed Action and Alternatives Table 2-1. Proposed mechanical and prescribed burn treatment acres in FRZs. FRZ Total Acres Treated Plantationa (Acres) Riparian Reservesa (Acres) Emergency Access Routea (Miles) 1. Purpose of FRZ 2. Road(s) This FRZ Would Protect 3. Municipal Watershed(s) This FRZ Would Protect Total acres treated: 947 

 M Unit: 26  Mastication: 645 

2 

 Prescribed Burn: 302 

136 102 2.2 

1. Protects Black Bear Ranch, infrastructure, and Blue R

crown fire behavior west of Blue Ridge LO 

2. Road 39, County Road 1E001 into Black Bear Ranch 3. Eddy Gulch and Black Bear Municipal Watersheds 

Total acres treated: 704 

 M Unit: 93  Mastication: 277 

3 

 Prescribed Burn: 427 

43 34 4.4 

1. Protects Blue Ridge LO, extends the FRZ to the sout

Ranch; maintains/improves existing treatments 

2. Road 39, National Forest System (NFS) Road 39N23 3. Eddy Gulch and Callahan Municipal Watersheds 

Total acres treated: 326

 M Unit: 46  Mastication: 142 

4 

 Prescribed Burn: 184 

123 17 0.4 

1. Protects Bacon Rind area; uses a strategic ridge 2. NFS Road 39N23 3. Isolates Callahan and Murphy drainages / Callahan M

Total acres treated: 540

 M Unit: 94  Mastication: 185 

5 

 Prescribed Burn: 355 

60 43 0.5 

1. Important—links FRZs on west perimeter with west to 

there is potential active crown fire behavior on either 

2. NFS Road 39N23 3. Callahan and Crawford Municipal Watersheds 

Total acres treated: 575 

 M Unit: 40  Mastication: 268 

6 

 Prescribed Burn: 307 

214 49 2.1 

1. Part of longest connected segments of FRZs, from a

west-east FRZs along Road 39; protects Crawford C

2. NFS Road 39N23 3. Callahan and Crawford Municipal Watersheds 

Total acres treated: 723

 M Unit: 0  Mastication: 238 

7 

 Prescribed Burn: 485 

33 42 0 

1. FRZ segment connects FRZs between Cecilville and 

east along Road 39; protects Cecilville 

2. County road from Cecilville to Forks of Salmon 3. — 
Table 2-1. Proposed mechanical and prescribed burn treatment acres in FRZs (continued). 

Chapter 2: Proposed Action and Alternatives 2-9 FRZ Total Acres Treated Plantationa (Acres) Riparian Reservesa (Acres) Emergency Access Routea (Miles) 1. Purpose of FRZ 2. Road(s) This FRZ Would Protect 3. Municipal Watershed(s) This FRZ Would Protect Total acres treated: 449

 M Unit: 35  Mastication: 132 

9 

 Prescribed Burn: 317 

98 38 0 

1. Isolates large area of potential crown fire behavior in 2. NFS Roads 39N56 and 39N23 3. Crawford Municipal Watershed 

Total acres treated: 384

 M Unit: 19  Mastication: 179 

10 

 Prescribed Burn: 205 

9 12 0 

1. Isolates large area of potential crown fire behavior in 2. — 3. Crawford Municipal Watershed 

Total acres treated: 334

 M Unit: 58  Mastication: 101 

11 

 Prescribed Burn: 233 

42 21 0 

1. Isolates large area of potential crown fire behavior in 2. Road 39, NFS Road 39N20 3. Crawford Municipal Watershed 

Total acres treated: 447

 M Unit: 204  Mastication: 193 

12 

 Prescribed Burn: 254 

43 16 3.0 

1. FRZ located at head of East Crawford Creek, with hig

active and passive crown fire behavior; protects Eddy 

2. Road 39 3. Eddy Gulch and Counts Gulch Municipal Watersheds 

Total acres treated: 694

 M Unit: 69  Mastication: 287 

13 

 Prescribed Burn: 407 

105 38 2.0 

1. Extends FRZ along Road 39, isolates East Shadow C

Inventoried Roadless Area and FWS priority protectio

2. Road 39, NFS Road 40N61 3. — 

Total acres treated: 254

 M Unit: 112  Mastication: 103 

14 

 Prescribed Burn: 151 

62 5 1.0 

1. Forms east boundary of FRZ system, protects Russia

and FWS priority protection area # 4 from large area behavior in East Shadow Creek 

2. Road 39 3. — 

Total acres treated: 317

 M Unit: 7  Mastication: 56 

15 

 Prescribed Burn: 261 

5 111 0.4 

1. Continuation of Grasshopper Ridge FRZ system, link

area of potential crown fire behavior 

2. Callahan to Cecilville County Road, Road 39 3. Shadow Creek in East Shadow Creek 
Table 2-1. Proposed mechanical and prescribed burn treatment acres in FRZs (continued). 

2-10 Chapter 2: Proposed Action and Alternatives FRZ Total Acres Treated Plantationa (Acres) Riparian Reservesa (Acres) Emergency Access Routea (Miles) 1. Purpose of FRZ 2. Road(s) This FRZ Would Protect 3. Municipal Watershed(s) This FRZ Would Protect Total acres treated: 314 

 M Unit: 108  Mastication: 102 

16 

 Prescribed Burn: 212 

53 53 0 

1. Forms link that encloses East Shadow Creek at Gras

area of potential crown fire behavior, safe access rouEddy Gulch LO 

2. — 3. Shadow Creek 

Total acres treated: 283

 M Unit: 0  Mastication: 145 

17 

 Prescribed Burn: 138 

61 38 0 

1. First of two segments that separate Whites Gulch an

protection to emergency egress-ingress routes 

2. NFS Road 39N59 3. Eddy Gulch Municipal Watershed 

Total acres treated: 1,000

 M Unit: 20  Mastication: 131 

20 

 Prescribed Burn: 869 

95 279 5.1 

1. Reduces hazardous fuels on steep western aspect a

egress route along county road, protects Rainbow Ra

Wilderness 

2. County Road 1C01 from Etna Summit to Idlewild, NF3. Music Creek Municipal Watershed 

Total FRZ Acres Treated: 8,291 M Unit Acres: 931 Mastication Acres: 3,184 Prescribed Burn Acres: 5,107b

1,182 898 21.1 

Notes: a. Plantation, Riparian Reserve, and emergency access route treatments are included in “Prescribed Burn” acres in column 2. b. The “Prescribed Burn Acres” include priority fire treatments in FRZs and secondary treatments in M Units. 
Chapter 2: Proposed Action and Alternatives 2-11 Table 2-2. Proposed thinning treatments for habitat and community protection. Stand Cable Tractor Construct New Temporary Roads Former L

Access 

M Unit FRZ Compartment Number Stand Number Forest Typea CWHR Seral Stageb Acres Fe

3 6 438 751 DF MS 7 2 5 4 6 438 752 DF MS 33 15 18 7(N) 9 438 773 DF MS 14 4 10 7(S) 9 438 755 DF MS 19 11 8 8 5 438 756 WF MS 5 5 0 2,19 4 431 502 DF MS 29 15 14 1,110 5 438 757 WF MS 32 0 32 11 5 438 758 WF MS 3 0 3 12 3 431 509 DF MS/LS 22 14 8 13 3 433 303 WF MS/LS 32 2 30 15a&b 437 701 WF MS/LS 15c 12 437 701 WF MS 138 52 86 1,577 1,316 12 437 702 WF MS/LS 4 4 0 17 11 437 703 WF MS/LS 12 12 0 550 19 11 437 705 DF MS/LS 46 46 0 20 12 437 706 WF MS 13 0 13 21 16 437 707 DF MS 108 47 61 1,074 22 15 439 801 DF MS 7 2 5 23 14 439 802 WF MS/LS 42 42 0 24 14 439 803 WF MS/LS 45 45 0 605 25 13 439 804 WF MS 27 23 4 530 2 430 553 WF MS 9 9 0 31 20 416 351 WF MS/LS 20 20 0 32 2 430 552 DF MS/LS 5 0 5 35 13 439 805 WF MS 4 4 0 36 13 439 806 WF MS 21 21 0 617 37 12 437 708 WF MS 12 12 0 560 38 5 437 709 WF MS 12 12 0 39 5 438 759 DF MS 14 14 0 40 5 438 760 WF MS 7 7 0 
Table 2-2. Proposed thinning treatments for habitat and community protection (continued). 

2-12 Chapter 2: Proposed Action and Alternatives Stand Cable Tractor Construct New Temporary Roads Former L

Access 

M Unit FRZ Compartment Number Stand Number Forest Typea CWHR Seral Stageb Acres Fe

43 5 438 762 MC LS 12 6 6 51 2 430 554 DF MS 12 12 0 52 10 437 710 DF MS/LS 19 19 0 54 12 437 712 WF MS 37 0 37 60 13 439 807 RF LS 17 17 0 61 14 439 808 WF MS/LS 25 25 0 65 5 438 764 DF MS/LS 6 6 0 66 9 438 765 DF MS 2 2 0 73 3 433 306 WF MS/LS 26 26 0 75 4 431 505 DF MS 9 6 3 450 76 4 431 506 DF MS 8 8 0 79 3 433 307 WF MS 13 0 13 80 5 438 772 WF MS 3 3 0 Totals 931 570 361 5,433 5,1

Notes: a. DF = Douglas-fir MC = Mixed-conifer RF = Red fir WF = White fir. b. MS = Mid-successional LS = Late-successional. c. The 240 feet is the total of four 60-foot spurs. d. The 100 feet is for one spur.
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 2: Proposed Action and Alternatives 2-13

Table 2-3. General thinning prescriptions (for trees larger than 8 inches dbh) at five years post 

treatment. 

Type 

(Seral Stage) 

Basal Areaa

(square feet per acre) 

Stand Density 

Indexb

Approximate Tree 

Spacing 

(feet) 

Canopy Cover 

(percent) 

Douglas-fir (MS)c 140 198 25 48 

Douglas-fir (LS) 198 251 28 50 

White fir (MS) 201 273 23 37 

White fir (LS) 208 257 29 38 

Red fir (LS) 235 284 29 32 

Mixed-conifer (LS) 206 260 28 50 

Notes: 

a. Basal area—the combined area of the cross sections of tree boles at a height of 4.5 feet above the ground, generally given 

as square feet per acre. 

b. Stand Density Index—a measure of the density of a stand of trees based on the number of trees per unit area and dbh of the 

tree of average basal area. 

c. MS = mid-successional (dominant and codominant trees generally 14–18 inches dbh). 

 LS = late-successional (dominant and codominant trees generally larger than 18 inches dbh). 

Plantations would be thinned to a 20-foot by 20-foot spacing, using mastication on slopes less 

than 45 percent. On slopes greater than 45 percent, plantations would be prescribed burned, except in 

eight strategic plantations in five FRZs where hand thinning, pruning (maintaining 60 percent canopy 

cover), and pile and burn would be necessary to maintain the integrity of the FRZs. Those treatments 

would occur on 56 acres in FRZ 2, 17 acres in FRZ 3, 28 acres in FRZ 5, 49 acres in FRZ 9, and 

9 acres in FRZ 14. 

Proposed Temporary Roads and Landings. The construction of new temporary roads and the 

use of former logging access routes are proposed to access treatment units. 

 Approximately 1.03 miles (5,433 feet) of new temporary roads would be used to access all 

or portions of seven M Units. These roads are described as “New temporary road” in 

Table 2-4. All of these temporary roads would be closed (ripped and mulched, as needed) 

following thinning. 

Table 2-4. Proposed new temporary roads, former logging access route updates, and short spurs. 

Location 

Length 

(feet) Access for M Unit Description 

Intersection 39N53 1,577 M Unit 15 (Cable) New temporary road 

Intersection 39N20 550 M Unit 17 New temporary road 

Intersection 39N73 1,074 M Unit 21 (Cable) New temporary road 

Intersection FS39 605 M Unit 24 New temporary road 

Intersection 39N58B 617 M Unit 36 New temporary road 

Intersection 39N53A 560 M Unit 37 New temporary road 

Intersection 39N37A 450 M Unit 75 New temporary road 

Intersection 39N23 1,123 M Unit 9 Former logging access route 

Intersection 39N53 1,381 M Unit 15 (Tractor) Former logging access route 

Intersection 39N58 519 M Unit 25 Former logging access route 

Intersection 39N04 – Lafayette Pt. 2,154 M Units 43 and 8 Former logging access route 

Intersection FS39A 240 M Unit 23 Four logging spurs at 60 feet each–operations 

Intersection 39N04A 100 M Unit 39 Short logging spur–operations 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

2-14 Chapter 2: Proposed Action and Alternatives

 Approximately 0.98 mile (5,177 feet) of former logging access routes would be reopened (vegetation removed and bladed) to access all or portions of five M Units. These 

routes, described as “Former logging access route” in Table 2-4, would be water-barred 

and closed immediately after thinning is completed. 

 Five short spurs, each less than 100 feet long, would be bladed for tractor or cable 

yarding operations in two units. 

 Existing landings will be used. The ID team considered using whole-tree yarding to 

reduce slash treatments, but it would require larger landings and additional clearing and 

was therefore not considered further. 

 Existing skid trails will be used. There may be short sections of skid trails that could be 

over 35 percent slope and that use the scarps (the steeper slope) to connect one flat bench 

to another flat bench. Please refer to the Soil RPMs in Section 2.9.4 below. 

Proposed Haul Roads and Drafting Sites

Haul Roads—There are five basic routes that would be used to haul products out of the 

Assessment Area following thinning; all of these routes have been used in the past and are suitable for 

use with this project: 

 2E001 (Sawyers Bar). The route connects to County Road 1C01 with haul to Etna 

and Highway 3 to Yreka. 

 40N61 (Whites Gulch Road). The route connects to County Road 1C01 with haul 

to Etna and Highway 3 to Yreka. 

 FS39. The route connects with County Road 1C02 with haul to Callahan 

and Highway 3 to Yreka. 

 39N20. The route connects with County Road 1C02 at Shadow Creek with haul 

to Callahan and Highway 3 to Yreka. 

 39N23. The route connects with County Road 1C02 at Cecilville with haul to Callahan 

and Highway 3 to Yreka. 

Drafting Sites—Roads will be watered to reduce dust during hauling. Water drafting sites for 

dust abatement will occur at designated sites for that purpose—existing drafting sites and access 

routes will be used. No vegetation removal will be allowed at drafting sites with the exception of 

vegetation trimming done in such a way that existing vegetation and associated root strength along 

stream banks and access routes are maintained. Maps A-4a and A-4b show the locations of the 

proposed drafting sites (labeled as “Proposed Water Fill Locations” on the maps). 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 2: Proposed Action and Alternatives 2-15

2.5.2.2 Rx Units 

The ID team considered the following questions when designing the Rx Units: 

 Based on FLAMMAP and FARSITE fire behavior modeling using 90th percentile weather 

conditions, would construction of FRZs alone accomplish the two project objectives? (See 

Section 2.1 above.) 

 How could the Eddy Gulch LSR best be protected from fires originating from outside the 

LSR? 

 How could the Eddy Gulch LSR best be protected from fires originating inside the LSR? 

 Could late-successional characteristics and habitats be protected using treatments limited to 

ridgetops and buffers around property infrastructures and roads? 

 How could fuel treatments best be accomplished on steep inaccessible ground with 

minimal effects on natural resources? 

There are 11 proposed Rx Units (Table 2-5 and shown on Maps A-4a and A-4b) totaling 

17,524 acres, to increase resiliency to wildfires and protect habitat for the NSO and other wildlife 

species that are dependent on late-successional forests. The units range in size from approximately 

250 to 4,300 acres and would be generally located between the FRZs. Most of the Rx Unit treatments 

would occur on south-facing aspects where fuels dry faster, and treatments would support the role of 

the FRZs. The Rx Units were designed and located in areas containing the USFWS priority protection 

areas, which include clusters of NSO Activity Centers or are important to maintain connectivity in the 

LSR. The treatments would be consistent with “Activity Design Criterion 8: Hazard Reduction–

Prescribed Burning,” as described in the forestwide LSR assessment (USFS 1999). 

Broadcast burning, ignited by hand or with “ping pong” balls from a helicopter, would be used to 

remove ground and small ladder fuels (less than 4 inches dbh) and to achieve post-treatment flame 

lengths of less than 2 feet, with fuel loads maintained to achieve flame lengths of less than 4 feet over 

time. Implementation of prescribed burns would not be consistent across each Rx Unit, but rather 

small patches of heavier fuels would be maintained in burn areas, mimicking the range of natural 

variation that was created by the pre-European settlement fire regime. That historic fire regime 

produced a mosaic of vegetation, consisting of large areas of mid- and late-successional forest, 

interspersed with more open conifer stands mixed with hardwoods or younger stands created by 

disturbances. The prescribed burning would result in some mortality of intermediate, dominant, and 

codominant trees. Mortality would be highest in the smaller intermediate trees, and total mortality 

would not exceed 10 percent in a burn block. Most mortality would occur to individual trees scattered 

throughout the entire burn area; however, small openings may also occur where groups of 3 to 5 trees 

could be killed when high concentrations of surface fuels occur. Mortality would be lower in midsuccessional and late-successional stands where trees are larger, the bark is thicker, and the branches 

are higher on trees. The sum of all openings in a burn unit would not exceed 10 percent of any unit. 

Snags and coarse woody debris densities would be consistent with Standards and Guidelines 

contained in the Klamath LRMP. Roads, topographic features, and hand-cut control lines would 

control prescribed fire size. Existing landings would be used if burning is ignited from a helicopter. 

Burns may be accomplished when air quality, weather, and fuel moisture conditions could be met. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

2-16 Chapter 2: Proposed Action and Alternatives

Table 2-5. Proposed Rx Units. 

Treatment Location 

Rx 

Unita, b Total 

Acres 

Plantationsc

(Acres) 

Riparian 

Reservesc

(Acres) 

Along 

Emergency 

Access Routes 

(Miles) 

1. Emergency Access Route(s) That 

Would Be Protected 

2. Municipal Watershed(s) That Would 

Be Protected 

3. Owl Activity Center(s) That Would 

Be Protected 

1 1,301 17 508 3.6 

1. FS39, 39N23, 1E001 

2. 650 acres–Black Bear Ranch Watershed 

158 acres–Black Bear Ranch 

3. KL1035 

2 1,972 98 514 3.2 

1. 39N23 

2. 1,946 acres–Callahan 

3. KL1033 

3 2,833 140 843 0 

1. — 

2. — 

3. KL1014 

4 4,339 393 1,546 3.0 

1. 39N23, 39N23.15 

2. 4,338 acres–Crawford Creek 

3. KL1032, KL1031, KL1012 

5 1,608 78 595 0 

1. — 

2. — 

3. — 

6 1,459 22 564 0 

1. — 

2. — 

3. KL1028 

7 1,130 221 220 8.1 

1. FS39, 1C02 

2. — 

3. KL4026 

8 863 35 290 1.6 

1. 40N54, 40N54.4 

2. — 

3. — 

9 1,247 46 351 1.4 

1. 1C01, 41N18, 41N18.1 

2. — 

3. KL1046 

11 251 97 46 0.7 

1. 39N23 

2. — 

3. — 

12 521 43 203 1.0 

1. FS39, 39N60 

2. 317 acres–Eddy Gulch 

3. KL1034 

Totals 17,524 1,190 5,680 22.6 

Notes: 

a. Other activities in Rx Units may include prescribed underburns and fireline construction, including handline and machineconstructed fireline. 

b. Rx Unit 10 is now part of FRZ 20. 

c. Plantation and Riparian Reserve acres are included in “Total Acres” in column 2. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 2: Proposed Action and Alternatives 2-17

2.5.2.3 Roadside Treatments Along Emergency Access Routes 

The ID team considered the following questions when determining what roads should be treated: 

 Do all RS treatments for the Eddy Gulch LSR Project include roads identified in the 

Salmon River CWPP and conform to the RS treatment standards recommended in the 

CWPP? 

 Are there other roads in the Assessment Area that need fuel treatments to protect health and 

safety of firefighters and the public? (These roads include open National Forest System 

(NFS) roads and Siskiyou County roads necessary for safe ingress and egress.) 

 What locations along the CWPP-identified roads do fire behavior modeling and fire 

suppression experience show that flame lengths could span the roads, and where smoke 

from heavy fuels that buffer the roads could obscure visibility for extended periods? 

Treatments are proposed along 60 miles of emergency access routes; 44 of the 60 miles would 

receive the same treatment as the FRZ or Rx Unit the route passes through. The following are the RS 

treatments proposed along 16 miles (approximately 154 acres) of emergency access routes that do not 

pass through FRZs or Rx Units (see Map A-4c): 

 RS 1 treatments would consist of hand thin and pile burn of trees up to 6 inches dbh on 

slopes greater than 45 percent (43.1 acres). 

 RS 2 treatments would involve mastication to remove trees less than 10 inches dbh on 

slopes less than 45 percent (40.6 acres). 

 RS 3 treatments are in Riparian Reserves and would only consist of mastication, hand thin, 

and pile burn (69.5 acres). 

Generally, the RS treatments would occur along the following roads (see Map A-4c): 

 NFS Road 39 from County Road 1CO2 up to the northeast corner where it intersects the 

boundary of FRZ 15; 

 NFS Road 40N61 (Whites Gulch) from the intersection with Road 39 to the county road; 

and 

 the south side of NFS Road 40N54 from the intersection of the county road east to the 

intersection of 40N35. 

All hazard trees would be identified and removed in accordance with Klamath National Forest 

Hazard Tree Policy (USFS 2005). To maintain the canopy cover requirements listed in the Salmon 

River CWPP, only small fuels within 50 feet of the road would be removed. 

2.5.3 Designated Land Allocations and Critical Habitat 

Late-Successional Reserve 

All project activities would occur in the Eddy Gulch LSR. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

2-18 Chapter 2: Proposed Action and Alternatives

Riparian Reserves 

Small trees would be removed on approximately 6,578 acres of Riparian Reserves throughout the 

Assessment Area. A masticator would be used on slopes less than 45 percent and within 0.25 mile of a 

road on 875 acres of FRZs to remove trees less than 10 inches dbh. Hand thinning and pile burning 

would be used on 483 acres of slopes greater than 45 percent in FRZs, and low-intensity backing fires 

would be used on 5,107 acres in Rx Units to remove trees up to 6 inches dbh. The masticator would 

not exceed more than 6 pounds per square inch ground pressure. No treatments with mechanical 

equipment would occur within 30 feet of ephemeral, intermittent, or perennial streams. Equipment 

may cross dry ephemeral or intermittent streams in designated locations. 

Northern Spotted Owl Critical Habitat 

The project has been designed to minimize adverse effects and provide long-term beneficial 

effects on the primary constituent elements of NSO Critical Habitat (“the physical and biological 

features in the necessary and appropriate quantity and spatial arrangement essential to the 

conservation of the species” [50 CFR 17]). Silvicultural prescriptions focus on retaining primary 

constituent elements at the stand scale. For nesting and roosting habitat, the primary constituent 

elements include large (greater than 30 inches dbh) trees in stands with 60–90 percent canopy cover, 

multistoried canopy that allow birds to fly under the canopy, and with abundant large snags and 

coarse woody debris. In foraging habitat, tree height diversity, canopy closure, snag volume, and 

density of snags are important. 

Prescribed burning in suitable habitat would not result in canopy cover going below 60 percent in 

nesting/roosting and foraging habitat or change by more than 10 percent, if the pre-treatment crown 

closure is less than 60 percent, or 40 percent in dispersal habitat (this includes hardwood, 

subdominant, and dominant tree components above 15 feet in height). 

2.5.4 Implementation Sequence for the Proposed Action 

The following sequence of treatments would be used to implement the Eddy Gulch LSR Project: 

1. Complete FRZs (M Units and RS treatments) during the first four years. 

Construct FRZs in the following order: 

FRZs 2, 3, 12, 13 

FRZs 14, 15 

FRZs 4, 5, 6, 9 

FRZs 7, 10, 11 

FRZs 16, 17, 20 

2. Complete FRZs (mastication and prescribed burn) during the first six years following the 

order above. Some prescribed burning may occur in Rx Units adjacent to FRZs to establish 

control points. 

3. Complete Rx Units during the first 11 years. The approximate order would be: 

a. Northwest and western portion of Rx Unit 1 and Rx Unit 12 

b. Rx Unit 3 and Rx Unit 8 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 2: Proposed Action and Alternatives 2-19

c. East side Black Bear Ranch Road in Rx Unit 1 and Rx Unit 2 

d. West portion of Rx Unit 4 and Rx Unit 11 

e. East portion of Rx Unit 4 and Rx Unit 9 

f. Remainder of Rx Unit 1 and Rx Unit 5 

g. Rx Unit 6 and Rx Unit 7 

4. Within occupied or unsurveyed suitable habitat, no more than 50 percent of the nesting, 

roosting, or foraging habitat would be burned or mechanically treated in a single year in 

any one 7th-field watershed up to 3,500 acres in size. If the 7th-field watershed is more 

than 3,500 acres, apply the design criteria at the 8th-field watershed scale or in some other 

manner that meets the intent of the design feature. 

2.6 Alternative C: No New Temporary Roads Constructed_______ 

Alternative C responds to public concerns regarding the environmental and economic effects of 

constructing new temporary roads. Alternative C is similar to the Proposed Action but approximately 

1.03 miles (5,443 feet) of new temporary roads identified in the Proposed Action would not be 

constructed. As a result, no fuels treatments would occur in portions of seven M Units (see 

Table 2-6). This reduces the total acres of treatments in M Units from 931 under Alternative B to 832 

under Alternative C (a reduction of 99 acres). Fuels treatments could not be carried out in those 

M Units because of excessive treatment costs, high existing dead crown fuel loadings, and potential 

heat damage to the overstory if these untreated units were prescribed burned. Thus, approximately 

921 acres would still be susceptible to a crown fire. The inability to treat the 921 acres would result in 

vulnerable areas that could allow wildfires to escape to other areas of the LSR. 

Table 2-6. Changes in M Unit treatment acres between Alternatives B and C with the elimination 

of new temporary roads. 

Alternative B 

Acres of Treatment 

Alternative C 

Acres of Treatment 

M Unit FRZ 

Type 

(Seral Stage)*

New Temporary 

Roads Deleted 

(feet) Cable Acres

Tractor 

Acres Cable Acres 

Tractor 

Acres 

15a and b White fir (MS/LS) 

15c 

12 

White fir (MS) 1,577 52 86 26 86 

17 11 White fir (MS/LS) 550 12 0 7 0 

21 16 Douglas-fir (MS) 1,074 47 61 26 61 

24 14 White fir (MS/LS) 605 45 0 30 0 

36 13 White fir (MS) 617 21 0 7 0 

37 12 White fir (MS) 560 12 0 0 0 

75 4 Douglas-fir (MS) 450 6 3 0 3 

Totals 5,433 195 150 96 150 

Total = 345 Total = 246 

Note: *MS = Mid-successional. 

 LS = Late-successional. 

Under Alternative C, the FRZs would continue to total 8,291 acres; however, 99 acres in M Units 

would remain untreated. The total number of acres treated by tractor yarding would remain at 

361 acres; however, the acres of cable yarding would be reduced from 570 acres under Alternative B 

to 471 acres under Alternative C. Reducing acres of M Units treated would also reduce the number of 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

2-20 Chapter 2: Proposed Action and Alternatives

acres treated in Rx Units 5 and 6 because excessive fuels remaining in M Units would preclude safely 

burning portions of those Rx Units. Rx Unit 5 would be reduced by 26 percent (418 acres) because no 

treatment would occur in a portion of M Unit 17, and Rx Unit 6 would be reduced by 28 percent 

(404 acres) because no treatment would occur in a portion of M Unit 24 (see Maps A-6a and A-6b). 

Six-foot-wide control lines would be constructed around the perimeter of those untreated areas to 

keep prescribed burns out of those portions of Rx Units 5 and 6. There would be no changes in the 

miles of emergency access routes treated, transportation plan, or resource protection measures. 

2.7 Alternatives Considered but 

Eliminated from Detailed Study _________________________ 

NEPA requires federal agencies to rigorously explore and objectively evaluate all reasonable 

alternatives and to briefly discuss the reasons for eliminating any alternatives that were not developed 

in detail (40 CFR 1502.14). Public scoping comments yielded only one suggestion for an additional 

alternative—one that did not propose construction of temporary roads. That suggested alternative was 

carried forward for analysis as Alternative C. 

Helicopter logging was considered but eliminated from detailed study. Additional larger landings 

would have to be constructed; the small size of the material being removed, the cost of the equipment, 

and current log market significantly constrain the economics of the operation; and limited operating 

periods to reduce impacts on NSO significantly constrain the operating season; and the large number 

of NSO activity centers would adversely affect logistics of operating helicopters. 

2.8 Summary Comparison of Alternatives ___________________ 

Excessive fuel hazards in the Eddy Gulch LSR could result in a wildfire characterized by as much 

as 73 percent crown fire. This type of fire behavior would destroy late-successional habitat, 

communities, and municipal watersheds and could adversely affect emergency access routes. In 

response to this fire threat, fuel reduction treatments are needed for 

1. Habitat Protection—Protect existing and future late-successional habitat from threats of 

wildfire that occur inside and outside the Eddy Gulch LSR. 

2. Community Protection—Reduce wildfire threat to communities and municipal water 

supplies and ensure public and firefighter safety. 

Alternative A (No Action) would not meet the purpose and need because, without treatments, 

wildfire would threaten late-successional habitat, communities, and municipal watersheds and would 

not create conditions for safe evacuation along emergency access routes or access for suppression 

operations during a wildfire (Table 2-7). A wildfire would also generate large quantities of smoke and 

other emissions that could affect sensitive receptors in the LSR. 

Under Alternative B (Proposed Action), treatments on 25,815 acres would increase resistance and 

resilience of the treated areas to the adverse effects of a wildfire, which would reduce threats to 

50 percent of the NSO core areas in the LSR, treat 800 acres in the WUI, offer safe passage along 

60 miles of emergency access routes, and protect infrastructure. 
Chapter 2: Proposed Action and Alternatives 2-21

Table 2-7. Comparison of alternatives by project objectives, resource indicators, and effects on resources. 

Indicators 

(By Project Objective) 

Alternative A 

(No Action) 

Alternative B 

(Proposed Action) 

(N

R

Objective 1: Habitat Protection Protect existing and future late-successional habitat from threats of wildfire that occur inside and outside the Eddy Gulch LSR. 

Late-successional habitat would be threatened by wildfires 

Large portions of late-successional habitat would be protected from wildfires 

Fewer acrhabitat wowildfires 

 Acres that are (1) resistant to the spread of, or 

(2) resilient to the effects of a wildfire 

(1) 0 acres (2) 2,890 acres 

(1) 8,291 acres (2) 17,524 acres 

(1) 8,192 (2) 16,702 

 Percent of fire type (1) surface or (2) crown fire 

in the entire LSR 

(1) 27 percent (2) 73 percent 

(1) 77 percent (2) 23 percent 

(1) 75 pe(2) 25 pe

 Percent of NSO habitat in the LSR adversely 

affected by wildfire 

100 percent of NSO core areas 50 percent of NSO core areas 55 percen

 Conifer stands resemble historic range of 

conditions 

2,890 acres Treatments will move 25,815 acres 

of conifer stands in the direction of historic range of conditions 

Treatmentof conifer historic ra

Objective 2: Community ProtectionReduce wildfire threat to communities and municipal water supplies and ensure public and firefighter safety. 

Communities and municipal water supplies would be threatened by wildfires 

Treatments would reduce the threat from wildfires to communities and municipal water supplies 

Treatmentfrom wildfmunicipal 

 Acres of WUI treated 0 acres 800 acres 800 acres  Miles of emergency access routes treated 0 miles 60 miles 60 miles  Acres of FRZs (fuelbreaks) constructed 0 acres 8,291 acres 8,291 acre Important infrastructure protected None Repeater site, Eddy Gulch Lookout, 

campgrounds 

Campgrou

 Acres of municipal watersheds treated 0 acres 9,850 acres 9,850 acre Changes in emissions 29,300 tons of PM10, PM2.5, 

and carbon monoxide emitted from a wildfire 

80 percent reduction in emissions 80 percen
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

2-22 Chapter 2: Proposed Action and Alternatives

Under Alternative C (No New Temporary Roads Constructed [1.03 miles = 1.7 acres of 

disturbance]), treatments on 24,894 acres would increase resistance and resilience of the treated areas 

to the adverse effects of a wildfire. However, the inability to treat approximately 920 acres could 

increase the complexity and difficulty of suppression efforts and the number of acres burned by a 

stand-replacing crown fire. Treatments would reduce threats to 45 percent of the NSO core areas in 

the LSR, treat 800 acres in the WUI, offer safe passage along 60 miles of emergency access routes. 

However, the inability to treat all acres could result in a wildfire damaging important infrastructure, 

such as the Eddy Gulch Lookout and repeater site, which are necessary for fire detection and 

communication. Under both action alternatives, emissions from a wildfire would be reduced by 

80 percent in the treated areas, compared to Alternative A. 

Under both action alternatives, emissions from a wildfire would be reduced by 80 percent in the 

treated areas, compared to Alternative A. 

2.9 Resource Protection Measures _________________________ 

Resource protection measures (also known as mitigation measures) are designed to avoid or 

substantially reduce a project's significant adverse environmental effects. The following resource 

protection measures have been incorporated into Alternatives B and C. These measures are in 

addition to Standards and Guidelines contained in the Klamath LRMP and approved Best 

Management Practices (BMPs). 

2.9.1 Wildlife 

2.9.1.1 Northern Spotted Owls 

 No activities will occur between February 1 and September 15 within an active NSO 

70-acre nest core. 

 Noise-producing activities that are above ambient noise levels will not occur between 

February 1 and July 9 within 0.25 mile of an occupied activity center or unsurveyed 

suitable nesting/roosting habitat. 

 No activities that remove or downgrade suitable NSO habitat will occur between 

February 1 and September 15 within 0.5 mile of an occupied activity center or unsurveyed 

suitable nesting/roosting habitat. 

 Burning will not occur between February 1 and July 31 within 0.25 mile of an occupied 

activity center or unsurveyed suitable nesting/roosting habitat if the following conditions 

are met, seasonal restrictions may be waived: 

 A topographic feature buffers the activity center or unsurveyed suitable 

nesting/roosting habitat from smoke, or burning is conducted uphill of the known 

activity center or unsurveyed suitable nesting/roosting habitat. 

AND 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Chapter 2: Proposed Action and Alternatives 2-23

 Smoke is managed so that light to moderate dispersed smoke may be present within 

a canyon or drainage but dissipates or lifts within 24 hours. 

 Ignition will be discontinued if heavy, concentrated smoke begins to inundate the 

0.25-mile buffer late in the afternoon. 

 There will be no seasonal restrictions on burning or use of mechanized equipment if 

protocol surveys are current and negative. 

 As an option to full protocol surveys, burning or other activities that will not remove or 

downgrade suitable NSO habitat may occur in spring if three surveys are completed in the 

year-of-action implementation and meet the following standards: (1) the first and second 

surveys begin after March 1 and are separated by a minimum of five days; (2) the third 

survey occurs after April 15; and (3) no owls are detected. If an NSO is detected during any 

of the surveys, no burning may occur within 0.25 mile of the activity center between 

February 1 and July 31, and no activities that create noise above ambient levels may occur 

within 0.25 mile of the activity center between February 1 and July 9, unless surveys 

determine Non-Nesting status. To determine Non-Nesting status, two observations of the 

owl(s) are required during the nest survey period (April 1 to June 1). Observations must be 

at least three weeks apart, with the second observation occurring after April 15. 

 New temporary roads will be located to avoid trees larger than 20 inches dbh, where 

feasible. 

 No more than 50 percent of the suitable habitat within a home range will be treated 

(thinning, underburning, and other fuels treatments) in a given year. 

2.9.1.2 Northern Goshawk 

 A seasonal restriction of March 1 to August 31 will apply to all activities (including 

activities that degrade or are beneficial) that modify habitat within 0.5 mile, or create 

smoke or noise above ambient levels within 0.25 mile of historic sites or any additional 

nest sites that are discovered in the Assessment Area. 

 If protocol-level surveys indicate that an historic site is not occupied by breeding 

goshawks, seasonal restrictions may be waived. 

2.9.1.3 Peregrine Falcon 

 A seasonal restriction of February 1 to July 31 will apply to all activities that create noise 

above ambient levels within 0.25 to 0.5 mile (dependent on topographic features) of any 

active eyries that may be discovered in the Assessment Area. 

2.9.1.4 Bald Eagle 

 A seasonal restriction of January 1 to August 31 will apply to all activities that modify 

habitat within 0.5 mile, or that create smoke or noise above ambient levels within 0.25 mile 

of historic sites or any additional nest sites that are discovered in the Assessment Area. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

2-24 Chapter 2: Proposed Action and Alternatives

2.9.2 Fisheries 

2.9.2.1 Streamside Protection 

 Except where a masticator is used, fuel treatments on all units may occur within 30 feet of 

intermittent or perennial streams less than 1-foot wetted width. 

 Handpiling and pile burning may occur within 15–30 feet of intermittent or small perennial 

streams in areas where treatment units are not located on granitic soils, or where the 

sideslopes entering intermittent and small perennial channels do not exceed 35 percent, or 

where soil cover estimates within 15 feet of the intermittent or small perennial streams are 

greater than 50 percent. For perennial streams greater than 1-foot wetted width, handpiling 

with no burning may occur within 15–30 feet of the streambank. The guidelines for this to 

occur are as follows: 

 Demonstrate through a series of appropriately placed plots that estimated soil cover 

exceeds 50 percent within the adjacent 15-foot no-handpile buffer (15 feet adjacent to 

streambank); 

 Handpiles will be spread out and not be “stacked” above one another where, during 

burning, they could connect and affect a greater area than anticipated; or a linear area is 

developed that will increase the potential for erosion to occur; 

 Handpiles will be small in size—6 feet or less in diameter; and 

 Handline construction in riparian vegetation shall be avoided where practical. 

 Logs will be suspended when being yarded across channels. Skid trail crossings of 

localized, hydrologically disconnected ephemeral channels (no Riparian Reserves present) 

will be uncommon and in such cases require remedial shaping. 

2.9.2.2 Underburning 

 No more than 10 percent of a 6th-field watershed will be burned in any one year in order to 

minimize the potential for cumulative adverse effects when underburning. 

 Handlines in Riparian Reserves will be waterbarred and covered with organic material 

immediately following prescribed burning, when safe to do so. 

2.9.2.3 Mastication 

The following guidelines will apply when a masticator is used: 

 Soil moisture will be below 18 percent. 

 The track-mounted excavator will not operate within 50 feet of any perennial/intermittent 

stream less than 1-foot wetted width; however, the arm of the masticator may reach within 

this 50-foot buffer to treat competing vegetation (approximately a 30-foot reach). For 

perennial streams greater than 1-foot wetted width, a 100-foot buffer will be designated. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Chapter 2: Proposed Action and Alternatives 2-25

 The track-mounted excavator will not operate beyond break in slope of any inner gorge. 

 Dry intermittent streams may be crossed by the track-mounted excavator/masticator at 

designated sites only after field review and approval by district fisheries biologist and/or 

hydrologist. No perennial streams will be crossed. 

2.9.2.4 Water Drafting 

All project water drafting will follow National Oceanic and Atmospheric Administration 

(NOAA)-Fisheries Water Drafting Specifications (USDC NMFS 2001), including, but not limited to 

the following: 

 Drafting will not reduce the stream flow by more than 10 percent. 

 When water is drafted, intakes will be screened with 3/32-inch mesh (for rounded or square 

openings) or 1/16-inch mesh for slotted opening. 

 Pumping rate shall not exceed 350 gallons per minute or 10 percent of the stream flow. 

 Pumping will be terminated when the water tank is full. 

 Water drafting sites for dust abatement on roads will occur at designated sites for that 

purpose. Erosion-control measures will be employed on the access and/or main road to 

prevent water leakage from causing stream sedimentation. Hazardous material spill 

prevention and containment equipment will be present on water trucks. Water trucks and 

pumping equipment will be in a well-maintained condition, free of fluid leaks, and have 

hoses in good operating condition. 

2.9.2.5 Special Areas 

Refer to the Fish Biological Assessment / Biological Evaluation in the Eddy Gulch LSR project 

record for detailed information on “Areas With Watershed Concerns” and the cumulative watershed 

effects (CWE) analysis conducted for the project. Based on CWE assessments and field reviews, the 

proposed Eddy Gulch LSR Project treatment units were located and designed to avoid and protect 

sensitive areas in these watersheds to ensure cumulative effects do not result in adverse effects on 

Proposed (or Listed) anadromous fish or their habitat. The proposed treatments were designed to 

reduce the effects of wildfire but would not reduce CWEs due to existing main roads located in 

Riparian Reserves. 

2.9.2.6 Riparian Reserves 

 The Riparian Reserves have been mapped (Maps A-12a and A-12b). The Klamath LRMP 

defines standard slope distance for Riparian Reserves as two site-potential tree heights or 

300 feet for anadromous and resident fish-bearing streams (whichever is greater) and one 

site-potential tree height or 150 feet for nonfish-bearing streams (whichever is greater). 

This project defines one site-potential tree height as 170 feet on each side of a qualifying 

stream channel. Therefore, the Riparian Reserve width is 340 feet for fish-bearing streams 

and 170 feet on each side of an active stream channel for nonfish-bearing streams. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

2-26 Chapter 2: Proposed Action and Alternatives

 As a handline is being built into a draw, stop building the handline within 25 feet of the 

wetted edge of the channel to minimize disturbed soil adjacent to the stream. 

 Prescribed fire will be ignited in a manner that minimizes the potential for moderate- or 

high-intensity burns. 

 When underburning in Riparian Reserves, at least 90 percent of the large woody debris will 

not be consumed, both standing and on the ground. 

 All entry to waterways occupied by spawning anadromous fish or where eggs would be 

incubating, as determined and indicated by a fisheries biologist, is prohibited. Restricted 

time periods are generally from October 15 through June 15. Additional restrictions may be 

appropriate for waterways containing Spring Chinook Salmon and summer-run steelhead, 

as determined by the District Fisheries Biologist. (The focus is protection of spawning and 

incubating eggs.) 

 Where more than 80 percent shade exists, at least 80 percent shade on the water will be 

retained after treatment. 

 Larger conifers (greater than 20 inches dbh) felled within perennial stream channels or 

inner gorges, will be left. However, slash will be minimized in the stream channel. 

 BMPs and Wet Weather Operation Standards (USFS 2002) will be implemented during all 

activities. 

 No new landings will be constructed in Riparian Reserves. 

2.9.3 Water Resources 

 Implement BMPs. 

 Water drafting sites for dust abatement on roads will occur at designated sites for that 

purpose. Erosion-control measures will be employed on the access and/or main road to 

prevent water leakage from causing stream sedimentation. Hazardous material spill 

prevention and containment equipment will be present on water trucks. Water trucks and 

pumping equipment will be in a well-maintained condition, free of fluid leaks, and have 

hoses in good operating condition. 

 Refueling and maintenance of project motorized equipment, including helicopters, will 

occur at least 200 feet away from any channel (USFS 2003). 

 Mulch or slash any skid trails on slopes over 35 percent. Slash or certified straw will be 

placed on them to achieve a 70–80 percent soil cover. 

 The new temporary roads will be closed (hydrologically restored) at project completion. 

The temporary roads will be outsloped (as necessary), covered with slash (if needed), and 

blocked after use (prior to the first winter after use). Road closure includes obliteration 

(recontouring) of temporary road segments; removal of berms and fills, any constructed 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Chapter 2: Proposed Action and Alternatives 2-27

stream crossing (none anticipated), tillage or scarification of compacted areas, waterbars, 

and slash or mulch cover of disturbed areas to 70 percent. 

 Apply erosion control measures to the new temporary roads and former logging access 

routes that will be used during the project. 

2.9.4 Soils 

 Reuse existing skid trails and landings. 

 No new full-bench skid trails will be built. 

 Skid trail locations will be agreed to by the Forest Service. 

 Prevent road or landing runoff from entering skid trails. 

 Minimize soil erosion by water barring all skid trails. 

 Ground-based yarding equipment is restricted to slopes less than 35 percent; however, 

there may be short sections of skid trails that could be over 35 percent slope and could use 

the scarps (the steeper slope) to connect one flat bench to another flat bench. 

 Mulch or slash those short sections of skid trails on slopes over 35 percent. Slash or 

certified straw will be placed on them to achieve a 70–80 percent soil cover. 

 No more than 15 percent of any treatment unit should be disturbed by primary skid trails, 

cable corridors, and landings. 

 Conduct skidding operations during dry soil conditions (sufficiently dry to 10-inch depth) 

or follow wet weather logging guidelines. 

 Track-mounted masticators can operate up to 45 percent slopes when soil is dry down to 

10 inches or follow wet weather logging guidelines. 

 Deck logs on existing road prism versus constructing new landings. 

 Burn during spring-like conditions, in any season, to minimize the consumption of litter 

and coarse woody debris (down logs greater than 20-inch diameter). No direct firing on 

coarse woody debris. 

 Retain existing levels or a minimum of 5 logs/acre of coarse woody debris (down logs 

great than 20-inch diameter) for soil productivity needs. 

 Protect existing coarse woody debris by having ground-based equipment avoid the largerdiameter logs as much as practical. 

 Post-treatment total soil cover will be 70–80 percent, depending on slope steepness and soil 

texture. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

2-28 Chapter 2: Proposed Action and Alternatives

 Retain at least 50 percent soil cover as fine organic matter (less than 3-inch materials) in all 

treatment units. 

 M Units 15, 17, 21, 22, 30, and 80 will be monitored for detrimental disturbance and/or 

compaction and will be subsoiled if detrimental disturbance exceeds 15 percent in each 

unit. 

 Coordination. During implementation of this project, the project leader will coordinate with 

personnel from earth science and fire/fuels regarding protection of soils and unstable areas. 

2.9.5 Geology 

 Layout cable corridors to maximize log suspension and minimize surface disturbance to 

small areas of wet soil that occur in some thinning units. 

 Mulch or slash any skid trails on slopes over 35 percent. Slash or certified straw will be 

placed on them to achieve a 70–80 percent soil cover. 

 Use existing landings whenever available and design for stable cuts and fills to ensure that 

no sediment from landings is delivered to streamcourses. 

 Scatter slash to 80 percent ground cover on any wet areas disturbed by yarding. 

 Use all available tools in planning prescribed burning to avoid high-severity fire on active 

landslides and other unstable areas. This includes close coordination between fire and 

watershed personnel during field layout of burn units to identify unstable areas that are at 

risk of burning at high severity. 

 Maintain 60 percent tree canopy on units identified as having higher slope stability risk. 

 Close temporary roads. This includes removal of berms and fills, removal of any 

constructed stream crossing (none anticipated), tillage or scarification of compacted areas, 

waterbars, and slash or mulch cover of disturbed areas to 70 percent. 

 Asbestos. The Forest Service will provide a description of health hazards from asbestos 

exposure and maps to contractors identifying areas that may have asbestos and suggest they 

may consider sealed cabs on their equipment. If timber haul routes change during project 

implementation, any additional roads would be checked against the bedrock map to 

determine if they are underlain by ultramafic rock, and the asbestos standards applied. Dust 

abatement is required on all roads underlain by ultramafic rocks, and it is recommended 

that masticators have positive-pressure climate-controlled sealed cabs. 

 Coordination. Following award of the contract for this project, personnel from earth 

science, timber administration, and fire will coordinate details of implementation, including 

protection of unstable areas during logging and burning activities. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Chapter 2: Proposed Action and Alternatives 2-29

2.9.6 Botany 

2.9.6.1 Forest Service Sensitive Plants 

The measures required for Cypripedium fasciculatum (CYFA) and Cypripedium montanum

(CYMO2) populations include the following: 

 Avoid direct ground disturbance to plants: exclude mastication and hand-thinning in FRZs, 

RS treatments, and Riparian Reserves and exclude fireline construction (including handline 

and machine-constructed firelines) in Rx Units within 25 feet of population boundaries; 

exclude mechanical treatment and yarding within population boundaries. 

 Maintain shade from overstory canopy cover: exclude mechanical harvest activities within 

one site tree distance on slopes to the south and southwest of populations and allow harvest 

activities to north and northeast of populations with trees felled away from populations. 

 Avoid high-temperature burns from slash pile burning treatment: exclude all piling and 

burning of slash in FRZs within 25 feet of population boundary. 

 Allow prescriptive burning (in FRZs and Rx Units) within population boundary outside of 

active growing season (September 2 to March 31); where conditions allow for burning 

during the active growing season (April 1 to September 1), mitigate to exclude burning of 

plants with either (i) use of fire retardant foam applied outside of the population boundary, 

or (ii) construction of a fireline (handline) 25 feet outside of population boundary. 

The measures required for the two Ptilidium californicum (PTCA5) populations include the 

following: 

 Avoid all direct disturbance to PTCA5 substrate trees: exclude mastication in RS 

treatments within 25 feet of substrate tree. 

 Avoid harvest of PTCA5 substrate trees in RS treatments. 

 Allow all prescriptive fire in FRZs but protect the lower bole of the PTCA5 substrate tree 

from all fire treatments, including treatment of slash: mitigate with either (i) the use of fire 

retardant foam applied in a buffer around the tree, or (ii) construction of a fireline 

(handline) in a buffer around the tree. 

 Maintain shade from overstory canopy cover in population: exclude mechanical harvest 

activities within one site tree distance on slopes to the south and east of populations, and 

allow harvest activities to north and northeast of populations with trees felled away from 

populations. 

Resource protection measures are not required for the Smilax jamesii population. 

2.9.6.2 Sensitive Fungi 

The six Forest Service Sensitive Fungi that are assumed to be present occur in the wetter 

environments of riparian areas and uplands within 25 feet of the riparian vegetation. This habitat is 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

2-30 Chapter 2: Proposed Action and Alternatives

present in Riparian Reserves inside proposed FRZs and Rx Units, and does not occur in proposed 

M Units or RS treatments. RPMs are not proposed for the six Forest Service Sensitive Fungi. Instead, 

RPMs for Riparian Reserves are incorporated into the Proposed Action. The RPMs are designed to 

protect fish and water resources, and would also provide benefits to Sensitive fungi and habitat. 

2.9.6.3 Noxious Weeds 

Prevention

 Require all contractors and permittees to clean equipment prior to entering National Forest 

System lands and when moving within a treatment unit from known noxious weed sites; 

follow Provision B6.35 Equipment Cleaning (summarized below): 

- Vehicles used off roads shall not be used in the Assessment Area if it was last 

operated in an area infested with one of more invasive species of concern areas 

without having cleaned such equipment of seeds, soil, vegetative matter, and other 

debris that could contain or hold seeds. Equipment shall be considered clean when a 

visual inspection does not disclose seeds, soil, vegetative matter, and other debris that 

could contain or hold seeds. 

 Flag noxious weed populations on the ground prior to project implementation to avoid all 

proposed project ground-disturbing activities. 

 Avoid proposed ground-disturbing project treatments in units known to contain noxious 

weeds; these treatments include road construction, mastication, prescribed fire, and fireline 

construction (both hand and machine firelines and piling and burning of slash). See Table 6 

in the Botanical Resources Report for weed sites and proposed treatment unit locations. 

 Require the use of certified weed-free seed and straw to restore areas of ground 

disturbance. 

 Mastication equipment will be brought in clean (debris free) and not be staged in areas 

known to have noxious weed infestations. 

 Mastication treatment areas will be surveyed for new noxious weed populations after 

mastication treatments occur. 

 New noxious weed populations, resulting from project implementation, will be treated and 

monitored. 

Control 

 Conduct post-treatment surveys in proposed treatment units and use site-specific 

evaluations to determine appropriate treatment to control any weed sites located. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Chapter 2: Proposed Action and Alternatives 2-31

Monitoring 

 Monitor mechanical treatment units and RS treatments for noxious weeds, as part of the 

Klamath National Forest noxious weed program, after the proposed project treatments are 

completed or as long as it takes vegetation to recover from disturbance (as measured by 

ground duff cover and forb and shrub layer cover). 

2.9.7 Heritage Resources 

 Heritage resource sites have been flagged and will be avoided. “Avoid” means that no 

activities associated with the project that may affect heritage resource sites shall occur 

within a site’s boundaries. 

 If previously unrecorded heritage resources are discovered during project implementation, 

the Archaeologist for the Salmon River and Scott River Ranger Districts will be contacted 

immediately. The heritage resources will be recorded, clearly delineated, and protected. 

2.9.8 Air Quality 

 Burn plans, which include smoke management plans, will be written prior to 

implementation of prescribe burn treatments. The burn plans will identify and comply with 

policies and regulations of the Siskiyou County Air Pollution Control District and 

Northeast Plateau Air Basin. 

2.9.9 Scenery 

Resource protection measures for project activities visible from Sensitive Viewing Locations: 

 Stump treatments. In M Units where excessive stump contrasts would otherwise appear 

visually dominant (and therefore not meet the Partial Retention Visual Quality 

Objectives/VQOs), apply a low cut stump height of less than 4–6 inches within 75 feet of 

the road/trail edge. Where additional contrast reduction is needed to retain a dominantly 

natural-appearing roadside setting (Partial Retention Visual Quality Objective/VQO), 

visible stumps within this view zone shall be fully or partially concealed by application of 

dirt, duff, and woody debris. 

 Thinning by cable. Minimize the difference in stand densities within and on either side of 

a cable corridor. Cover soil disturbance in cable corridors with debris, as needed, to retain a 

dominantly natural appearance (Partial Retention Visual Quality Objective/VQO) when 

viewed from sensitive viewpoints. 

 Treatment of activity debris. Smooth turn piles or any other soil disturbance from 

machine piling within 75 feet from roads. 

 Retain visibly distinctive trees. In M Units, retain visibly distinctive trees, such as those 

with atypical forms, distinctively colored or textured bark (such as large ponderosa pine or 

madrone), evidence of earlier fires (catfaces), acorn granaries, or colorful seasonal leaves 

(such as black oak, big leaf maple, Pacific dogwood). 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

2-32 Chapter 2: Proposed Action and Alternatives

 Road actions. Implement closure of new temporary roads, former logging access routes, 

and spurs to appear largely natural and not attract attention. Preferably, this is through the 

use of natural-appearing native boulder groupings, logs, and natural-appearing landforms, 

rather than unnatural-appearing dirt piles, trenches, signs, or gates. 

2.9.10 Recreation 

Measures to ensure the safety and convenience of the public include: 

 Traffic Safety and Control Plans prior to commencing project operations. The Plan will 

provide for public safety on Forest Service controlled roads and trails open to public travel. 

 Roads and trails open to the public will be kept open or only closed for short durations. 

Project activities will minimize conflicts with public use on weekends and holidays. 

 Dispersed campsites will be maintained in a usable condition if possible; however, they are 

not protected nor managed as developed sites. 

 Warning signs will be posted on the Pacific Crest National Scenic Trail during any adjacent 

project activities. Any damage to the trail will be immediately repaired. 

2.10 Seasonal Constraints on Operations 

in the Eddy Gulch LSR Project Assessment Area __________ 

The following analysis of the Limited Operating Periods (LOPs) identified in the resource 

protection measures was prepared to identify constraints that could affect implementation of the 

Proposed Action. 

 Sensitive plants. Burning during the growing season is restricted where Region 5 Sensitive 

plants occur; mitigation will be to flag and avoid for all types of treatments. The majority 

of populations are very small (less than 100 individual plants) and will not substantially 

reduce the number of acres treated. 

 NSO core areas. All M Units can be harvested without constraint of an LOP, except 

M Units 19 and 69, which occur in two NSO core areas (assuming they are occupied) and 

cannot be harvested between February 1 and September 15. 

 NSO and northern goshawk activity centers. LOPs restrict burning within 0.25 mile of 

an occupied or unsurveyed NSO or northern goshawk activity center (resulting in a 

125-acre area) during spring. Except for the 125-acre buffered area, which generally occurs 

in the lower portion of concave watersheds, the majority of the remaining units can be 

burned, with proper smoke dispersal (Table 2-8). A number of these buffered areas are 

unoccupied, and as long as surveys are conducted and the activity center remains 

unoccupied, the LOP would not apply. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Chapter 2: Proposed Action and Alternatives 2-33

Table 2-8. Percent of FRZs and Rx Units that would not be affected by LOPs. 

Prescribed 

Burn Area 

Total 

Acresa Available for Spring Burning 

Percent 

Available 

for Burningb

Rx Unit 1 and FRZs 2 and 4 2,575 Everything except 125 acres (NSO nest buffer) immediately 

north of Black Bear Ranch and northwest of Road 1E001. 

90 

Rx Unit 2 and FRZ 3 1,972 Everything, except 125 acres (NSO nest buffer) in E 1⁄2 sec 

24 and SE 1⁄4 sec 18 and 125 acres (northern goshawk nest 

buffer) on Forest Service land adjacent to Black Bear Ranch. 

81 

Rx Unit 3 and FRZ 7 2,833 Everything except 250 acres (NSO and northern goshawk nest 

buffers) along Matthews Creek. 

86 

Rx Unit 4, FRZs 5, 6, 9, 

and 11 

4,318 Two separate polygons: western polygon is constrained by 

3 NSO nest buffers; eastern polygon, everything except 

125 acres at the end of 39N46. 

83 

Rx Unit 5 and FRZs 12 and 16 2,370 No restrictions. 100 

Rx Unit 6, FRZs 13 and 15 1,450 Everything except 125 acres (NSO nest buffer) in the NE 

1⁄4 sec 19. 

90 

Rx Unit 7 and FRZ 14 1,384 Everything except 125 acres (NSO nest buffer) in E 1⁄2 sec 20 

and W 1⁄2 sec 21. 

88 

Rx Unit 8 863 No restrictions. 100 

Rx Unit 9 and FRZ 20 2,247 Everything except 250 acres (2 NSO nest buffers). 78 

Rx Unit 11 251 No restrictions. 100 

Rx Unit 12 521 Southern portion between 39 road and 39N27. 20 

Total 20,784 

Notes: 

a. Acreage includes Rx Unit and adjacent FRZ. 

b. Percent available for burning = Total Areas – (125-acre nest buffer (nests) + 125 acres/nest) to allow for location of control 

points and smoke dispersal. 

 NSO habitat. No more than 50 percent of NSO nesting/roosting/foraging (n/r/f) habitat 

can be adversely affected in a 7th-field watershed (less than 3,500 acres) by mechanical 

treatment or burning in a single year. M Units generally avoid NSO habitat; therefore, the 

majority of treatment will be mastication or burning. For planning purposes assume each 

NSO home range (1.3-mile radius = 3,400 acres) occurs in a separate watershed, and NSO 

home ranges in the Eddy Gulch LSR have an average of 1,643 acres of n/r/f habitat or 

48 percent of the home range within a 7th-field watershed. Thus, within NSO home ranges, 

approximately 1,640 acres (820 acres n/r/f + 820 acres nonhabitat) could be burned 

annually. 

 Fisheries water quality. Project activities are scheduled to occur between April 15 and 

October 15. This period may be extended on either end of the stated seasonal range based 

on occurrence of all of the following criteria: (1) a long-term dry weather forecast, (2) the 

ability to winterize activities at the end of the day, (3) acceptance of recommendations 

from the district fisheries biologist and/or hydrologist (after meeting the first two criteria), 

and (4) authorization by the District Ranger (after meeting the first three criteria). Wet 

Weather Operation Standards (USDA Forest Service 2002a) will be followed whenever 

activities occur outside of the normal operating season (USDA Forest Service 2002). All 

landing, skid trail, and temporary road construction, road closure, and road re-conditioning 

will be conducted during the appropriate periods of weather and soil moisture to ensure 

BMP attainment and the avoidance of adverse effects on listed species (USDA Region 5 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

2-34 Chapter 2: Proposed Action and Alternatives

Soil Quality Handbook 1995b and BMP 5.6 in Appendix D of the Fish Biological 

Assessment / Biological Evaluation for this project). Favorable forecast periods will also be 

of a suitable length to allow completion or winterization of the task undertaken before 

precipitation events occur. 
Chapter 3 

Affected Environment and 

Environmental Consequences 
Welcome 

You are now in the “Affected Environment and Environmental 

Consequences” chapter. Here are the topics you can read about. 

3.1 Introduction............................................................................................3-1

3.2 Forest Vegetation...................................................................................3-4

3.3 Fire, Fuels, and Air Quality ................................................................3-29

3.4 Wildlife and Habitat.............................................................................3-57

3.5 Aquatic Resources..............................................................................3-111

3.6 Soils and Geology ..............................................................................3-149 

3.7 Botanical Resources and Noxious Weeds......................................3-173

3.8 Social Values.......................................................................................3-218

3.9 Short-term Uses and Long-term Productivity ...............................3-229 

3.10 Unavoidable Adverse Effects...........................................................3-230 

3.11 Irreversible and Irretrievable Commitment of Resources ...........3-230 

3.12 Cumulative Effects ............................................................................3-231 

3.13 Climate Change ..................................................................................3-231 

3.14 Energy Requirements, Conservation Potential, 

Depletable Resource Requirements ................................................3-232 

3.15 Prime Farmland, Rangeland, and Forest Land ..............................3-232 

3.16 Possible Conflicts with Other Land Use Plans..............................3-232 

3.17 Other Required Disclosures.............................................................3-232 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.1 – Introduction 3-1

Chapter 3. Affected Environment 

and Environmental Consequences 

3.1 Introduction__________________________________________ 

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

Gulch Late-Successional Reserve (LSR) Project Assessment Area and the effects on these 

environments that would result from taking no action (Alternative A) or from implementation of 

“Alternative B: Proposed Action ” or “Alternative C: No New Temporary Roads Constructed.” This 

chapter also presents the scientific and analytical basis for comparison of the alternatives presented in 

“Chapter 2: Proposed Action and Alternatives.” 

Each resource section in this chapter is a summary of the respective resource reports. The 

following reports are available on the project website (http://www.eddylsrproject.com): Silviculture 

Report, Fuels and Air Quality Report, Wildlife and Habitat Report, Aquatic Resources Report for 

Water Quality and Fisheries, Botanical Resources Report, Soils Report, Geology Report, Scenery 

Report, Scenery Analysis, Recreation Report, Wild and Scenic Rivers Report, Social Assessment, 

Economics Analysis, and Roads Report. The following documents are also available on the project 

website: Biological Assessment/Biological Evaluation (BA/BE) for Wildlife, BA/BE for Fish, and 

BA/BE for Plants. 

This “Environmental Consequences” chapter analyzes both beneficial and adverse effects that 

could result from selecting any of the alternatives described in this final environmental impact 

statement (EIS). This chapter includes a summary of laws and policies relevant to each resource topic 

and the methods used to analyze current conditions and potential effects. 

3.1.1 Terms 

Throughout this final EIS, acres presented will be identified (or apparent from context) as 

applying to one of the following areas: 

Eddy Gulch LSR — the entire 61,900-acre LSR. 

Assessment Area — the 37,239-acre portion of the Eddy Gulch LSR west of Etna Summit 

where various treatments are proposed. All inventoried roadless areas that occur in the LSR were 

excluded from planning efforts and are therefore not part of the Assessment Area. 

Treatment Unit — the acres proposed for some type of on-the-ground treatment under a 

particular alternative. 

Analysis Area — the area around treatment units considered in the effects analysis (the analysis 

area may be larger than the LSR Assessment Area). The analysis area varies by resource. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-2 Chapter 3 – Affected Environment and Environmental Consequences

3.1.2 Definitions for Evaluating Effects 

The “Environmental Consequences” section for each resource describes the effects that would 

result from taking no action or implementing either action alternative; those effects are described 

according to the following definitions. 

3.1.2.1 Analysis Period (Duration of Effects) 

Each resource section in this chapter defines the analysis period used for evaluating effects on 

that specific resource. 

3.1.2.2 Types of Effects 

 Beneficial effects are those that result in a positive change in the condition or nature of the 

resource, usually with respect to a standard or objective. A change that moves a resource 

toward its desired condition. 

 Adverse effects are those that result in a negative change in the condition or nature of the 

resource, usually with respect to a standard or objective. A change that moves a resource 

away from its desired condition. 

 Direct effects are caused by the action and occur at the same place and time as the action. 

 Indirect effects are caused by the action and are later in time, further removed in distance, 

but are still reasonably foreseeable; or the response of the target resource is triggered by the 

reaction of another resource to the Proposed Action. 

 Cumulative effects are those that result from the incremental impact of the action when 

added to other past, present, and reasonably foreseeable future actions. 

 Irreversible commitments of resources are permanent or essentially permanent resource 

use or losses. They cannot be reversed, except in the extreme long term. Examples include 

mineral extraction or loss of soil productivity. 

 Irretrievable commitments of resources are losses of productivity or use for a period of 

time. One example is road construction on suitable timber lands. Timber growth on the 

land is irretrievably lost while the land is used as a road, but the timber resource is not 

irreversibly lost because the land could grow trees in the future, if the road were removed. 

3.1.2.3 Intensity of Effects 

Each resource section in this chapter contains the intensity of effects definitions used for 

evaluating effects on that specific resource. The intensity definitions are expressed as negligible, 

minor, moderate, and major. 

3.1.3 Council on Environmental Quality Guidance 

on Cumulative Effects Analysis 

The Council on Environmental Quality (CEQ) provided recent guidance (memorandum prepared 

by James L. Connaughton, Chairman, White House Council on Environmental Quality, June 24, 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.1 – Introduction 3-3

2005) on the extent to which agencies of the federal government are required to analyze the 

environmental effects of past actions when they describe the cumulative environmental effects of a 

proposed action in accordance with Section 102 of NEPA (42 United States Code [USC] 4332, and 

the CEQ Regulations for Implementing the Procedural Provisions of NEPA [National Environmental 

Policy Act], 40 Code of Federal Regulations [CFR] parts 1500-1508. CEQ’s interpretation of NEPA is 

entitled to deference. Andrus v. Sierra Club, 442 U.S. 347, 358 (1979)). 

The following is excerpted from that June 24, 2005, memorandum: 

The environmental analysis required under NEPA is forward-looking, in that it 

focuses on t he potential i mpacts of t he proposed action that an agency is 

considering. 

CEQ interprets NEPA and CEQ’s NEPA regulations on cumulative effects as requiring analysis 

and a concise description of the identifiable present effects of past actions to the extent that they are 

relevant and useful in analyzing whether the reasonably foreseeable effects of the agency proposal for 

action and its alternatives may have a continuing, additive and significant relationship to those 

effects. In determining what information is necessary for a cumulative effects analysis, agencies 

should use scoping to focus on the extent to which information is “relevant to reasonably foreseeable 

significant adverse impacts,” is “essential to a reasoned choice among alternatives,” and can be 

obtained without exorbitant cost. 40 CFR 1502.22. 

3.1.4 Reasonably Foreseeable Future Projects 

in the Vicinity of the Eddy Gulch LSR Project 

The Klamath National Forest Schedule of Proposed Actions was reviewed to identify current and 

reasonably foreseeable projects on the Salmon River and Scott River Ranger Districts that should be 

included in the cumulative effects analysis for the Eddy Gulch LSR Project. Ongoing projects include 

annual road maintenance, improvements to existing mining claims, hiking, and appropriate responses 

for fire suppression. Additional future projects include the following: 

 Installing telephone and fiber-optic lines through the Ranger District (this involves digging 

a trench adjacent to roads to bury the lines and installing access points for future 

maintenance activities). 

 North Fork Roads Stormproofing Project (this involves storm proofing 76 miles of road 

requiring blading, improving road drainage, and protecting riparian and stream systems; 

decommissioning 36 miles of roads to reduce sediment delivery to streams; and adding 

2.4 miles of existing road). 

 Construction of a fuelbreak system west of Black Bear Ranch (approximately 700 acres of 

ridgetop fuel reduction). 

 A small amount of projects on private lands have been funded under the Salmon River 

Community Wildfire Protection Plan (CWPP). This includes funding to treat 75 acres of 

fuels on private properties in and around the Eddy Gulch LSR Project Assessment Area in 

the next 18 months. There may be funding for at least 50 acres in the following 18 months. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-4 Chapter 3: Affected Environment and Environmental Consequences

3.2 Forest Vegetation ____________________________________ 

3.2.1 Introduction 

This section describes forest vegetation (conifer and hardwood) in the Assessment Area for the 

Eddy Gulch LSR Project. This report describes the natural and human factors that have contributed to 

current conditions of vegetation, composition, and structure of the forest. This section also describes 

the effects from taking no action (Alternative A) and effects that would result from implementing the 

Eddy Gulch LSR Project under the Proposed Action (Alternative B) or under Alternative C (No New 

Temporary Roads Constructed). 

3.2.2 Methodology 

3.2.2.1 Analysis Methods and Assumptions 

All of the stands identified for thinning treatments are located in either a Fuel Reduction Zone 

(FRZ) or roadside (RS) treatment along an emergency access route. There are two categories for 

thinning treatments: trees to be thinned are larger than 8 inches diameter at breast height (dbh) and 

trees to be thinned are less than 8 inches dbh. 

Field Inventories and Stand Exams. In order to ensure that silvicultural prescriptions are 

consistent with the Klamath LRMP, field inventories were conducted to measure attributes of existing 

vegetation. Data were used to determine site quality, timber volume, basal area, stand density index 

(SDI), average size of live trees in terms of quadratic mean dbh, number of trees per acre, tree 

growth, species present, and tree condition. All proposed thinning stands in the FRZs (with trees to be 

thinned larger than 8 inches dbh) were site reviewed by a silviculturist. A stand exam crew installed 

random plots and collected stand data that included basal area, trees per acre, volume per acre, canopy 

cover, site class, and stand density. The thinning units were inventoried using the current Forest 

Inventory and Analysis User’s Guide for the United States Department of Agriculture (USDA) Forest 

Service Pacific Southwest Region. The stands were stratified into six categories: 

1. Douglas-fir mid-successional, 

2. Douglas-fir mid- / late-successional, 

3. white fir mid-successional, 

4. white fir mid- / late-successional, 

5. red fir late-successional, and 

6. mixed-conifer late-successional. 

The stand diagnoses and strata-specific prescriptions were developed based on the field 

information. 

The field data were then loaded into the Forest Vegetation Simulator (FVS) program, which is a 

forest growth model that predicts forest stand development following treatment. The model analyzed 

the field data collected for the six strata categories listed above. FVS calculates specific data for basal 

area and volume and models the information (such as canopy cover and stand density) based on data 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.2 – Forest Vegetation 3-5

from local research, which is programmed into algorithms within the FVS. The model does not 

produce absolute values and approximates the natural processes. 

Additional analyses included aerial photo interpretation and Forest Inventory timber type 

coverages in Geographic Information System (GIS). The Forest Inventory typing is vegetation-type 

mapping based on year 1995 aerial photographs. These were used to determine timber strata, size 

class, and densities. The GIS coverages were also used to determine land classification and allocation. 

The topography and slope of and access to each treatment unit were used to determine the most 

appropriate system to be used for thinning. For treatment units in the Eddy Gulch LSR Project, 

ground-based (tractor) and cable yarding systems are proposed. Silvicultural prescriptions were based 

on a desired future stand condition using stand exam data, FVS projections, aerial photograph 

interpretation, and field review. 

The prescriptions are designed to space trees to meet the fire objective of reducing crown fire 

potential. The FVS data analysis simulated thinning the stand from below to produce the predicted 

changes. Stand development was modeled for 5- and 30-year periods, using the proposed thinning 

(under Alternatives B and C) and with no thinning (under Alternative A), to display the differences 

between treating and not treating the stands. 

The RS treatments along emergency access routes (roads or road segments) are long, linear 

management stands that traverse numerous vegetation types. The roads or road segments were 

inventoried, and the vegetation was classified into 1 of 3 categories (developed together by fuels and 

silviculture specialists) with associated generic prescriptions. 

Prescription Development. A stand prescription was developed for each stratum shown in 

Appendix A of the Silviculture Report (Table A-1 for Alternative B and Table A-2 for Alternative C). 

The basic prescription is based on a designated largest leave tree spacing (DxD). The largest tree is 

determined by its dbh measurement. The spacing indicates a minimum and maximum distance in 

which the largest leave tree must be selected. This prescription works best in areas where tree spacing 

is more important than stand variability. It works well in meeting the objectives of an FRZ. The 

concept is that the largest trees within a prescribed distance will be left, and all other trees greater 

than 8 inches between the largest leave trees will be cut and removed. The spacing requirement 

minimizes tree crown contact by thinning from below, with emphasis on thinning clumps of conifer 

trees. 

The interdisciplinary (ID) team silviculturist and fire/fuels specialists and the Klamath National 

Forest silviculturist and silviculture contract inspector visited a Rogue National Forest timber sale that 

had been marked using a DxD prescription. It was agreed that the DxD prescription would work well 

for the Eddy Gulch LSR Project. 

The ID team silviculturist prepared draft DxD stand prescriptions for several white fir units in the 

Shadow Creek area. The forest silviculturist field reviewed these proposed prescriptions and agreed 

with using this prescription on the project. 

An ID team fire/fuels specialist also field reviewed the above-mentioned draft prescriptions and 

agreed that they met the fire/fuels objectives. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-6 Chapter 3: Affected Environment and Environmental Consequences

Trees larger than the indicated maximum dbh will not be cut unless they fall under the 

prescriptions contained in the Klamath National Forest Hazard Tree Policy (USFS 2005—included as 

Appendix C of this final EIS). The DxD spacing was individually prescribed for each stand. Each 

stand was reviewed in the field, and the prescribed spacing was selected based on stand factors such 

as tree species, tree crown size, and tree age. 

“Special Directions” (see the last column in Tables A-1 and A-2 in the Silviculture Report) are 

used to either emphasize or de-emphasize tree species selection. This was done by weighing dbh 

measurements by adding or subtracting inches to the indicated species dbh measurement. The 

Klamath National Forest Forestwide Late-Successional Reserve Assessment (forestwide LSR 

assessment) (USFS 1999) placed high value on retaining sugar pine, so most of the stand 

prescriptions have a special direction adding inches to the dbh measurement. White fir in some units 

did not meet stand objectives and was de-emphasized by subtracting inches from the dbh 

measurement. 

All stand prescriptions remain the same for Alternatives B and C, with the only difference being 

the amount of acres in M Units that would be treated; that is, Alternative C would treat 99 acres less 

than Alternative B because, under Alternative C, no new temporary roads would be constructed to 

access some of the treatment units. 

Refer to the “Fuels Report” for the Eddy Gulch LSR Project (or the “Fire, Fuels, and Air Quality” 

section in this document) for an analysis of the effects that would result from implementation of 

Rx Unit treatments under Alternative B (17,524 acres) and the reduction in Rx Unit treatments under 

Alternative C (16,702 acres). 

3.2.2.2 Scope of the Analysis 

Analysis Area. Vegetation management activities have localized effects on vegetation attributes 

(such as canopy cover, tree density, and tree size) that are generally confined to the treated area. 

Therefore, the direct, indirect, and cumulative effects analyses of vegetation resources are 

geographically bounded to the Eddy Gulch LSR Project Assessment Area. 

Analysis Period. The timeframe for the effects analysis is 5 years for short-term effects and up to 

30 years for long-term effects on vegetation. The western slope of the Klamath Mountains in the 

Klamath National Forest has a relatively high rate of vegetation establishment and growth due to high 

annual precipitation and productive forest soils. Within this time frame (up to 30 years following 

treatment), vegetation generally has sufficient opportunity to increase canopy cover, basal area, and 

tree density to a point where subsequent thinning would be needed to maintain stand vigor, health, 

and growth. 

3.2.2.3 Intensity of Effects 

“Intensity” refers to the severity of effects or the degree to which the action may adversely or 

beneficially affect a resource. The intensity definitions used throughout this effects analysis are 

described below. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.2 – Forest Vegetation 3-7

Negligible. Effects would be at the lowest levels of detection and would have no appreciable 

effect on resources, values, or processes. 

Minor. Effects would be perceptible but slight and localized. 

Moderate. Effects would be readily apparent and widespread and would result in a noticeable 

change to resources, values, or processes. 

 Major. Effects would be readily apparent and widespread and would result in a substantial 

alteration (beneficial or adverse) or loss of resources, values, or processes and would likely be 

permanent. 

3.2.2.4 Measurement Indicators 

There are four measures (or indicators) that were used to assess current stand structure in the 

Assessment Area. These same indicators were used to assess effects of taking no action and effects 

that could result from implementation either Alternative B or Alternative C. 

Indicators for Stand Structure 

 Basal area 

 SDI 

 Tree size 

 Canopy cover 

Indicator: Basal area. Basal area is a measure of stand density or stocking. Basal area is the 

cross section area of a tree stem in square feet measured at breast height (4.5 feet above ground) and 

inclusive of bark, usually computed by using dbh or tallied through the use of basal area factor angle 

gauge. Stocking for an area, usually on a per-acre basis, is the sum of the basal areas for all trees in 

the area. It is a measure used to describe expected stocking levels for wildlife habitat. 

Indicator: Stand Density Index. SDI, developed by Dunning and Reineke (1933), is another 

measure of stand density. It is the number of trees per unit area that a stand would have at a given 

average dbh. 

SDI can also be used as a species-specific measure of tree competition for resources (nutrients, 

water, and sunlight). The calculated SDIs for the stand management proposals were evaluated based 

on indicated inter-tree competition levels. Long (1985) identified four levels of competition using the 

SDI ratings developed by Dunning and Reineke. The four levels are 

1. onset of competition—25 percent of maximum SDI; 

2. lower limit of full site occupancy—35 percent of maximum SDI; 

3. lower limit of self thinning (initiation of mortality due to resource competition, remaining 

trees continue to grow)—60 percent of maximum SDI; and 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-8 Chapter 3: Affected Environment and Environmental Consequences

4. maximum stocking (mortality = biomass accumulation = no net growth in stands)—

100 percent SDI. 

The maximum SDI for the major conifer species in stands in the Eddy Gulch LSR Project 

Assessment Area are 

800 for red fir; 

760 for white fir; 

600 for Douglas-fir; and 

430 for mixed-conifer (using ponderosa pine as the key species). 

Indicator: Tree Size. Tree size (average diameter) is an important wildlife habitat attribute. The 

forestwide LSR assessment emphasizes larger conifer stocking levels, particularly for trees greater 

than 24 inches dbh. 

Indicator: Canopy Cover. Canopy cover is the degree to which the canopy (forest layers above 

one’s head) blocks sunlight or obscures the sky, expressed as a percent of ground area (is also 

referred to as canopy closure or crown cover). Canopy cover is another stand attribute that is used to 

describe wildlife habitat. 

3.2.3 Affected Environment (Existing Conditions) 

This section provides a description of the existing forest stand conditions for each of the four 

measurement indicators listed above. 

3.2.3.1 Historic Influences on Stand Structure 

Pre-settlement Influences. Prior to European settlement, fire was the primary disturbance 

regime that affected the composition and structure of forests in what is now the Eddy Gulch LSR. The 

fires were either ignited by lightning or Native Americans, and given the frequency of those fires, the 

intensity of the fires varied, resulting in a mosaic (variety) of forest stands that differed from today’s 

stands. In a study conducted about 50 miles from the Eddy Gulch LSR Project, Taylor and Skinner 

(1998) reported that, in the Douglas-fir–dominated forests of the Klamath Mountains, upper slopes 

(ridge tops) had more frequent fires and more severe fires than middle and lower slopes (Table 3-1). 

Table 3-1. Median and range of median fire return intervals (years) for sites by 

aspect and slope position for plots on Thompson Ridge, Klamath Mountains, 

California. 

Slope Position 

N 

(samples) 

Median Fire 

Return Interval 

(year) 

Range 

(year) 

Lower (2,000–3,100 feet) 17 19 5–87 

Middle (3,100–4,060 feet) 27 14 6.5–116 

Upper (4,060–5,020 feet) 16 10.5 4–37.5 

Source: Taylor and Skinner 1998. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.2 – Forest Vegetation 3-9

Moreover, lower slope positions experienced mostly (75 percent) low-severity fires, whereas 

upper slopes experienced mostly (63 percent) moderate- and high-severity fires, with the mid-slope 

positions being intermediate. Severe fires were defined to be those that had less than four “tall” stems 

per acre remaining after the fire. 

Skinner and Taylor (1998) concluded, “The cumulative effect of fire severity variation across 

slopes suggests that forests with late-successional characteristics (such as multilayered canopy, high 

density of large-diameter trees, snags, and coarse woody debris) were more commonly found at lower 

slope positions as well as on north- and east-facing slopes. Upper slope positions, as well as 

intermediate positions on south- and west-facing slopes, were more likely to display a pattern of 

scattered, remnant, older trees and patches, exhibiting some late-successional characteristics within a 

coarser-grained pattern largely of younger stands.” 

In a study in the central Oregon Coast range, Impara (1997) also found that upper hillslope 

positions had higher frequency and severity of fire than lower hillslope positions. He noted, “An 

important feature of this result is that old-growth trees are more common at lower hillslope positions 

than at upper hillslope positions. This pattern of old-growth occurrence should be considered in 

studies of forest patterns and related management approaches to old-growth forests.” 

Fire history also influenced the composition of stands in the Eddy Gulch LSR. Historically, stands 

in the Eddy Gulch LSR Project Assessment Area had a higher component of shade-intolerant species 

such as ponderosa, Jeffrey, and sugar pine in the overstory. These species are better adapted to the 

open stands created by frequent fires. 

The ID team’s silviculturist reviewed photographs taken from the Eddy Gulch Lookout location 

in 1935 and from the same location in 1992. The Figure 3-1 photograph (1935) view area is east of 

the lookout towards the Deacon Lee trailhead and the Russian Wilderness Area. The Figure 3-2 

photograph is of the same view area but was taken 57 years later in 1992. Note the road that is visible 

in the hardwood / brush fields in the 1935 photograph is totally obscured in the 1992 photograph by 

the conifer stands that now occupy the site. 

The Figure 3-3 photograph (1935) is to the west of the lookout showing the upper portions of 

Eddy Gulch (right) and Crawford Creek (left). The Figure 3-4 photograph of the same view was taken 

in 1992. The southerly aspects in Crawford Creek in 1935 had large areas of hardwood / brush fields 

with scattered pockets of conifers. The 1992 photograph shows that conifer stands are now a major 

component of the landscape vegetation. 

The northerly aspects on the upper slopes in Eddy Gulch did support less dense conifer stands. 

The stands appear to be less dense in 1935 than in the 1992 photograph. 

The predominantly white fir conifer stands that developed in the hardwood / brush fields (as 

shown in the 1935 photos) have continued to grow and are now 70 years or more in age. Field 

examination of these stands indicates that they are densely stocked with a high level of inter-tree 

competition that is leading to poor stand health, higher fuel loads, and increased fire danger. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-10 Chapter 3: Affected Environment and Environmental Consequences

Figure 3-1. Photo taken in 1935—view area is east of Eddy Gulch Lookout. 

Figure 3-2. Photo taken in 1992—same view area as Figure 3-1. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.2 – Forest Vegetation 3-11

Figure 3-3. Photo taken in 1935—view area is west of Eddy Gulch Lookout. 

Figure 3-4. Photo taken in 1992—same view area as Figure 3-3. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-12 Chapter 3: Affected Environment and Environmental Consequences

Post-settlement Influences. Gold was discovered in about 1850 in the area that is now the Eddy 

Gulch LSR. Over the next four to five decades, miners removed much of the vegetation in the vicinity 

of the mining activities for tunnel timbers and structures and often burned the rest to expose the 

mineral resource (examples would be the lower portions of Whites Gulch and Eddy Gulch and areas 

around Black Bear Ranch). The result is a somewhat less-than-natural number of trees and stands 

over 130 years of age. With the creation of the Klamath National Forest shortly after the turn of the 

century, and the emphasis on fire suppression beginning about 1910, not only have forests returned to 

much of the potential forest land in the LSR, but most stands contain many more trees and other 

understory vegetation (along with limbs, logs, and other understory fuels) than would have been 

present under historical conditions. Approximately 84 percent of the Eddy Gulch LSR Project 

Assessment Area has not experienced fire since 1910. This has resulted in approximately 67 percent 

of the Assessment Area being classified as severely departed and approximately 28 percent classified 

as moderately departed from its historical biophysical conditions (Creasy 2008). Roughly 64 percent 

of the severely and moderately departed acres are in the true fir (genus Abies) zone, with the 

remaining 36 percent located in the lower elevations (Creasy 2008) (refer to the “Fuels Report” for 

further descriptions of departure from historical conditions). 

3.2.3.2 Current Stand Structure 

The current vegetation composition and structure in the Eddy Gulch LSR were shaped by 

physical and biological factors, primarily those that influence temperature, moisture, and disturbance. 

These factors include topography, aspect, soil conditions, hydrology, weather, and fire (USFS 1999). 

Fire suppression has had an effect on vegetation that would have existed historically or ordinarily in 

the presence of fire; that is, a mosaic of vegetation, which includes large areas of mid- and latesuccessional forest, interspersed with more open conifer stands mixed with hardwoods or younger 

stands created by disturbances. 

Stand Structure in the Assessment Area. Historically, stands in the Eddy Gulch LSR Project 

Assessment Area had a higher component of shade-intolerant species such as ponderosa, Jeffrey, and 

sugar pine in the overstory. Currently, the dominant vegetation consists of true firs (red and white) in 

the upper elevations and Douglas-fir and mixed-conifer stands in the mid to lower elevations of the 

Assessment Area. Madrone and other hardwoods (such as black oak) are commonly found in stands 

below 4,000 feet elevation. Other common conifer species, which are scattered throughout the LSR in 

the lower and less-exposed areas, are ponderosa pine, sugar pine, incense-cedar, and knobcone pine. 

The dominant hardwood in the lower and more exposed areas is canyon live oak. The major 

vegetation types in the LSR include Douglas-fir, mixed-conifer-pine, white fir, red fir, and nonconifer 

vegetation. The mixed-conifer-pine forests occur below 5,000 feet and are found on dryer slopes. The 

Douglas-fir stands occur mostly on north-facing slopes below 5,000 feet. White fir increases in 

dominance with increasing elevation, north-facing slopes, and moisture. Red fir stands are found 

mostly on north-facing slopes above 5,500 feet and on south-facing slopes above 6,000 feet. 

Forest stands can be described by dominant species and their distribution, successional stage 

(based on mean dbh of trees in the stand), or amount of canopy cover. The distribution of dominant 

species was described in the previous paragraph. The distribution and abundance of successional 

stages and amount of canopy cover for forest stands in the Eddy Gulch LSR are depicted on Map A-7

and Table 3-2 below. Approximately 30 percent of the Eddy Gulch LSR is characterized by latesuccessional forest. Approximately 43 percent of the late-successional and mid-successional stands 

are greater than 40 percent canopy cover. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.2 – Forest Vegetation 3-13

Table 3-2. Current abundance of forest successional stages and canopy 

cover in the Assessment Area. 

Stage / Canopy Cover 

Mean DBH / 

Percent Canopy Cover Acres 

Late-Successional / Open Over 25 inches / less than 40% 4,400 

Late-Successional / Dense Over 25 inches / greater than 40% 14,380 

Mid-Successional / Open 12–25 inches / less than 40% 4,510 

Mid-Successional / Dense 12–25 inches / greater than 40% 12,420 

Early Successional / Pole 6–11 inches / greater than 40% 7,200 

Early Successional / Sapling / Seedling Plantations 2,310 

Other Vegetation 16,680 

 Total 61,900 

Source: USFS 1999. 

Stand Structure in the M Units. All of the stands slated for thinning of crown fuels (removal of 

trees larger than 8 inches dbh in FRZs or the M Units described in detail in Chapter 2 of this final EIS 

for the Eddy Gulch LSR Project) in the Assessment Area are located on ridgetops. The ridgetops were 

selected because they are optimum locations to increase resistance to wildfires (Millar et al. 2007). 

Each stand was evaluated, and the characteristics of those stands, by forest type and successional 

stage, are summarized in Table 3-3. All of the stands identified for treatment are mid- or latesuccessional stands, with a high proportion (over 50 percent) of trees less than 10 inches dbh. All of 

the stands exceed 60 percent of the maximum SDI, where mortality will likely increase as a result of 

competition for resources (such as nutrients, water, and sunlight). These stands are also very different 

than the remnant late-successional stands (described by Taylor and Skinner [1998] and Impara 

[1997]) that were present prior to European settlement. Table 3-3 shows current conditions for the 

four indicators: basal area, SDI, tree size, and canopy cover. 

Table 3-3. Current stand structure on ridgetops where proposed M Units are located. 

Summary of 

Current Strata Data 

Summary of Current Conditions for Stand Structure Indictors 

(Basal Area, SDI, Tree Size, and Canopy Cover) 

SAFa 

Forest 

Type 

CWHRb 

Seral 

Stage 

TPA 

Total 

TPAc, d 

>10” 

BAe/acre 

>10” 

Average 

dbhf >10”

TPA 

>24” 

Canopy 

Cover (%) SDIg Consequence of SDI 

DFh MSi 441 135 192 16.1 5 73 405 Beyond self-thinning 

DF MS/LSj 235 120 249 19.5 20 72 425 Beyond self-thinning 

WFk MS 299 190 302 17.1 9 61 506 Beyond self-thinning 

WF MS/LS 275 124 284 20.5 29 58 479 Beyond self-thinning 

RFl LS 613 113 350 23.8 43 59 643 Beyond self-thinning 

MCm LS 255 159 320 19.2 28 69 453 Beyond self-thinning 

Notes:

a. SAF = Society of American Foresters 

b. CWHR = California Wildlife Habitat Relationship 

c. TPA = trees per acres 

d. > = greater than 

e. BA = basal area (measured as square feet per acre) 

f. dbh = diameter at breast height 

g. SDI = stand density index 

h. DF = Douglas-fir 

i. MS = mid-successional 

j. LS = late-successional 

k. WF = white fir 

l. RF = red fir 

m. MC = mixed-conifer 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-14 Chapter 3: Affected Environment and Environmental Consequences

Stand Structure in Roadside Treatments Along Emergency Access Routes. The Proposed 

Action would treat 44 miles of emergency access routes in FRZs and Rx Units (treatments would be 

similar to the FRZ or Rx Unit the route passes through) and 16 miles (with 154 acres of treatments) of 

RS treatments outside of FRZs and Rx Units—a total of 60 miles of RS treatments along emergency 

access routes. The following are the proposed RS treatments along the 16 miles of emergency access 

routes that occur outside FRZs and Rx Units (see Map A-4c): 

 Route—40N54 South Russian from the Forest Service bridge at the Assessment Area 

boundary to the intersection with the Rainbow Mine road and then along the road to the 

Rainbow Mine property line. The majority of the stand is in the South Russian Creek 

Riparian Reserve. Slopes are steep, except for the portion near the Forest Service bridge 

and the portion from the private bridge to the property boundary. 

 Route—40N61 Whites Gulch from North Fork Salmon River bridge to 39 Road 

intersection. The lower portion of Whites Gulch, below the first switchback, has 

experienced heavy mining and logging activity. It is also located in the Whites Gulch 

Riparian Reserve. Conifer stocking is mostly Douglas-fir. The middle section has several 

large conifer plantations and significant portions of poor site conditions mostly supporting 

live oak. The upper section has several large conifer plantations intermixed with older true 

fir stands. 

 Route—the 39 Road from the 1C02 intersection to intersection with FRZ 14. The 

topography traversed is generally steep (over 60 percent slopes). The lower-elevation 

vegetation is dense, consisting mostly of young Douglas-fir or mixed-conifer. The upperelevation stands are older white fir stands intermixed with plantations (some older 

plantations are ponderosa pine). 

3.2.3.3 Disturbances 

The current condition of forest vegetation in the Assessment Area will not remain static because 

natural and human disturbances will continue to affect stand conditions and forest health. Major 

disturbances include insect and disease activity, weather, and wildfires; whereas, mining would have 

little effect on the Eddy Gulch LSR, as a whole, and is considered a minor disturbance in the 

Assessment Area. Insects, diseases, and weather-related events are the disturbances described below. 

The “Fuels Report” details the current fuels conditions in the LSR. 

Insects and Diseases. Insects and diseases create dead and down material and recycle nutrients 

into the ecosystem, but they can also increase the potential for high-intensity fires by increasing the 

amount of dead and down fuel. This can have secondary effects on sediment production and changes 

in vegetative character, landslides, and atmospheric conditions. The removal of frequent low-intensity 

fires (replaced by infrequent high-intensity fires) has encouraged insects and diseases to replace fire 

as the primary disturbance process. This has exacerbated the fire behavior potential on many sites 

(USFS 1995). 

Insects—Insect levels play an important role in stand health. Insects commonly attack trees 

weakened by disease, mechanical damage, and inter-tree competition. Increases in insect levels can 

have major effects on stand health when large numbers of weakened trees, including dominant and 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.2 – Forest Vegetation 3-15

co-dominant trees, are killed. This can alter the pattern of forest succession and increase fuel loads 

and the likelihood of a stand-replacing fire. Insect levels are cyclic and are not easily predicted in the 

long term. Existing stand density and health conditions were used to evaluate possible future activity 

levels. 

High and moderate levels of insect-caused mortality can be found throughout the Eddy Gulch 

LSR. This mortality amplifies the risk of severe fire effects and can hamper the ability to control fires 

in areas containing dead and down fuel loading and dead trees (snags), which pose a significant safety 

hazard. The areas of primary concern inside the LSR include the historically high-mortality area from 

Grouse Point west, both forks of Crawford Creek, and a moderate-mortality area from Grasshopper 

Ridge to the northwest and also in Music Creek and Highland Creek. Very little recent insect-caused 

tree mortality was observed during the 2008 field season, and current insect activity appears to be at 

or below the endemic level. 

Fir Engraver Beetle. The fir engraver beetle (Scolytus ventralis) attacks most true fir species 

in the western United States. The attacks by this under-the-bark burrowing beetle can result in patch 

kill around the bole, top kill, and tree mortality. Top kill and tree mortality are often associated with 

trees already weakened by root disease, overstocking, drought, and heavy dwarf mistletoe infection 

(Keen 1952). 

Western Pine Beetle. The western pine beetle (Dendroctonus brevicomis) is the most 

devastating insect affecting ponderosa pine in California and Oregon. Normally, this beetle breeds in 

windfalls, unhealthy trees, or in trees weakened by drought, stand stagnation, fires, and beetle 

infestations, which usually lead to tree mortality (Keen 1952). 

Diseases—Diseases play an important role in stand health. The potential problems created by 

diseases include weakening of trees, which leads to increased tree mortality or susceptibility to blow 

down or breakage. This can alter the pattern of forest succession and increase fuel loads and the 

likelihood of a stand-replacing fire. Field observations of current disease types and levels of 

occurrence/severity were used to roughly predict future levels. 

Dwarf Mistletoe. Dwarf mistletoe (Arceuthobium spp.) is found throughout the Assessment 

Area. It has a definite influence on stand health, particularly where edaphic (soil-related) factors or 

stand density place other limits on tree growth and health. Dwarf mistletoe is a host-specific (capable 

of living solely on or in one species) parasitic seed plant. Field reconnaissance of the Assessment 

Area identified mistletoe infection in the major conifer species (Douglas-fir, white fir, incense-cedar, 

ponderosa pine, and red fir) that are present in the Assessment Area, indicating that several different 

dwarf mistletoe species are present. Conifer species most affected in the area are red fir, Douglas-fir, 

and ponderosa pine. 

Cytospora. Cytospora (Cytospora abietis) is a canker disease that affects red fir in the 

Assessment Area. This disease is closely associated with dwarf mistletoe. The progress of the disease 

starts with individual branch infections and proceeds in trees and stands to kill branches, until the 

crowns of trees are so weakened that fir engraver beetles, or other factors such as drought years, can 

successfully kill trees. Large areas of continuous fir forest offer little resistance to the spread of the 

canker. Larger openings can provide buffers to inhibit spread and are often responsible for breaks in 

disease occurrence. Management practices to reduce the spread of cytospora and increase success of 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-16 Chapter 3: Affected Environment and Environmental Consequences

stand development include large openings and reintroduction of fire. Red fir stands and red firs in 

white fir stands near ridgetops in the eastern portions of the Assessment Area are heavily infested 

with cytospora and dwarf mistletoe. The infestations are heaviest on the north slopes. 

 Sugar Pine Blister Rust. Sugar pine blister rust (Cronartium ribicola) is endemic in the 

LSR. This introduced disease affects western white pine, whitebark pine, foxtail pine, and sugar pine. 

The disease is introduced by spores from the alternate host (gooseberry), usually on limb tips, and 

moves through the tree tissue toward the main trunk. In many cases, young trees are killed and older 

trees have tops killed. This disease can reduce tree vigor to a point where other factors, including 

mountain pine beetle, can kill host trees. Blister rust was observed in minor amounts in the reviewed 

stands. 

 Fomes Annosus. Fomes annosus (Heterobasidion annosum) is a disease that decays tree 

roots. Incense-cedar, ponderosa pine, and sugar pine are resistant to the strain that infects white fir 

and red fir. The disease is considered to be prevalent in higher-elevation true fir stands in northern 

California. Not all areas in these stands are infested, and not all trees within them are highly 

susceptible to infection (DeNitto 1989). Very little recent tree mortality, particularly centers with 

patterns of chronic mortality, was observed during the 2008 field season. 

Wind and Snow Events. Field observations of the effects on vegetation from weather-related 

events over the past 10 to 20 years were used to describe current conditions and roughly predict the 

effects of these events on proposed stand management activities. 

The Eddy Gulch LSR has experienced high wind events that have uprooted or broken off 

numerous conifer and large hardwood trees. These events periodically occur during heavy snow and 

high wind storms. The last widespread snow/wind event occurred in the mid-1990s, and most of these 

areas were salvage logged at that time to reduce the fuel load hazard. 

Heavy snow and wind events occurred during the winter of 2007–2008. The damage to stands 

was limited in scope when compared to the event in the 1990s. Significant damage is mostly confined 

to the Klamath Basin area in Eddy Gulch LSR. A moderate amount of damage occurred on the ridge 

between the east and west forks of Shadow Creek. Pockets of minor damage are found scattered 

throughout the western portion of the Assessment Area. 

3.2.4 Desired Stand Conditions 

3.2.4.1 M Units (Mechanical Thinning Removing Trees 

Larger than 8 Inches Diameter at Breast Height) 

During the planning phase for the Eddy Gulch LSR Project, the ID team considered public 

comments, Forest Service and U.S. Fish and Wildlife Service recommendations, pre-European stand 

conditions, and consequences of climate change to reduce the probability of stand-replacing wildfires 

in the forested landscapes. The desired condition is that ground, ladder, and crown fuels have been 

reduced in the M Units, and this will successfully retard the spread of passive or active crown fires 

and set those stands on a trajectory to be similar to conditions that were present prior to European 

settlement. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.2 – Forest Vegetation 3-17

The objectives for establishing the desired stand conditions for the M Units in the FRZs are 

documented in the forestwide LSR assessment (USFS 1999) in “Chapter 4 Management 

Recommendations, Shaded Fuelbreak” (same as an FRZ) development. The emphasis is on 

interrupting fuel continuity through tree canopy spacing and treatments to reduce fuels. 

The desired condition of stands in the M Units in the Eddy Gulch LSR Assessment Area was 

established using the SDI (Table 3-4), which is a tool for measuring stand health and for predicting 

future conditions. The desired condition SDI was described as 60 percent or less of the maximum SDI 

at 30 years after treatment for each forest type. This standard was used because it is the point where 

mortality (as a result of inter-tree competition) is initiated. When the SDI was established, other stand 

characteristics (such as basal area per acre and canopy cover) were calculated (see Table 3-6 in 

Section 3.2.5.1 below) and compared to the desired conditions described in Chapter 3 of the 

forestwide LSR assessment (USFS 1999). 

Table 3-4. Desired stand structure for the upper third of slopes, as 

described in the forestwide LSR assessment. 

Klamath Forestwide LSR Assessment 

Desired Condition

Stand Structure 

(Aspect)

Basal Area 

(square feet per acre)

Canopy Cover 

(percent)

DFa (NEb) 185–220 40–60 

DF (SW)c 160–195 30 

MCd (SW) 210–245 25 

True Fir (NE) 300 40–60 

True Fir (SW) No data No data 

Source: USFS 1999. 

Notes: a. DF = Douglas-fir c. SW = southwest 

b. NE = northeast d. MC = mixed-conifer 

Chapter 3 of the forestwide LSR assessment (USFS 1999) contains descriptions of desired 

conditions for late-successional forest stands on the upper one-third of slopes for all LSRs on the 

Klamath National Forest (Table 3-4). “The descriptions are to be used to guide the development of the 

prescriptions, with development and maintenance of LS/OG [late-successional / old-growth] habitat 

as the ultimate objective of the treatment” (USFS 1999). The guides are for areas where habitat 

conditions are the primary objective. 

The proposed variable-spacing thinning prescriptions were designed to achieve the forestwide 

LSR assessment objectives for shaded fuelbreaks (same as the FRZs), where the primary treatment 

objectives are fire/fuel related (USFS 1999, Chapter 4). The primary objective is to limit the potential 

of crown fires by interrupting vertical fuel continuity (ladder fuels) and tree crown contact (canopy 

spacing). 

The variable-spacing thinning stand attributes were also compared with the guidelines for the 

“LS/OG” habitat attributes described in Chapter 3 of the forestwide LSR assessment (USFS 1999). 

Additional emphasis would be given to retaining desired conifer species and all hardwoods. Posttreatment canopy cover would range from 32 to 50 percent (Table 3-5). 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-18 Chapter 3: Affected Environment and Environmental Consequences

Table 3-5. General thinning prescriptions (for trees larger than 8 inches dbh) immediately after 

thinning. 

Type 

(Seral Stage) 

Basal Areaa

(square feet per acre) 

Stand Density 

Indexb

Approximate 

Tree Spacing 

(feet) 

Canopy Cover 

(percent) 

Douglas-fir (MS)c 132 189 25 48 

Douglas-fir (LS) 191 244 28 50 

White fir (MS) 190 262 23 37 

White fir (LS) 200 251 29 38 

Red fir (LS) 230 280 29 32 

Mixed-conifer (LS) 200 254 28 50 

Notes: 

a. Basal area— the combined area of the cross sections of tree boles at a height of 4.5 feet above the ground, generally given as 

square feet per acre. 

b. Stand Density Index—a measure of the density of a stand of trees based on the number of trees per unit area and dbh of the tree 

of average basal area. 

c. MS = mid-successional (dominant and codominant trees generally 14–18 inches dbh); LS = late-successional (dominant and 

codominant trees generally larger than 18 inches dbh). 

3.2.4.2 Remaining Portions of Treatment Units 

The desired condition in remaining portions of the FRZs, Rx Units, and RS treatments along 

emergency access routes is to increase the resilience to fire by reducing ground and ladder fuels and 

removing hazard trees that may block ingress or egress routes during an emergency event. 

The Salmon River Community Wildfire Protection Plan (CWPP) (SRFSC 2007) recommended 

the following canopy cover in conifer stands for shaded fuelbreaks along emergency access routes: 

late-successional: 70–100 percent; mid-successional (40–80 feet tall), 50–80 percent; and early 

successional (less than 40 feet tall), 50–70 percent. The Salmon River CWPP recommendations for 

canopy cover were used in the development of treatments along the emergency access routes located 

outside of the FRZs. 

Outside FRZs. It is desirable that ground and ladder fuel trees that are cut along emergency 

access routes outside the FRZs are less than 10 inches dbh, but larger hazard trees may be cut if they 

present a safety hazard. Conifer trees could be thinned to a 20-foot spacing in young conifer stands 

that are generally less than 10 inches dbh. Under desired conditions, suppressed conifers less than 

10 inches dbh will be cut in larger conifer stands if they are contributing to the fuel ladder. Smaller, 

suppressed hardwoods (generally less than 6 inches dbh) may be cut in some dense hardwood stands 

(mostly live oak) and dense young conifer / hardwood stands. 

Inside FRZs and Rx Units. For fuel reduction areas inside FRZs but outside the M Units and in 

the Rx Units, there would be mastication of ladder fuels (conifer trees up to 10 inches dbh on slopes 

less than 45 percent) and potential removal of larger hazard trees in accordance with the Klamath 

National Forest Hazard Tree Policy (USFS 2005—included as Appendix C of this final EIS). The 

exception is conifer plantations where trees could be thinned to a 20-foot spacing. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.2 – Forest Vegetation 3-19

3.2.4.3 Disturbances 

Insects. It is desirable to continue to have insect levels in the LSR, but they are generally 

maintained at endemic levels. It is important that insects do not reach levels that will create situations 

that will prevent the long-term sustainability of late-successional habitats (USFS 1999). 

Diseases. While it is desirable to have levels of mistletoe in late-successional stands, too much 

of the disease could cause problems with allowing regeneration to get established as stands begin to 

deteriorate. Historically, fire kept mistletoe at lower levels than what is observed in some areas today. 

Managers will have to be aware of some of the potential problems that may be encountered by 

allowing mistletoe levels to continue to increase in the coniferous vegetative types (USFS 1999). 

Weather-related Events. Weather-related events will continue to affect stands in the LSR. It is 

desirable that fuel reduction activities, including salvage logging, occur following these events and 

where sufficient amounts of damage have led to undesirable increases in fuel loading. 

3.2.5 Environmental Consequences 

This section provides a summary of the direct, indirect, and cumulative effects of the three 

alternatives. For Alternatives B and C (the action alternatives), effects are discussed in terms of the 

prescriptions proposed for each treatment type. Prescriptions with similar effects on vegetation are 

grouped together for the purposes of this analysis: 

 Mechanical thinning and removal; 

 Mastication and hand cutting (used to treat only small trees, generally less than 

10 inches dbh); and 

 Underburning. 

The detailed descriptions of the prescriptions for the various treatment types are presented in 

Chapter 2 of this final EIS for the Eddy Gulch LSR Project. 

3.2.5.1 Alternative A: No Action 

Stand Structure 

Indicators: Basal Area, Stand Density Index, Tree Size, and Canopy Cover 

Direct and Indirect Effects. Maintaining the existing stand structure under Alternative A would 

favor shade-tolerant species such as white fir and incense-cedar. Currently, the older strata (midsuccessional / late-successional and late-successional) are densely stocked (Tables 3-6a, b, and c) and 

are starting to show signs of deterioration, as indicated by smaller crowns and minor to moderate tree 

mortality levels. With no treatment, these conditions would continue, with increasing levels of tree 

mortality during the 30-year analysis period (Table 3-7). 

SDIs for all strata are currently above the lower limit of self-thinning—60 percent SDI (refer to 

Table 3-3 above). Under Alternative A, SDIs would drop closer to the lower self-thinning level during 

the 30-year analysis period because stocking would be reduced as a result of tree mortality 

(Table 3-7). The exception is the mixed-conifer stands, where the SDI would still be well above the 

60 percent SDI level after 30 years. 
3-20 Chapter 3: Affected Environment and Environmental Consequences Table 3-6. Stand structure for M Units: comparison of current and 5- and 30-year stand data for Alternatives A, B, and C. Current Strata Data Table 3-6a. Summary of Current Conditions for Stand Structure Indicators (Basal Area, SDI, Tree Size, and Canopy Cover) Current Strata Data Table 3-6a. Summary of Current Cond

Indicators (Basal Area, SDI, Tree S

SAFa Forest Type CWHRb Seral Stage TPAc Total TPA >10”d BA/ace >10” Average dbhf >10” TPA >24” Canopy Cover (%) SDIg (this is for TPA Total) SAF Forest Type CWHR Seral Stage TPA Total TPA >10” BA/ac >10” Average dbh >10” 

DFh MSi 441 135 192 16.1 5 73 405 DF MS 441 135 192 16.1 

DF MS/LSj 235 120 249 19.5 20 72 425 DF MS/LS 235 120 249 19.5 

WFk MS 299 190 302 17.1 9 61 506 WF MS 299 190 302 17.1 

WF MS/LS 275 124 284 20.5 29 58 479 WF MS/LS 275 124 284 20.5 

RFl LS 613 113 350 23.8 43 59 643 RF LS 613 113 350 23.8 

MCm LS 255 159 320 19.2 28 69 453 MC LS 255 159 320 19.2 

Projected Strata Data Table 3-6b. Alternative A: Summary of Predicted Conditions in 5 Years Projected Strata Data Table 3-6d. Alternatives 

Predicted Conditions in 

SAF Forest Type CWHR Seral Stage TPA >10” BA/ac >10” Average dbh >10” TPA >24” Canopy Cover (%) SDI (TPA >10”) SAF Forest Type CWHR Seral Stage TPA >10” BA/ac >10” Average dbh >10” 

 DF MS 135 205 16.7 6 62 319 DF MS 68 140 19.4 

DF MS/LS 113 251 20.1 21 62 349 DF MS/LS 56 198 25.4 

WF MS 185 315 17.7 12 56 462 WF MS 80 201 21.4 WF MS/LS 122 296 21.1 29 52 404 WF MS/LS 53 208 26.9 

RF LS 111 357 24.3 43 49 461 RF LS 52 235 28.7 

MC LS 105 247 20.8 26 59 339 MC LS 57 206 25.7 

Projected Strata Data Table 3-6c. Alternative A: Summary of Predicted Conditions in 30 Years Projected Strata Data Table 3-6e. Alternatives 

Predicted Conditions in 

SAF Forest Type CWHR Seral Stage TPA >10” BA/ac >10” Average dbh >10” TPA >24” Canopy Cover (%) SDI (TPA >10”) SAF Forest Type CWHR Seral Stage TPA >10” BA/ac >10” Average dbh >10” 

 DF MS 117 246 19.7 21 65 345 DF MS 66 183 22.6 

DF MS/LS 94 267 22.8 26 62 354 DF MS/LS 55 226 27.5 

WF MS 145 355 21.2 36 56 484 WF MS 74 254 25.1 WF MS/LS 106 335 24.0 41 54 434 WF MS/LS 49 239 30.0 

RF LS 90 362 27.1 56 47 447 RF LS 48 255 31.3 

MC LS 88 249 22.7 27 58 330 MC LS 55 233 27.9 

Notes: a. SAF = Society of American Foresters b. CWHR = California Wildlife Habitat Relationship c. TPA = trees per acre d. > = greater than e. BA = basal area per acre f. dbh = diameter at breast height g. SDI = stand density index h. DF = Douglas-fir i. MS = mid-successional j. LS = 

k. WF = l. RF = m. MC = 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.2 – Forest Vegetation 3-21

Table 3-7. Eddy Gulch LSR strata data and stand structure: current, 30-year desired conditions, and 

30-year conditions post-thinning in M Units and with no treatment. 

Species Stand Structure 

Composition 

Strata Data Trees Greater Than 10 Inches dbh 

FVS Predicted 

30-year 

SAF Tree Mortality (per acre) a

Forest 

Type 

CWHR 

Seral 

Stage 

Desired 

Current 

SDI 

35%

All TPAb

Current 

SDI 

Desired 

SDIc 

at 30 

Years 

SDI 60% 

FVSd 

Predicted 

SDI at 30 

Years Post 

Thinning 

FVS 

Predicted SDI 

at 30 Years 

No Treatment 

Post 

Thinning 

No 

Treatment 

DFe MSf 210 405 ≤360 243 345 -2 -16 

DF MS/LSf 210 425 ≤360 279 354 -1 -19 

WFe MS 266 506 ≤456 323 484 -6 -40 

WF MS/LS 266 479 ≤456 284 434 -4 -16 

RFe LS 280 643 ≤480 298 447 -4 -21 

MCe LS 150 415 ≤258 285 355 -2 -71 

Notes: 

a. SAF = Society of American Foresters 

b. TPA = trees per acre 

c. SDI = stand density index 

d. FVS = Forest Vegetation Simulator 

e. DF = Douglas fir; WF = white fir; RF = red fir; MC = mixed-conifer 

f. MS = mid-successional; LS = late-successional 

Over the 30-year analysis period, species composition would change in the Douglas-fir strata, 

with the Douglas-fir percent increasing and the hardwoods decreasing. The decrease in the percent of 

hardwoods would be a result of increased competition from the dense conifer tree stocking. In the 

white fir strata, the percent of white fir would increase with a reduction in the amount of red fir. A 

major change from red fir to white fir would occur in the red fir stand. The mixed-conifer stand that is 

heavy with ponderosa pine would continue to increase the percent of ponderosa pine, basically 

changing to a ponderosa pine type (Table 3-8). 

The larger trees in the older strata (MS/LS and LS) are densely stocked and are starting to show 

signs of deterioration, as indicated by smaller crowns and minor to moderate tree mortality levels. 

These conditions would continue with increasing levels of tree mortality (Table 3-7). The smaller 

trees are heavily suppressed and mortality would be high. 

During the 30-year analysis period (without treatment), mortality would reduce the number of 

trees greater than 10 inches dbh per acre by 14–24 percent in Douglas-fir and true fir stands. The loss 

of trees would reduce the canopy cover by 4–12 percent. At 30 years, 45 percent of the trees greater 

than 10 inches dbh would have died in the mixed-conifer stands. The basal area would be reduced; 

however, the SDI would still be above the desired condition, meaning mortality would continue. In all 

stands, most trees that had died during the first 5–10 years would fall, thereby increasing ground 

fuels, while most of the remaining standing trees would increase ladder fuels (Tables 3-6a, b, and c). 

Basal areas would increase in all strata over the 30-year analysis period (without treatment), 

except in the mixed-conifer stands (Tables 3-6a, b, and c above). The basal area and number of larger 

trees (greater than 24 inches dbh) would increase as the residual trees continued to grow. The 

exception would be in the mixed-conifer stands where the high mortality would reduce the basal area 

and canopy cover. Any trees that died during this period would increase ladder fuels if they remain 

standing, and if they fall, would eventually increase large-material ground fuel loading.
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-22 Chapter 3: Affected Environment and Environmental Consequences

Table 3-8. Percent species by strata: current, no thinning, and with thinning. 

Strata / 

Year Treatment 

DouglasFir 

(%) 

White 

Fir 

(%) 

Red 

Fir 

(%) 

Ponderosa 

Pine 

(%) 

Sugar 

Pine 

(%) 

IncenseCedar 

(%) 

Hardwoods

(%) 

Douglas-fir – mid-successional 

2008 Current 67 5 14 

2038 No thinning 71 14 8 

2038 With thinning 60 15 20 

Douglas-fir – mid-successional / late-successional 

2008 Current 74 4 2 18 

2038 No thinning 83 3 5 5 

2038 With thinning 74 4 9 9 

White fir – mid-successional 

2008 Current 6 77 16 

2038 No thinning 76 23 

2038 With thinning 80 19 3 

White fir – mid-successional / late-successional 

2008 Current 6 73 15 3 

2038 No thinning 5 80 8 3 

2038 With thinning 9 68 8 6 

Red fir – late-successional 

2008 Current 20 80 

2038 No thinning 63 37 

2038 With thinning 51 49 

Mixed-conifer – late-successional 

2008 Current 12 70 18 

2038 No thinning 8 90 2 

2038 With thinning 23 69 8 

Canopy cover in all stands would drop 5–10 percent during the 30-year analysis period 

(Tables 3-6a, b, and c above) as a result of self-thinning or disturbance events. 

Comparison with Late-Successional Guidelines. The Douglas-fir stands and mixed-conifer 

stands currently exceed the basal area and canopy cover guidelines (refer to Table 3-4) contained in 

the forestwide LSR assessment (USFS 1999). 

For true fir stands, the forestwide LSR assessment only lists the stand basal area guidelines for 

stands located on north and east aspects. The canopy cover guidelines apply to all aspects and 

positions on the slope. Approximately 80 percent of true fir strata acres in M Units are located on 

south or west aspects. The true fir stands are currently at guideline levels. SDI calculations and field 

stand examinations indicate that minor to major amounts of tree mortality are occurring (the red fir 

stand being the worst). SDI data indicates that, with no treatment, tree mortality would increase 

during the 30-year analysis period (refer to Table 3-6). 

Effects from Disturbance 

Insects. Changes in insect activity usually are a result of stresses on a tree or stand. These 

stresses include overcrowding, drought–moisture stress, and fire. Until a stress factor exists, insect 

levels would remain at background, generally low, endemic levels. Current beetle activity is at or 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.2 – Forest Vegetation 3-23

below the average endemic level. Beetle population levels tend to be variable, depending on many 

factors, including weather and tree damage and health. It is anticipated that the beetle population 

levels would tend to increase with the anticipated reduction in tree vigor and increase in tree mortality 

under Alternative A. 

Diseases. Diseases also need a stress factor to occur at more than background levels, where 

individual or small groups of trees of low vigor are attacked. Cytospora and dwarf mistletoe are well 

established in portions of the Assessment Area. Cytospora will tend to decline as the diseased red fir 

trees slowly die out and are mostly replaced by white fir. Dwarf mistletoe would continue to affect 

tree vigor and mortality in portions of the Assessment Area, with a minor increase during the 30-year 

analysis period. Both sugar pine blister rust and fomes annosus are minor in scope and are projected 

to remain so during the 30-year analysis period. 

Wind and Snow Events. Wind and snow events have historically occurred in the Assessment 

Area and have caused variable levels of damage in the conifer stands. The heavy wind and snow 

events that occurred during the 2007/2008 winter season caused minor to moderate damage to several 

isolated stands. These events will continue to occur during the 30-year analysis period with 

unpredictable amounts of damage and increases in fuels. 

Effect of Climate Change. Climate change will increase temperatures, the length of the fire 

season, and the number of acres burned (Lenihan et al. 2006; Westerling and Bryant 2006). Increases 

in temperature would result in replacement of Douglas-fir forests with Douglas-fir-oak forests 

(Lenihan et al. 2006). An increase in fire season length would increase the number of acres burned 

and mortality in conifer stands, leading to conversion to brushfields. 

Changes resulting from temperature variations would likely be minor over the 30-year analysis 

period; however, changes in fire behavior could be substantial, dependent on the frequency and size 

of fires. Overall, the effects on the trees during the 30-year analysis period would be minor to 

moderate. 

Cumulative Effects. Most other actions that may occur in the future would have little effect on 

forest vegetation, when considered at the landscape scale. The stands would remain overstocked until 

sufficient mortality occurs as a result of self-thinning or a wildfire. Changes in stand characteristics 

that occur from self-thinning would vary depending on stand age and condition. The reduction in the 

number of trees per acre from self-thinning in the younger, mid-successional stands would be 

beneficial in that it would reduce tree competition for nutrients, water, and sunlight. A reduction in the 

number of trees per acre in the older, late-successional stands would be detrimental if the stocking 

drops below the desired stocking level. These changes would occur gradually over time and would be 

a minor to moderate benefit in the younger stands and a moderate to major adverse effect in the older 

stands. In either case, the tree mortality would create additional ground and ladder fuels that would 

contribute to fire severity in the stands. The moderate to major adverse effects resulting from a 

wildfire would be immediate and long term. 

Taking no action would affect each stratum and stand differently and at different times. Taking no 

action could eventually result in conditions that allow an insect or disease epidemic to occur. 

Different insects attack different species; for example, mountain pine beetles, western pine beetles, 

and Ips beetles (a genus of pine bark beetles) attack pine; Douglas-fir bark beetles attack Douglas-fir; 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-24 Chapter 3: Affected Environment and Environmental Consequences

and spruce bud worms and scolytus beetles attack Douglas-fir and true firs. All need specific 

conditions to weaken trees to the point that an epidemic can happen. Mixed-conifer and Douglas-fir 

stands are currently overcrowded. A multiyear drought could trigger an epidemic. 

Large high-intensity wildfires could create a breeding ground for insects or diseases to build to an 

epidemic level. These populations could then attack surviving trees that were weakened by the fire. 

With predictions for warmer temperatures and possibly less precipitation in the future, it would be 

more likely that insects would find more stressed trees to infest. 

Construction of a fuelbreak system west Black Bear Ranch would have no effect on stand 

conditions in the Assessment Area and alone would have little effect on reducing the size or intensity 

of a wildfire. 

Conclusion. The inter-tree competition that would continue under the no-action alternative 

would kill individual trees, resulting in long-term minor to moderate adverse effects at the landscape 

or ecosystem level. A wildfire would have immediate adverse effects that would continue over the 

long-term. A wildfire would have major adverse effects on individual stands burned by active crown 

fires, but the effects would be minor to moderate at the landscape level. In the long term, the 

increased mortality would increase fuels and contribute to higher-severity fires. The fires would result 

in substantially more mortality, which would result in long-term major adverse effects at the 

landscape or ecosystem level. Similarly, a drought that triggers an insect or disease epidemic would 

have long-term major adverse effects at the landscape or ecosystem level. 

3.2.5.2 Alternative B: Proposed Action and Alternative C: 

No New Temporary Roads Constructed 

Both action alternatives are addressed together because effects would be similar. Under 

Alternative C, approximately 99 fewer acres would be treated by mechanical thinning than under 

Alternative B because the 1.03 miles of new temporary roads would not be constructed. Maps 

showing the proposed treatment units under Alternatives B and C are contained in Appendix B of the 

Silviculture Report. 

Direct and Indirect Effects: Stand Structure 

Indicators: Basal Area, Stand Density Index, Tree Size, and Canopy Cover 

Mechanical Thinning and Removal in M Units. The thinning prescriptions (refer to Tables A-1 

and A-2 in the Silviculture Report) would reduce the SDIs of all strata to below or close to the 

35 percent SDI (lower limit of full site occupancy), except in the mixed-conifer stand. The 30-year 

projection of SDIs indicates that all strata (except mixed-conifer) would be below the lower limit of 

self-thinning (60 percent SDI) (refer to Tables 3-6d and e).

The mixed-conifer stand is an older, larger tree stand that is currently very heavy with ponderosa 

pine and sugar pine (88 percent). The 30-year projection is that the percent of Douglas-fir would 

increase from 12 to 23 percent. The actual SDI for the stand would then be higher, given the higher 

SDI for Douglas-fir. The 30-year SDI for the stand would probably be slightly above the 60 percent 

SDI. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.2 – Forest Vegetation 3-25

The thinning prescriptions would reduce the strata densities for trees greater than 8 inches dbh by 

increasing the average spacing between trees (Table 3-9). White fir, Douglas-fir, red fir, and incensecedar would be the primary species removed, but some ponderosa pine and a limited number of sugar 

pine may also be removed. 

Table 3-9. Average spacing between trees. 

Strata* / Year 

Alternative A 

No Action 

(tree spacing in feet) 

Alternatives B and C 

With Thinning 

(tree spacing in feet) 

DF MS

5 years 18 25 

30 years 19 26 

DF MS/LS 

5 years 20 28 

30 years 22 28 

WF MS

5 years 15 23 

30 years 17 24 

WF MS/LS

5 years 19 29 

30 years 20 30 

RF LS

5 years 20 29 

30 years 22 30 

MC LS

5 years 20 28 

30 years 22 28 

Note: *DF = Douglas fir MC = Mixed-conifer 

WF = White fir MS = Mid-successional 

RF = Red fir LS = Late-successional 

After thinning, the percent of Douglas-fir (refer to Table 3-8 above) in the young Douglas-fir 

strata would be reduced, with a corresponding increase in the percent of hardwoods as the thinning 

reduces the number of conifers per acre, which lessens the current competition with the hardwoods. 

The percent of Douglas-fir in the older strata would remain the same as the current percent of 

Douglas-fir. The amount of hardwoods would continue to drop as a result of the longer period of 

competition from the conifers, which has reduced the hardwood trees crown size and vigor. However, 

the amount of hardwoods would still be higher than under the no-action alternative. 

The largest trees in the M Units (refer to Tables 3-6a, d, and e above) would be retained, while 

generally the smaller trees would be removed, or if less than 8 inches dbh, would be thinned by 

underburning. Layering would be reduced. Five years after treatment, the number of trees greater than 

10 inches dbh would be reduced (compared to the current stands) by 48 to 58 percent in Douglas-fir 

and true fir stands and 65 percent in mixed-conifer stands. This would reduce the basal area but 

increase the average dbh in each stand. Trees greater than 24 inches dbh would remain the same or 

increase, except in the red fir stands, where the number would decline by 25 percent as a result of 

thinning the clumps of larger trees. Canopy cover would be reduced, and the desired SDI would be 

achieved. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-26 Chapter 3: Affected Environment and Environmental Consequences

There would be little change in the number of trees greater than 10 inches dbh 30 years after 

treatment compared to the number of trees 5 years after treatment. However, the basal area, average 

dbh, and number of trees greater than 24 inches dbh would increase in all stands as a result of reduced 

competition and higher growth rates. The desired SDI would be achieved in all stands, except mixedconifer. 

The thinning treatments would reduce the strata densities for trees greater than 10 inches dbh by 

increasing the average spacing between trees (refer to Table 3-9 above). Ladder fuels would be 

reduced as a result of thinning from below to remove materials greater than 8 inches dbh. Tree 

mortality for the 30-year analysis period would be greatly reduced (refer to Table 3-7 above). 

The thinning treatments would reduce the basal areas in all strata (refer to Tables 3-6a, d, and e

above). The basal areas would continue to be less than they would under the no-action alternative 

during the 30-year analysis period. 

The thinning treatments would initially reduce canopy cover by 15 to 20 percent (refer to 

Tables 3-6a, d, and e above), but it would increase back to the 40 to 55 percent range within the 

30-year analysis period. The exception is the older, very decadent red fir stand that is heavily infested 

with cytospora and dwarf mistletoe. The proposed thinning would reduce the canopy cover by 

approximately 25 percent and remain at that level during the 30-year analysis period. 

Comparison with Late-Successional Guidelines. The Douglas-fir and mixed-conifer stands 

would meet the forestwide LSR assessment guidelines for basal area and canopy cover at 5 years 

post-treatment, as shown in Table 3-10. The exception is the younger Douglas-fir mid-successional 

strata basal area. These strata would meet the basal area desired conditions within 30 years. 

Table 3-10. Desired conditions for forest stands on the upper third of slopes compared with stand 

conditions at five years post-treatment. 

Klamath Forestwide LSR Assessment 

Desired Conditions 

Eddy Gulch LSR 

Alternatives B and C at Five Years Post-Treatment 

Forest Type 

(Aspect) 

Basal Area 

(square feet per acre) 

Canopy Cover

(percent) 

Forest Type 

(Successional Stage)

Basal Area 

(square feet per acre) 

Canopy Cover

(percent) 

DFa (NEb) 185–220 40–60 DF (MSe) 140 48 

DF (SW)c 160–195 30 DF (MS / LSf) 198 50 

MCd (SW) 210–245 25 MC (LS) 206 50 

WFg (MS) 201 37 

WF (MS / LS) 208 38 

True Fir (NE) 300 40–60 

RFh (L / S) 235 32 

WFg (MS) 201 37 

WF (MS / LS) 208 38 

True Fir (SW) No data No data 

RFh (L / S) 235 32 

Notes: 

a. DF = Douglas-fir f. LS = late-successional 

b. NE = northeast g. WF = white fir 

c. SW = southwest h. RF = red fir 

d. MC = mixed-conifer e. MS = mid-successional 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.2 – Forest Vegetation 3-27

The true fir stands (white fir) are close to the canopy cover guideline level (in the forestwide LSR 

assessment) for shaded fuel breaks (the FRZs). The red fir stands would be approximately 8 percent 

below the guidelines due to the advanced tree mortality already occurring in the stand. The basal area 

levels would be approximately 20 to 30 percent below the late-successional habitat guideline. The 

lower basal area level is prescribed to meet the tree spacing objective for FRZs. 

The prescribed lower values for stand attributes in white fir and red fir stands in the Eddy Gulch 

LSR are more consistent with descriptions of stand characteristics prior to European settlement 

(Taylor and Skinner 1998). They contribute to increasing resistance to wildfires (Millar et al. 2007), 

particularly by reducing the probability of passive and active crown fires. The prescribed lower values 

would also contribute to lower mortality as the climate becomes warmer in the future. 

Mastication and Hand Cutting. The mastication and hand cutting treatments proposed under 

Alternatives B and C would be located on slopes less than 45 percent. The treatment would involve 

trees less than 10 inches dbh. The number of trees per acre would be reduced, leading to a reduction 

in inter-tree competition. The effect on canopy cover would be minor. 

Underburning. Underburning would be used on slopes greater than 45 percent in the FRZs and 

in the Rx Units to remove trees less than 4 inches dbh. These treatments would reduce fuel hazards 

but would not affect the species composition, average tree size, or have little effect on canopy cover. 

Effects from Disturbance 

Insects. Current beetle activity is at or below the average endemic level. Beetle population 

levels tend to be variable, depending on many factors, including weather, tree damage, and health. 

The thinning treatments would reduce inter-tree competition and the potential for tree mortality by 

removing most of the trees that are projected to die in the no-treatment 30-year analysis. Long-term 

beetle activity in these stands would be less than under the no-action alternative due to the reduction 

in inter-tree competition. All treatments would contribute to increased tree vigor over the long term—

a beneficial effect—which would reduce the probability of insect attack. However, there could be a 

short-term increase in insect activity immediately after thinning, resulting from an increase in recently 

down fuels (logging slash and/or trees killed by underburning). 

Disease. All treatments would increase tree vigor. This would result in a reduced probability of 

successful insect attack—a beneficial effect. However, if thinning and mastication are not done 

carefully, mechanical injuries to residual trees could result in pathogens attacking these trees. The 

thinning prescriptions would remove a large number of red fir infected with cytospora and dwarf 

mistletoe. The remaining infected red fir would continue to slowly deteriorate as additional branches 

die and until the trees weaken to the point where mortality occurs. The mortality level during the 

30-year analysis period would be minor. The thinning treatments would not change the status of the 

blister rust from the no-action alternative. 

Implementation of the thinning treatments would increase the possibility of fomes annosus 

infections in the true fir stands through the creation of stumps and some residual tree bole damage. 

Tree growth would be slowed if infections occurred, but any associated tree mortality would mostly 

occur beyond the 30-year analysis period. The affects would be within the habitat objectives for an 

LSR. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-28 Chapter 3: Affected Environment and Environmental Consequences

Wind and Snow Events. The thinning treatments would result in more open stands, and 

depending on location, the residual trees would be more exposed to the wind. Field observations by 

the silviculturist during the 2008 field season indicate that previously thinned stands have a minor 

increase in damage when compared to stands that have not been thinned. 

Climate Change. The thinning treatments would reduce inter-tree competition—a beneficial 

effect—which would help reduce the effects of climate change on these stands. This could reduce the 

overall affects on the treated stands to a minor level during the 30-year analysis period. 

Cumulative Effects. The ongoing and future projects would have little to no effect on forest 

vegetation in the Assessment Area. 

Conclusion. Mechanical thinning, mastication, and underburning would all result in a major 

improvement in the health and vigor of residual trees at a landscape or ecosystem scale; therefore, 

beneficial effects would be moderate to major over the long term. Mechanical thinning, especially, 

would create more open stands, which would reduce the potential for crown fires and which would be 

more similar to stand conditions that occurred prior to European settlement, thus mimicking historic 

disturbance patterns. The M Units would be located along ridgetops, where the most open stands were 

historically located. Each treatment would affect the stands to different degrees, increasing tree 

species diversity in stands in the Assessment Area. Mechanical thinning would reduce current basal 

area stocking by 25 to 45 percent and canopy cover by about the same amount. Mastication and 

underburning would reduce basal area by about 2 to 13 percent, with a minor change to canopy cover. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.3 – Fires, Fuels, and Air Quality 3-29

3.3 Fire, Fuels, and Air Quality _____________________________ 

3.3.1 Introduction 

This document summarizes forest fuels and fire behavior in the Eddy Gulch Late-Successional 

Reserve (LSR) Project Assessment Area. The description includes the historical fire regime, current 

fuel hazards and resulting fire behavior, and the effects from taking no action (Alternative A) or from 

implementing Alternative B (Proposed Action) or Alternative C. This document also discusses the 

current air quality status for Siskiyou County and the potential effects on air quality from taking no 

action or from implementing the project under either action alternative.

3.3.2 Methodology: Fire and Fuels 

3.3.2.1 Analysis Methods and Assumptions 

Stewardship Fireshed Analysis. Initially, a number of key documents were reviewed to 

understand the fuel conditions and fire potential in the Eddy Gulch LSR Project Assessment Area; 

those documents include the Klamath Land and Resource Management Plan (Klamath LRMP) (USFS 

1995), Klamath National Forest Forestwide Late-Successional Reserve Assessment (forestwide LSR 

assessment) (USFS 1999), Salmon River Community Wildfire Protection Plan (CWPP) (2007), Black 

Bear (2002) and Rainbow (2003) Cooperative Fire Safe Plans, Klamath National Forest Fire 

Management Plan (2004), and historic reference conditions for the Eddy Gulch LSR. The 

interdisciplinary (ID) team’s fuels specialists reviewed line officer direction and currently proposed 

and past fuels treatment projects and silvicultural projects within the Eddy Gulch LSR Assessment 

Area, the remainder of the LSR, and adjacent areas that could impact or be impacted by fuel 

treatments or wildfires. 

A Stewardship Fireshed Analysis (SFA) (Callenberger and Henderson 2008, see Attachment 1 of 

the fuels report) for the Eddy Gulch LSR Project was conducted to evaluate weather patterns, identify 

fire behavior and protection targets, and test and evaluate treatments. The evaluation area included the 

former boundary of the old Salmon River Ranger District. Field work in 2007 and 2008 involved 

gathering data for the SFA and evaluating potential protection targets, potential fuel treatment 

patterns, and roadside fuel treatments for safe ingress for suppression forces and egress by residents 

during a wildfire. The field work included inventories of dead and down (ground) fuels, ladder fuels, 

and crown fuels in 50 plots scattered throughout the Assessment Area (Table 3-11). These plots were 

used to select the appropriate fuel models used in fire behavior modeling, which was used to assess 

fire behavior potential before and after treatment and at 20 years post-treatment. 

After stand inventories were completed and analyzed using the Forest Vegetation Simulator 

(FVS), information from FVS and the fuel profile inventories (data plots) were used to evaluate 

prescriptive fire treatments that could be implemented to meet project objectives (see Section 3.2

above or the Silviculture Report for more information about FVS.) Numerous fire modeling tools 

were used for the analysis: 

 All current fire behavior indicators and crown bulk density were calculated with FMAPlus; 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-30 Chapter 3: Affected Environment and Environmental Consequences

Table 3-11. Examples of fuel models that represent a majority of the Assessment Area and 

pose the high hazard in the Assessment Area. 

Fuel Model TU5(165): Very High Load 

Dry Climate Timber Shrub 

The primary carrier of fire is heavy forest litter 

with a shrub or small tree understory.

Fuel Model TL3(183): Moderate Load 

Conifer Litter 

The primary carrier of fire is moderate load 

conifer litter.

Fuel Model SH2(142): Moderate Load 

Dry Climate Shrub 

The primary carrier of fire is woody shrubs 

and shrub litter.

 Fire behavior in the Assessment Area was simulated using 90th percentile weather 

conditions and Fire Management Analyst, Nexus, Behave, FARSITE, and FLAMMAP; fire 

behavior indicators at 20 years were calculated with FVS–fire and fuels extension; 

 Fire types were calculated with FLAMMAP; and 

 Spatial analysis of fires was calculated with FARSITE (a fire and growth simulator). 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.3 – Fires, Fuels, and Air Quality 3-31

Weather inputs were developed at a fireshed workshop attended by the USDA Forest Service 

Region 5 Stewardship Fireshed Assessment Team, the fire management staff for the Salmon River 

and Scott River Ranger Districts, and the ID team (fire and fuels, silvicultural, and wildlife 

specialists). Fire behavior in the Assessment Area was simulated using 90th percentile weather 

conditions and Fire Management Analyst, Nexus, Behave, FARSITE (a fire and growth simulator), 

and FLAMMAP. Weather data for fire behavior modeling included the hourly wind files from the 

Blue Ridge Remote Automated Weather Station (RAWS) for July 23–30, 2006. After consultation 

with local fire and fuels experts, the 90th percentile weather was modified by increasing wind speeds 

because higher wind velocities influenced fire behavior during recent wildfires and would be 

expected ahead of and after weather fronts and thunderstorms. Fuel moisture levels were developed 

using 90th percentile weather data from the Blue Ridge RAWS from July 1 through October 31, 

2006—the primary fire months. Fire behavior information from three large fires (Uncle, Hancock, 

and Rush fires) that occurred in 2006 were used to validate the model results. The Uncle, Hancock, 

and Rush fires were used because of the availability of sufficient fire behavior data, as well as 

weather data. Also, the Forest Service fire specialist considers these fires to be typical examples of the 

current fire behavior. 

The data produced for the Eddy Gulch LSR SFA are used throughout this report and were crucial 

for 

 identifying the problem fire for the LSR based on fuels, weather, and topography and for 

articulating the need for the Eddy Gulch LSR Project; 

 identifying protection targets; and 

 designing and testing fuel treatments (which ultimately became the Proposed Action 

described in this final EIS) and patterns and displaying trade-offs. 

During spring and summer of 2008, potential fire behavior was reviewed by the ID team, and the 

fuels team conducted additional field surveys to review and validate fuel models and fuel hazards. 

Prescriptions and fuel reduction treatments were also reviewed during the field reconnaissance. 

Protection Targets. One objective of the SFA for the Eddy Gulch LSR Project was to 

identify community, cultural, and natural resources that should be protected—these are referred to as 

“protection targets” (refer to Table 3-12). These targets are based on protection of life and property 

first and then other high-value resources identified by the ID team, United States Fish and Wildlife 

Service (USFWS), and Salmon River CWPP. These targets are of critical concern to the public and 

agencies (such as the Forest Service, CalFire, and volunteer fire departments) tasked with providing 

fire protection inside the Klamath National Forest. 

Table 3-12. Examples of protection targets identified in the SFA. 

Protection Target 

Public Safety and Infrastructure: Provide safe travel routes for the public and suppression forces; provide 

protection of infrastructure and municipal watersheds. 

Other High-Value Resources: Private lands, northern spotted owl (NSO) core areas, late-successional habitat 

characteristics (and especially “remnant” old-growth stands); Key Watersheds, including areas of latesuccessional habitat that could sustain late-successional characteristics. 

Plantations: Represent previous Forest Service investments in maintaining forest cover in the Eddy Gulch LSR. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-32 Chapter 3: Affected Environment and Environmental Consequences

Public Safety and Infrastructure—Cecilville and Sawyers Bar are listed in the Federal 

Register (2001) as communities at risk from a wildfire. Both communities are located within 

1.5 miles of the LSR. The Salmon River CWPP identifies domestic watersheds and infrastructure 

improvements that are either in the LSR or potentially threatened by fire events coming from the 

LSR.1 The CWPP also identifies roads that pass through the LSR as important for serving as 

emergency access routes to evacuate residents and bring in suppression resources in the event of a 

large fire threatening the communities. The nearby community of Forks of Salmon and its 

infrastructure could also be threatened by fire events outside of or emanating from the LSR. 

Other High-Value Resources— 

 Private lands, NSO core areas, late-successional habitat characteristics (and especially 

“remnant” old-growth stands. The results of FLAMMAP modeling show that all NSO 

activity centers, either partially or entirely within the Assessment Area, are susceptible to 

either passive or active crown fire (see the Wildlife and Habitat Report for the Eddy Gulch 

LSR Project). Fuel hazards can rapidly increase due to several types of natural disturbance 

(such as insect infestations, diseases, blow down, fires, or any combination of natural 

disturbances, including drought), thereby rapidly increasing the potential for an escaped 

fire in the LSR. Late-successional stands are generally resistant to stand-replacing fires; 

however, threats still remain to individual trees where heavy lavers of bark sluff and duff 

around the base can increase temperatures of fires and tree mortality. 

 Key Watersheds. According to the Salmon River CWPP (SRFSC 2007), the Salmon River 

Key Watershed is the highest wildfire risk watershed in the Klamath Basin, and the Eddy 

Gulch LSR is a part of that watershed. An analysis completed for the CWPP found that 

over 408,000 acres of the 480,000-acre Salmon River Key Watershed have burned since 

1910 (SRFSC 2007). 

Plantations—There are approximately 3,900 acres of plantations that were planted between 

1963 and 1990 in the Eddy Gulch LSR (Table 3-13). The stands in plantations are more susceptible to 

stand-replacing intensities because the lowest limbs of these younger trees are generally less than 

4 feet above the ground fuels. 

Table 3-13. Plantations inside and outside the Eddy Gulch 

LSR Assessment Area. 

Locations of Plantations Acres 

Eddy Gulch LSR (including Assessment Area) 3,918 

Assessment Area 3,493 

In 1,320-foot LSR Buffer 889 

 

1. The Salmon River Fire Safe Council sponsored development of the Salmon River CWPP (SRFSC 2007). Cooperators on 

the CWPP include community members, the U.S. Forest Service, CalFire, other managing agencies, Karuk Tribe, Salmon 

River Volunteer Fire and Rescue, Orleans/Somes Bar Fire Safe Council, and Salmon River Restoration Council. Starting in 

December 2000, the Salmon River Fire Safe Council held monthly meetings to deal with many issues, including 

development of detailed community and neighborhood fire safe plans; water tanks and hydrant systems; water source 

(tanker fill sites) identification, mapping, and signing; road signing; private properties universal number signage; helispot 

location and mapping; community outreach and education; training; and general cooperation and information sharing with 

stakeholders and agencies. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.3 – Fires, Fuels, and Air Quality 3-33

3.3.2.2 Scope of the Analysis 

Analysis Area. The analysis area for fire and fuels analysis (Map A-1 in Appendix A of this 

report) includes the entire Eddy Gulch LSR Project Assessment Area; the communities of Cecilville, 

Sawyers Bar, and associated WUI areas that are included in the Salmon River CWPP; and hazardous 

conditions outside the LSR. 

Analysis Period. Fire behavior was modeled for current conditions, immediately after treatment, 

and at 20 years after treatment.

3.3.2.3 Intensity of Effects 

“Intensity” refers to the severity of effects or the degree to which the action may adversely or 

beneficially affect a resource. The intensity definitions used throughout this effects analysis are 

described below. 

Negligible. Effects would be at the lowest levels of detection and would have no appreciable 

effect on resources, values, or processes. 

Minor. Effects would be perceptible but slight and localized. 

Moderate. Effects would be readily apparent and widespread and would result in a noticeable, 

but temporary, change to resources, values, or processes. 

Major. Effects would be readily apparent and widespread and would result in a substantial 

alteration or loss of resources, values, or processes and would likely be permanent. 

3.3.2.4 Measurement Indicators 

Three indicators were used to assess current conditions and the effects of the forest fuel 

treatments: ground fuels, ladder fuels, and crown fuels. Changes in each indicator were quantified 

with measurements of fuel conditions or fire behavior (Table 3-14). Additionally, other indicators 

were used to determine how well an alternative met the purpose and need, including acres resistant or 

resilient to a wildfire, fire type, acres of fuelbreak constructed, miles of emergency access route 

treated, and acres of wildland urban interface treated. 

Table 3-14. Indicators and their measurements to describe 

effects among the alternatives. 

Indicator Measurement 

Ground fuels Fuel load, flame length, or rate of spread 

Ladder fuels Crown base height 

Crown fuels Crown bulk density 

Indicator: Ground Fuels— 

Measurement: Fuel load. The weight of dead and down woody fuel measured in tons peracre. The weight of standing brush tree boles and foliage can also be predicted if all or a portion is 

expected to be added to the dead and down fuel loading. Fuel loading is used to predict fire behavior 

by using the current and expected fuel loading to select the correct fuel model to use in fire behavior 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-34 Chapter 3: Affected Environment and Environmental Consequences

prediction systems. Components of fuel loading include fuel sizes and their proportion, arrangement, 

and continuity. Total fuel is all fuel, both living and dead, present on a site. Available fuel is the 

amount of fuel that will burn under a specific set of fire conditions. 

 Measurement: Flame Length. This is the length of flame measured in feet, from the base of 

the flame to the tip of the flame. Longer flame lengths increase resistance to control and the 

likelihood of torching events and crown fires. Flame length is influenced by fuels; weather and 

topography; fuel moisture volume in ton per-acre; and the type of fuel, dead and down or live; and 

presence of volatile resins in living vegetation, which are not a factor in this area. Other important 

influences are arrangement and continuity of fuels. A compact layer of ground fuel burns hot but the 

flame length is shorter than a fuel bed that is not compact. When flame lengths are long enough to 

ignite brush and small trees, torching of the largest trees becomes possible and flame lengths will 

increase dramatically. As illustrated in Table 3-15, increasing flame lengths above 4 feet may present 

serious control problems to firefighters, they are too dangerous to be directly contained by hand crews 

(Schlobohm and Brian 2002; Anderson 1982). Flame lengths over 8 feet are generally not controllable 

by ground-based equipment or aerial retardant and present serious control problems, including 

torching, crowning, and spotting. 

Table 3-15. Relationship between flame length and potential for success of active suppression. 

Flame Length Description 

Less than 4 feet Fires can generally be attacked at the head or flanks by firefighters using hand tools. A hand line 

should hold the fire. 

4–8 feet Fires are too intense for direct attack at the head with hand tools. A hand line cannot be relied on to 

hold the fire. Bulldozers, engines, and retardant drops can be effective. 

8–11 feet Fire may present serious control problems, such as torching, crowning, and spotting. Control efforts 

at the head will probably be ineffective. 

Greater than 11 feet Crowing, spotting, and major fire runs are probable. Control efforts at the head of the fire are 

ineffective. 

Source: NWCG 2004. 

Measurement: Rate of Spread. Rate of spread is the horizontal distance that the flame zone 

moves per unit of time (feet per minute) and usually refers to the head fire segment of the fire 

perimeter. It is directly related to the amount of heat received by the fuels ahead of the flaming zone, 

and the heat is a function of the energy release rate per unit area of fire front. Rate of spread is 

strongly influenced by fuels, winds, and topography—it generally increases with increasing wind 

speed, slope, and amount of fine fuels. 

Indicator: Ladder Fuels— 

 Measurement: Crown Base Height. Crown base height (CBH) is the distance from the 

ground to the lowest limbs of conifers or hardwoods. It indicates at what flame length trees will torch. 

When small trees or brush torch, they frequently serve as a catalyst that causes larger adjacent trees to 

torch up to the largest trees. Fuel loading, low CBHs and dense stands of trees are high risk areas for 

torching and active crown fire. Dense stands of conifers with low CBHs are indicative of the absence 

of natural-occurring fires or prescribed fire and usually include high numbers of white fir that can 

germinate and grow in shady conditions—this is referred to as shade-tolerant, fire-intolerant species. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.3 – Fires, Fuels, and Air Quality 3-35

Indicator: Crown Fuels— 

Measurement: Crown Bulk Density. Crown bulk density (CBD) measures the amount of 

fuel in the crowns of individual trees or stands. High CBD indicate crown fires are readily propagated 

through the entire stand. 

3.3.3 Affected Environment (Existing Conditions): Fire and Fuels 

3.3.3.1 Fire Regime Condition Class 

Fire Regime Condition Class (FRCC) is a classification of the amount of departure from the 

natural (historical) fire regime and is important for comparing pre-European conditions with current 

conditions in the Eddy Gulch LSR. Appendix B of the Fuels and Air Quality Report provides an 

explanation of FRCC as described by the National Interagency FRCC and the Landscape Fire and 

Resource Management Planning Tools Project (LANDFIRE) groups. Descriptions of the departure 

from the historic pattern in the Eddy Gulch LSR are based on earlier work by Taylor and Skinner 

(1998) and Skinner et al. (2006) and more recent work by M. Creasy (unpublished report for the 

Northern Province Ecology Program, June 24, 2008). 

FRCC 3 makes up 67 percent of the Eddy Gulch LSR (Table 3-16) and is described as, “Fire 

regimes have been significantly altered from their historical range.” Under FRCC 3, the risk of losing 

key ecosystem components is high. Fire frequencies have departed from historical frequencies by 

multiple return intervals—this results in dramatic changes to one or more of the following: fuel 

composition and fire size, frequency, intensity, severity, and pattern. Vegetation attributes have been 

significantly altered from their historical range. While the increased stand density and downed wood 

associated with this alteration can be desirable for some late-successional forest-related species, the 

NSOs and other species in the California Klamath Province have been shown to be more adapted to 

this area’s naturally frequent, low-intensity fires than individuals in the more northern provinces of 

the NSO’s range. 

Table 3-16. Percent of acres within each FRCC, Eddy Gulch LSR. 

Condition Class Acres Percent of the Area 

1 2,890 4.6 

2 17,763 28.4 

3 41,957 67.0 

 62,610 100.0 

Note: The Eddy Gulch LSR is approximately 62,650 acres. The acres in FRCC 

total about 62,610. There is an approximate 40-acre discrepancy because some 

polygons were not included in the FRCC data. 

Approximately 28 percent of the Eddy Gulch LSR is in FRCC 2, which is described as, “Fire 

regimes have been moderately altered from their historical range.” In these areas, the risk of losing 

key ecosystem components has increased to moderate. Fire frequencies have departed (either 

increased or decreased) from historical frequencies by more than one natural Fire Return Interval (see 

Appendix B of the Fuels and Air Quality Report “Fire Regime Condition Class Definition”). This can 

result in moderate changes to one or more of the following: fuel composition and fire size, frequency, 

intensity, severity, and pattern. Vegetation attributes have been moderately altered from their 

historical range. Approximately 5 percent of the Eddy Gulch LSR is in FRCC 1, where the current 

fire regime is similar to the historic regime. Conversely, 95 percent of the LSR has substantially 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-36 Chapter 3: Affected Environment and Environmental Consequences

departed from the historic fire regime, making the Assessment Area at significant risk of losing key 

ecosystem components. 

3.3.3.2 Fire Risk and Fire Hazard 

The likelihood of future fires causing unacceptable resource damage is influenced by two factors: 

fire risk and fire hazard. Fire risk is the probability of a fire occurring in the LSR and is based on 

historic fire records. Fire hazard, on the other hand, is dependent upon fuel conditions, including the 

accumulation of dead and living vegetation and fire weather. Under historic fire return intervals, fuel 

accumulation would be considerably less than current levels. A particular area may have a low 

historic risk of fire occurrence, but the fuel hazard, and thus fire severity, may be high enough in the 

LSR to result in unacceptable lethal levels of vegetation mortality (lethal effects are those where fires 

result in greater than 70 percent mortality) (USFS 1999). 

Figure 3-5 shows that from 1970 to 2005, the number of fires in the Salmon River and Scott 

River Ranger Districts ranged between 25 and 120 annually, and the number of acres burned 

exceeded 100,000 acres. The majority of fires occur during July and August, and these fire starts are 

primarily ignited by lightning strikes and quickly contained at less than 0.2 acre. Fire occurrence in 

the Eddy Gulch LSR is 0.69 fire per thousand acres per decade (USFS 1999:2-12), or about 4.3 fires 

in the LSR per year. The current fire risk is rated as “moderate,” meaning that at least one fire would 

be expected to occur in 11 to 20 years per thousand acres. With a risk rating of moderate, the potential 

exists for 62 fire starts in the Eddy Gulch LSR during the next 20 years (USFS 1999:2-44). 

There is evidence that suppression has affected the number of acres burned on the Salmon River 

and Scott River Ranger Districts. Since 1920 there has been an almost continuous reduction in the 

number of acres burned per decade by fires (0.3–299.9 acres) (Figure 3-6). During the same period, 

there appears to be an increase in the number of acres burned by fires greater than 300 acres. This 

demonstrates that successful suppression of fires has contributed to an accumulation of fuels that, 

when ignited, result in larger fires. 

3.3.3.3 Current Fuel Conditions 

Fire behavior describes how a fire burns, where it burns, how fast it travels, how much heat it 

releases, and how much fuel it consumes. It is important to understand what controls fire behavior 

and how to predict it because this knowledge helps predict fire effects, conduct prescribed burns, 

predict wildfire risk, and control wildfires. 

Fire behavior is controlled by three interacting components: fuels, weather, and topography. Fuels 

provide the energy source for fire. Fuel availability, which depends on both fuel arrangement and fuel 

moisture, determines if fires will burn as surface or crown fires. Weather elements, such as 

temperature, relative humidity, wind, precipitation, and atmospheric stability, also combine to 

influence fire behavior by regulating fuel moisture and rate of spread. Topography can influence fire 

indirectly, by mediating wind patterns, or directly—fires burning upslope spread faster than fire 

burning on flat land. 

Current conditions, as described by the fire and fuel indicators and their measurements (obtained 

from field surveys and modeling) are described in Table 3-17. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.3 – Fires, Fuels, and Air Quality 3-37

Figure 3-5. Fires in the Salmon River and Scott River Ranger Districts from 1970 to 2005. 

Notes: Fire Size Classes 

A = 0–0.2 acre B = 0.3–9.9 acres C = 10–99.9 acres D = 100–299.9 acres 

E = 300–999.9 acres F = 1,000–4,999.9 acres G = 5,000 acres plus 

Fire Cause Class 1 is lightning; 2–9 are various human causes. 

“Fires per fire day” is the number of fires burning on any day with wildfires. Thus, of the 833 days experiencing one or more 

wildfires during the 1970 to 2005 time period, there were 572 days with only a single fire. There were also 31 days, nearly 

once per year average, with 10 or more fires burning on the same day. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-38 Chapter 3: Affected Environment and Environmental Consequences

Figure 3-6. Changes in fire size on the Salmon River and Scott River Ranger Districts since 1920. 

Table 3-17. Fire and fuels indicators and their measurements. 

Indicator Measurement Current Conditions 

Fuel Load 1-hour fuels: 0.5–3 tons/acre 

10-hour fuels: 1–3 tons/acre 

100-hour fuels: 2–8 tons/acre 

1,000-hour fuels: 5–30 tons/acre (not tracked) 

Flame Length 11–20 feet 

Ground Fuels 

Rate of Spread 30–60 feet per minute 

Ladder Fuels Crown Base Height 2–15 feet 

Crown Fuels Crown Bulk Density 0.131–0.351 kilograms/cubic meter (kg/m3) 

Measurement: Fuel Load. In the Assessment Area, fuel loading of dead fuels less than 1 inch in 

diameter range from 0.5 to 3 tons/acre, and loading of dead fuels 1–3 inches in diameter range from 

2 to 8 tons/acre. The accumulation of ground fuels in the Assessment Area results from the fact that 

less than 10 percent of the entire LSR has burned in wildfires since 1955. Fuel loads are lower in 

areas where prescribed burning has recently occurred (Blue Ridge Lookout to Lafayette Point). 

Measurement: Flame Length. Given the parameters described above, predicted flame lengths 

during a wildfire would range from 11 to 20 feet in the Eddy Gulch LSR. The simulated flame lengths 

and acres potentially burned in the LSR have implications to suppression capabilities. These data can 

be used to estimate the probability that a fire could be contained by initial attack by comparing flame 

length outputs with the Fire Characteristics Chart (Andrews and Rothermel 1982) and a simplified 

adjective rating with suppression implications—the fire adjective rating chart is presented in 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.3 – Fires, Fuels, and Air Quality 3-39

Table 3-18 below. Assuming all fires with less than 3-foot flame lengths could be contained, fires 

with flame lengths of 3 to 7 feet may have a good chance of containment, and all fires with flame 

lengths longer than 7 feet could not be contained by initial attack. Initial attack by the closest 

suppression forces is critical to initial attack strategies, as resistance to control increases exponentially 

as fire perimeters and fire behavior increase. 

Table 3-18. Fire adjective rating chart. 

Adjective 

Rating 

Flame 

Length 

(feet) 

Acreage and 

Percent in 

Assessment Area Suppressions Implications 

Low 0–1 127 <1% Fire will burn and spread; however, very little resistance to control and 

direct attack with firefighters is possible. 

Moderate 1–3 8,340 14% Fire spreads rapidly, presenting moderate resistance to control but can be 

countered with direct attack by firefighters. 

Active 3–7 5,937 9% Fire spreads very rapidly, presenting substantial resistance to control. 

Direct attack with firefighters must be supplemented with equipment and/or 

air support. 

Very 

Active 

7–15 47,025 75% Fire spreads very rapidly, presenting extreme resistance to control. Indirect 

attack may be effective. Safety of firefighters in the area becomes a 

concern. 

Extreme >15 154 <1% Fire spreads very rapidly, presenting extreme resistance to control. Any 

form of attack will probably not be effective. Safety of firefighters in the area 

is of critical concern. 

Note: > greater than. 

 < less than.

There are potions of the Assessment Area that are inaccessible, with dense vegetation and steep 

topography that slows travel for firefighters and affects containment success. As shown on 

Table 3-18, fires in 15 percent of the Assessment Area could be contained, fires in 9 percent of the 

area may have a good chance of containment, while 76 percent would not be contained. These 

containment percentages correlate to the percentages in the third column of Table 3-18 and the 

corresponding adjective ratings. For example, 15 percent containment would be an adjective rating of 

“moderate” The results shown in Table 3-18 for the Assessment Area differ from those predicted in 

the forestwide LSR assessment (USFS 1999), where it was estimated that 66 percent could be 

contained and 26 percent could not be contained. The reason for this variation in containment 

percentage is due to the site-specific data gathered in 2007 and 2008 for the Eddy Gulch LSR Project, 

the availability of more sophisticated modeling tools, and the increase in vegetative growth and fuel 

loading over the past 10 years since the forestwide LSR assessment was prepared. 

Measurement: Crown Base Height. CBH ranges from 2–15 feet, the result of mature brush in 

lower elevation stands and growth of small conifers and hardwoods throughout the LSR. The low 

crown base height throughout the LSR is a major factor leading to the higher percentages of crown 

fires now predicted in the LSR. 

Measurement: Crown Bulk Density. CBD is a measurement generated by modeling stand 

structure. The current values indicate crown fires would be readily supported in the Eddy Gulch LSR. 

Fire Behavior Throughout the LSR. An earlier analysis (forestwide LSR assessment [USFS 

1999]), showed that approximately 8 percent of the Eddy Gulch LSR would have an active crown fire 

and approximately 39 percent would have a passive crown fire, or a total of 47 percent crown fire. In 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-40 Chapter 3: Affected Environment and Environmental Consequences

this analysis for the Eddy Gulch LSR Project, FLAMMAP model runs (using the Standard Fire 

Behavior Fuel Models 2005) show that, under 90th percentile weather conditions (2–3 mile per hour 

eye-level winds), approximately 46 percent of the LSR would experience a surface fire and 

54 percent would experience crown fire (Table 3-19, also refer to Map A-3a in Appendix A of the 

Fuels and Air Quality Report). When only the eye-level wind speeds were increased to 3–6 miles per 

hour (as observed on ridgetops in the LSR and during the 2006 Uncles, Hancock, and Rush fires) only 

27 percent of the LSR would experience a surface fire, while approximately 73 percent (45,190 acres) 

of the LSR would experience a crown fire (Table 3-19 below, Map A-9b in Appendix A of this final 

EIS). These current simulations resulted in substantially more crown fires than the earlier forestwide 

LSR assessment (USFS 1999), which estimated 47 percent crown fires in the Eddy Gulch LSR. 

Table 3-19. Acreages by fire type based on current conditions in the Eddy Gulch LSR. 

Eye Level Wind 

Speed of 2 to 3 MPH

Eye Level Wind 

Speed of 3 to 5 MPH

Percent of LSR Burned 

with Wind Speed 

of 2 to 3 MPH 

Percentage of LSR 

Burned with Wind 

Speed of 3 to 5 MPH Fire Type 

Descriptiona Acres Percent 

Surface Fireb 28,965 16,790 46 27 

Passive Crown Firec 33,053 38,135 53 61 

Active Crown Fired 510 7,602 1 12 

Notes: 

a. Fire type based on a westerly wind direction. 

b. Surface Fire—a fire that burns ground fuels (surface litter, debris, and small vegetation). 

c. Passive Crown Fire—the movement of fire through groups of trees; it usually does not continue for long periods of time. 

d. Active Crown Fire—the independent movement of flames through the branches and top of the trees. 

The expected fire severity (effect) was calculated with FLAMMAP using existing vegetation, 

topography, and constructed weather conditions for the Assessment Area (Map B-8 in Appendix B of 

the SFA). This analysis shows that, if subjected to wildfire, approximately 61 percent of the Eddy 

Gulch LSR would experience mixed levels of mortality from passive crown fire behavior. The 

potential for lethal fire effects from active crown fire behavior were identified for approximately 

12 percent of the LSR. High-severity events are more of a concern on south and west aspects and 

steep slopes due to the slopes’ alignment with prevailing winds and normal diurnal air movement 

caused by surface heating and cooling, and because fires burn faster up-slope due to fuel pre-heating 

ahead of the flaming front. Stand-replacing intensities are also more likely in young stands, 

particularly plantations, because the lowest limbs on these trees are close (generally less than 4 feet) 

to ground fuels and shrubs and grasses, as well as accumulated dead and down fuels, which are 

common ground fuels, making even moderate- to low-intensity wildfires stand replacing. 

3.3.4 Desired Conditions for the Assessment Area 

The potential for large stand-replacing fires would be reduced in the Eddy Gulch LSR. This 

would be achieved by reducing fuel hazards, which would result in different fire behavior 

(Table 3-20). 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.3 – Fires, Fuels, and Air Quality 3-41

Table 3-20. Current and desired fire behavior and fuel profile under 90th percentile weather 

conditions for Eddy Gulch LSR Project Assessment Area. 

Indicator Measurement Current Conditions Desired Conditions 

Fuel Load 1-hour fuels: 0.5–3 tons/acre 

10-hour fuels: 1–3 tons/acre 

100-hour fuels: 2–8 tons/acre 

Not tracked, 1,000 hour fuels: 

5–30 tons/acre 

 1-hour fuels: less than 1 ton/acre 

 10-hour fuels: less than 2 tons/acre 

 100-hour fuels: less than 3 tons/acre; 

0.5-foot fuel bed depth 

Flame Length 11 to 20 feet 2 to 4 feet 

Ground Fuels 

Rate of Spread 30 to 60 feet per minute Equal to or less than 20 feet per minute 

Ladder Fuels Crown Base 

Height 

Average between 2–15 feet, with 

increased crown base heights at 

higher elevations. Brush and 

small conifers occupy from 30%–

50% of many areas, decreasing 

with elevation.

In FRZs, 8- to 

15-foot crown base 

height or a gap 

between the tops of 

understory trees to 

the lowest limbs of 

residual trees of 

15–20 feet.

Outside FRZs, 

brush and lower 

limbs up to 15 feet 

are generally 

absent.

Crown Fuels Crown Bulk 

Density 

0.131–0.351 kg/m3 In FRZs, 65-115 trees 

per acre; ≈40% crown 

closure; less than 

0.0111 kg/m3 crown 

bulk density (Reinhardt 

and Crookston 2003) 

Outside FRZs, 

conifers under 

6 inches dbh are 

limited to 55%–70% 

of the area. 

Fire Type 

Current Acres in 

the Eddy Gulch 

LSR, by Fire Type 

Current Acres in the 

Assessment Area, by Fire Type 

Desired Percent 

Change, by Fire Type 

Desired Acres in 

Assessment Area, 

by fire Type 

Surface Fire 16,790 10,054 Increase 130%–200% 23,124–30,100 

Passive Crown Fire 38,135 22,715 Decrease 45%–75% 12,495–5,630 

Active Crown Fire 7,602 4,470 Decrease 70%–90% 1,340–450 

The general desired condition is to move the LSR toward the historic range of variation, where 

fuel hazards and fire behavior varied across the landscape. Fuel hazards would be reduced and 

wildfires would exhibit substantially more surface fires that currently observed and predicted 

(Table 3-20). It is reasonable to expect that heavier scattered pockets of fuels will occur on relatively 

cool, moist sites, such as those found on north- and east-facing slopes, and low-elevation slopes 

adjacent to perennial riparian areas. Generally, south- and west-facing aspects and upper slope 

positions, which are typically drier and hotter, will contain lighter fuel loadings, with fewer scattered 

pockets of heavy fuel loads. 

Generally, the following will help achieve desired conditions for fire behavior: 

 The average large tree size is generally greater than 20 inches dbh, which helps trees 

survive wildfire disturbance events if the ground and ladder fuel components are reduced to 

acceptable levels. 

 Large prescriptive fire projects in the Assessment Area have reduced the excessive 

accumulations of ground fuels, and ladder fuel profiles are discontinuous and at sustainable 

levels (consistent with habitat objectives for late-successional forest-related species). 

Crown spacing (expressed as “canopy bulk density”) is reduced, thereby reducing wildfires 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-42 Chapter 3: Affected Environment and Environmental Consequences

to primarily surface fires, with mixed severity typified by occasional torching and active 

crown fire behavior. 

 Strategically located FRZs (fuelbreaks) are present, where ground fuel accumulations, 

ladder fuels, and crown spacing have reduced fire behavior potential. This will provide safe 

areas for suppression crews to work and anchor control lines, thereby reducing the 

probability of fires spreading to adjacent drainages and allowing safe use of roads that are 

key access routes for firefighters and escape routes for residents and other publics. Fuel 

conditions allow greater decision space for an “appropriate management response” 

(AMR2

). 

 Large-diameter trees are primarily Douglas-fir, ponderosa pine, sugar pine, incense-cedar, 

and black oak (these trees are more resilient to wildfire). 

The Salmon River CWPP contains a prioritized list of projects to focus and guide implementing 

landowners, organizations, and funders. A key product of the CWPP is the development of wildfire 

safety zones to reduce citizen and firefighter risks from future large wildfires. The list of 

recommended projects consists of structure protection strategies, prevention measures, and pretreatment and shaded fuelbreak (same as an FRZ) construction to protect life and property in towns, 

residential areas, emergency access routes, and private/public interface areas. Other activities (such as 

maintaining adequate accessible water systems, plantation thinning, underburning, and natural fire 

management) were recommended in the CWPP (SRFSC 2007). 

The CWPP objectives to provide for the safety of adjacent communities and people (residents and 

emergency respondents) would be met if the following desired conditions exist: 

 Forests in the LSR are managed so as to minimize large-scale high-intensity fire threats to 

communities and infrastructure. Mechanical fuel treatments and prescribed burning have 

been implemented in areas projected to experience high fire intensity, and within 

strategically located FRZs to reduce fire intensity and provide locations from which to base 

suppression actions. 

 CWPP-identified road segments and all open roads in FRZs are being managed to ensure 

the safety of the public and suppression resources during wildfires. 

 Forest stands within the 0.25-mile radius around domestic water sources (such as spring 

boxes, wells, and water intakes) (SRFSC 2007) have a break in crown base height of at 

least 15 feet to eliminate fuel ladder conditions. 

 

2. AMR is a thoughtful approach to evaluating the conditions and context of a wildfire and designing a response to 

effectively address them. It encourages consideration of a wider spectrum of management options in response to each fire. 

The concept first appeared in the 2001 Review and Update of the 1995 Federal Wildland Fire Management Policy. The 

current Klamath National Forest Fire Management Plan defines AMR as “specific action taken in response to a wildland fire 

to implement protection and fire use objectives” by isolating topographic features to block-in fires when direct attack is not 

an appropriate action. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.3 – Fires, Fuels, and Air Quality 3-43

3.3.5 Environmental Consequences: Fire and Fuels 

3.3.5.1 Alternative A: No Action 

Direct and Indirect Effects. Current fire behavior is described above (Table 3-20). Excessive 

fuel loading would result in flame lengths of 11 to 20 feet and rate of spread of 30 to 60 feet per 

minute. Fuel ladders and dense canopies contribute to 73 percent crown fire in the Eddy Gulch LSR. 

During the next 20 years, overstocked stands of trees would continue to self thin and increase 

ground fuels. Mortality of trees greater than 10 inches dbh could add an additional 7–23 percent 

increase in cubic feet of ground fuels, and that could increase to 17–26 percent in 30 years, as 

estimated by the FVS (Table 3-21). Understory vegetation and shade-tolerant trees will continue to 

grow, thereby increasing the ladder fuels and lowering the stands’ crown base height, which would 

lead to a higher percentage of passive and active crown fires. Dense stands in the Assessment Area 

would become increasingly vulnerable to mortality from drought conditions, insects, disease, and 

storm damage and eventually contribute to the ground fuel load. Flame length would increase as 

ground fuels increased. The fuel hazard would continue to increase and fire behavior would become 

progressively worse, thereby creating risks to life and property, infrastructure values, private property, 

and natural resources in the Assessment Area. The chronic effects of climate change would place 

additional stress on trees, thereby increasing mortality rates, fuel loading, and fire intensity. 

Table 3-21. Changes in tree mortality in forest stands in the Eddy Gulch LSR at 20 and 30 years 

into the future. 

For Trees 10 Inches dbh and Greater 

SAF 

Forest Typea CWHR Seral Stageb

No Treatment 

FVS Predicted 20-year Tree Mortality 

(by cubic feet) 

No Treatment 

FVS Predicted 30-year Tree Mortality

(by cubic feet) 

DFc MSd 7.1% 16.9% 

DF MS/LSd 13.7% 20.5% 

WFc MS 12.6% 26.1% 

WF MS/LS 9.0% 17.7% 

RFc LS 12.4% 18.1% 

MCc LS 22.6% 26.4% 

Notes: a. SAF = Society of American Foresters. 

 b. CWHR = California Wildlife Habitat Relationship. 

 c. DF = Douglas-fir; WF = white fir; RF = red fir; MC = mixed-conifer. 

 d. MS = mid-successional; LS = late-successional. 

Direct and Indirect Effects of an Escaped Wildfire—Given the current fuel hazard in the 

Eddy Gulch LSR and predictions of climate change, the probability of a large wildfire will increase. 

Using past fire frequencies, current fuels conditions, and current 90th percentile weather conditions, 

three separate wildfire simulations were run to show probable direct effects of fires that have escaped 

initial attack. The simulations were run for only 72 hours using Farsite (a fire behavior program) to 

illustrate how a wildfire would spread and the acres of surface fire, passive crown fire, and active 

crown fire in the Eddy Gulch LSR Project Assessment Area under Alternative A (Figure 3-7). If the 

escaped fires were not contained in three days, an average of approximately 7,200 acres would burn 

with varying intensities, and result in 1,355 acres (19 percent) of surface fire; 5,065 acres (70 percent) 

of passive crown fire; and 780 acres (11 percent) of active crown fire. Surface fires would consume 
3-44 Chapter 3: Affected Environment and Environmental Consequences Figure 3-7. Three randomly selected examples of wildfire simulations in the Assessment Area under Alternative A. Note: Each simulated wildfire burned uncontained for 3 days. Yellow = surface fire Orange = passive crown fire Red = active crown fire
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.3 – Fires, Fuels, and Air Quality 3-45

all litter, woody debris (less than 3 inches in diameter), and all shrubs; kill most small trees (less than 

6 inches dbh); and some larger trees would die in the future, providing snags that will eventually fall 

to the ground and contribute to the fuel load. A passive crown fire would have the same effect, plus 

individual and groups of intermediate and mature trees would be killed immediately by the torching 

of crowns, and most of the stand would die by the end of the next summer from crown scorch and 

root and bole damage related stress from the wildfire. Mortality from an active crown fire would be 

almost immediately apparent, with nearly complete mortality. 

An escaped fire could adversely affect protection targets (private property, municipal watersheds, 

infrastructure, and northern spotted owl [NSO] core areas). The high percentage of crown fire 

(81 percent) could result in the loss of private property, short-term adverse effects on municipal 

watersheds, and long-term losses of late-successional habitat, including NSO core areas. 

Cumulative Effects. Construction of a fuelbreak system west of Black Bear Ranch would reduce 

fuel hazards on approximately 700 acres, and the fuel reduction projects (proposed in the Salmon 

River CWPP) on private property in and around the Assessment Area would reduce threats on private 

property. Alone, these fuel treatments offer limited resistance to a wildfire because fires can flank 

around them, or spot fires could ignite structures inside the limited fuelbreaks. Additionally, ingress 

and egress would be constrained because of the lack safe emergency access routes. The loss of key 

infrastructure, such as the repeater site near the Eddy Gulch Lookout, could adversely affect 

communication of emergency response crews during an escaped wildfire. 

Conclusion. Prior to European settlement, frequent wildfires, with varying intensity, had the 

greatest influence on the structure and composition of forests in the Klamath Mountains. Fire 

suppression eliminated this key ecological factor, resulting in the buildup of excessive fuels and 

forests that are highly susceptible to stand-replacing crown fires. The no-action alternative will not 

reduce those fuel hazards, ensuring that crown fires will persist, potentially resulting in the loss of 

private property, long-term damage to municipal waterheds and important infrastructure, and the loss 

of habitat for late-successional-dependent wildlife species. Thus, the purpose and need for the project, 

as described in Chapter 1, would not be achieved. The limited number of other potential projects (the 

fuelbreak system west of Black Bear Ranch and fuel reduction projects on private land), if 

implemented, would have beneficial effects by reducing the threat of a wildfire; however, those 

effects would be limited and localized in scope and have little influence on most forest resources. 

3.3.5.2 Alternative B: Proposed Action 

Direct and Indirect Effects of Fuel Reduction in FRZs. Table 2-1 in Chapter 2 of this document 

lists the purpose of each FRZ. The construction of 8,291 acres of FRZs would reduce ground, ladder, 

and crown fuel in 931 acres of M Units and ground and ladder fuels in 7,360 acres of other fuel 

reduction treatments. Thinning trees in M Units is an important component of fuels treatments 

because it would reduce crown bulk density in stands by 51–82 percent (Table 3-22), resulting in 

approximately 40 percent crown closure. Thinning also increases the height from the ground to the 

lowest limbs, which when combined with the thinner canopy, directly reduces the potential for 

passive and active crown fires. These treatments would reduce crown fuels substantially more than 

underburning alone. The thinning treatments would improve stand health, which would reduce future 

mortality and the amount of material that will eventually accumulate as ground fuels. This would 

result in 50 to 95 percent less mortality in treated stands that otherwise would have died and become 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-46 Chapter 3: Affected Environment and Environmental Consequences

Table 3-22. Change in crown bulk density and mortality in M Units as a result of 

treatments under Alternative B (based on FMAPlus). 

Indicator: Crown Fuels 

Measurement: Crown Bulk Densityc

SAF 

Forest Typea CWHRb

 

Seral Stage

Existing 

Conditions 

Post Treatment 

Conditions 

Reduction in Crown Bulk 

Density Compared 

to No Treatment 

DFd MSe 0.352 0.131 62% 

DF MS-LSe 0.131 0.052 61% 

WFd MS 0.243 0.089 63% 

WF MS-LS 0.139 0.044 69% 

RFd LS 0.181 0.089 51% 

MCd LS 0.277 0.051 82% 

Notes: a. SAF = Society of American Foresters. 

 b. CWHR = California Wildlife Habitat Relationship. 

 c. Crown bulk density measured in Kg/m3

. 

 d. DF = Douglas-fir; WF = white fir; RF = red fir; MC = mixed-conifer. 

 e. MS = mid-successional; LS = late-successional. 

ground fuels. Thinning would also move these stands toward the composition and structure that 

mimics conditions of the pre-European fire regime. That historic fire regime produced a mosaic of 

vegetation, consisting of large areas of mid- and late-successional forest, interspersed with more open 

conifer stands mixed with hardwoods or younger stands created by disturbances. 

Prescribed burning after thinning would reduce existing ground fuels and slash generated from 

thinning and remaining ladder fuels (up to 4 inches dbh), including lower branches on residual trees 

(Table 3-23). Thus, the desired condition for forest fuels would be achieved. Similar treatments in the 

Sierra Nevada removed approximately 60 percent of ground fuels less than 3 inches in diameter and 

60 percent of the small trees, which resulted in a post-treatment surface fire with 1-foot flame lengths 

(Stephens and Moghaddas 2005a). Thus, these treatments would achieve the desired flame lengths of 

less than 2 feet post-treatment in the Assessment Area. The combination of thinning and burning 

would reduce ladder and crown fuels and increase the crown base height to 8–15 feet. 

In the study conducted by Stephens and Moghaddas (2005a), prescribed burning was effective in 

reducing tree density in trees 1 inch–10 inches dbh, but further states that prescribed fire treatment did 

not substantially remove dominant or co-dominant trees because fire behavior was not severe enough 

to kill many trees over 11 inches dbh. It is important to note that indirect mortality from increased 

insect activity, periods of drought, and pathogens may increase mortality in larger trees in prescribed 

fire and mechanical treatments followed by fire treatments. Thus, there is the potential that 

(depending on different site characteristics) scorching could result in post-treatment mortality in 

residual trees greater than 20 inches dbh, which would provide future snags and CWD (Stephens and 

Moghaddas 2005a). However, large trees and snags are typically not lost during prescribed fire. The 

burn plan (developed prior to implementing any treatments for the Eddy Gulch LSR Project) will 

design a prescribed fire that consumes smaller-diameter trees. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.3 – Fires, Fuels, and Air Quality 3-47

Table 3-23. Changes in fuel indicators in FRZs under Alternative B. 

Indicator Measurement Current Conditions Alternative B 

Fuel Load Post-treatment 20 years 

(Ground Fuels)

1 hour fuels: 0.5–3 tons/acre 

10 hour fuels: 1–3 tons/acre 

100 hour fuels: 2–8 tons/acre 

1 hour fuels: less than 

1 tons/acre 

10 hour fuels: less than 

2 tons/acre 

100 hour fuels: less than 

3 tons/acre 

1 hour fuels: 2.5 tons/acre 

10 hour fuels: 

2.5 tons/acre 

100 hour fuels: less than 

6.5 tons/acre 

Flame Length 11 to 20 feet Less than 2 feet 

Ground 

Fuels 

Rate of Spread 30 to 60 feet per minute Equal to or less than 

20 feet per minute 

Approximating pretreatment fire-intensity 

characteristics 

Ladder 

Fuels 

Crown Base 

Height 

Average between 2–15 feet, 

with increased crown base 

heights at higher elevations. 

Brush and small conifers 

occupy from 30%–50% of 

many areas, decreasing with 

elevation.

In FRZs, 8- to 15-foot 

crown base height or a 

gap between the tops of 

understory trees to the 

lowest limbs of residual 

trees of 15–20 feet

Average between 

6–12 feet 

Prescribed burning outside of the M Units would reduce ground fuels and smaller (less than 

4 inches dbh) ladder fuels, while mastication will reduce the arrangement of ground fuels and reduce 

ladder fuels up to 10 inches dbh. These treatments would result in flame lengths less than 2 feet high 

and increase CBH. 

The effectiveness of the FRZ treatments is shown in Figure 3-8 (FARSITE was used for the 

predictions). The left pane of Figure 3-8 shows how fire would spread if only treatments in FRZs 

were implemented. Under 90th percentile weather conditions, the simulated wildfire burned 

approximately 2,773 acres, with flame lengths 6–10 feet long. When the simulated fire reached the 

FRZ, flame lengths dropped to less than 3 feet, where suppression crews could safely use direct attack 

strategies to contain the fire. Thus, the combined treatments in the FRZs would increase the resistance 

to a wildfire, providing a beneficial effect by increasing protection to late-successional habitat and 

communities. 

The effectiveness of the treatments would vary over time. Ground and ladder fuels would 

increase (Table 3-23), and crown bulk density would increase as the canopy cover increases (see 

“Section 3.2 Forest Vegetation” in the EIS or the Silviculture Report for more information). Thinning 

and burning in M Units and mastication would remain effective for 15–20 years. Prescribed burning 

outside of the M Units would remain effective for a shorter period of time. Studies in the Sierra 

Nevada revealed that ground fuels increased to 80 percent of their pre-treatment levels 10 years after 

treatment; however, additional increases in fuels were very low for the next 20 years (Keifer et al. 

2006). 

Direct and Indirect Effects of Fuel Reduction in Rx Units. Table 2-5 in Chapter 2 of this 

document lists the purpose of each Rx Unit. Treatments in the Rx Units would reduce ground and 

ladder fuels on up to 17,524 acres. Similar treatments conducted by Stephens and Moghaddas (2005a) 

removed approximately 60 percent of ground fuels less than 3 inches in diameter and 60 percent of 

the small trees. The majority of the trees that were removed were small (less than 10 inches dbh) 
3-48 Chapter 3: Affected Environment and Environmental Consequences Figure 3-8. Left pane: displays fire spread in an untreated area and effectiveness of constructing an FRZ. Right pane: displ

treated Rx Unit. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.3 – Fires, Fuels, and Air Quality 3-49

because crown cover in the residual stand only declined by 10 percent. Ground and ladder fuel 

reductions and changes in flame length and rate of spread would be similar to that described in 

Table 3-23. All acres in the treatment areas would not be treated equally because of access and 

localized differences in fuel moisture, which will affect the amount of fuels consumed. The 

effectiveness of the treatments in Rx Units is shown in Figure 3-8 (FARSITE was used for the 

predictions). The right pane of Figure 3-8 shows that, following treatment, a simulated wildfire 

burning under 90th percentile weather conditions only grew to 62 acres of low-intensity surface fire 

in 3.5 days. 

The introduction of large-scale prescribed fire to the Eddy Gulch LSR would restore a source of 

disturbance that influenced distribution and species composition of forest stands and associated 

wildlife. Low- to moderate-intensity fires would mimic the results of the historic fire regime; that is, a 

mosaic of vegetation, consisting of large areas of mid- and late-successional forest, interspersed with 

more open conifer stands mixed with hardwoods or younger stands created by disturbances. Although 

crown fuels would not change substantially, the treated areas would be more resilient to future fires 

and reduce the probability of a stand-replacing crown fire that would adversely affect latesuccessional habitat and local communities. Prescribed fire treatments would result in major shortterm beneficial effects, and moderate long-term beneficial effects as the effectiveness of the 

treatments would decline within the first 10 years; however, fuel hazards would change little during 

the next 20 years (Keifer et al. 2006). 

Direct and Indirect Effects on Fire Type in the Assessment Area. Treatments in the FRZs and 

Rx Units would shift the fire types in the Assessment Area from being primarily crown fires to 

primarily surface fires (Table 3-24), as identified in the SFA and the purpose and need for the project 

(refer to Chapter 1). The acres of surface fire would increase 188 percent as a result of these 

treatments, resulting in improved suppression capabilities and substantially less resource damage and 

property losses in the event of a wildfire. 

Table 3-24. Changes in fire type in the Assessment Area, resulting from implementation of 

Alternative B. 

Fire Type 

Current Acres in the 

Assessment Area 

Desired Acres in 

Assessment Area Fire Type 

Post-Treatment Fire Type 

in Assessment Area 

Surface Fire 10,054 23,124–30,100 28,898 

Crown Fire 27,185 13,835–6,080 8,341 

Direct and Indirect Effects of Roadside (RS) Treatments. Approximately 44 miles of 

designated emergency access routes (SRFSC 2007) would be treated in FRZs and Rx Units—fire 

behavior along those routes would be similar to that in the post-treatment FRZ or Rx Units. 

Approximately 16 miles of RS treatments along emergency access routes are outside of FRZs and 

Rx Units—about 80 percent of those routes would be treated within 50 feet of the road. Indirect 

effects would include improving their status as emergency access routes, allowing residents to safely 

evacuate and suppression crews access to the Assessment Area. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-50 Chapter 3: Affected Environment and Environmental Consequences

Direct and Indirect Effects on Community Protection Targets. Treatments in FRZs and Rx 

Units would reduce fuel hazards on approximately 9,850 acres of municipal watersheds and 

approximately 800 acres of 0.25-mile WUI around communities in the Assessment Area (Table 3-25). 

Additionally, treatments would reduce the threat of a wildfire on key infrastructure, such as the Eddy 

Gulch Lookout and repeater sites that are necessary for fire detection and communication. This would 

be a beneficial effect on local protection targets identified in the Salmon River CWPP and key 

infrastructure.

Table 3-25. Acres of municipal watersheds treated and 0.25-mile WUI around 

communities in the Eddy Gulch LSR Assessment Area. 

Municipal Watershed Acres Treated 0.25 mile WUI Acres Treated 

Black Bear Ranch Watershed 1,219 Black Bear Ranch 366 

Callahan 2,334 Eddy Gulch 68 

Counts Gulch 0 Finley Camp 24 

Crawford Creek 5,692 Rainbow 195 

Eddy Gulch 606 Taylor Hole 151 

Shadow Creek 6 Whites Gulch 0 

Music Creek 0 Music Creek 0 

Cumulative Effects. Implementing Alternative B, constructing a fuelbreak system west of Black 

Bear Ranch, and implementing proposed work on private property, as outlined in the Salmon River 

CWPP, would reduce the threat of wildfire in the Assessment Area. The beneficial effects would vary 

over time because treatments would have different periods of effectiveness. Effectiveness would last 

longest in areas treated mechanically, perhaps as long as 15–20 years. The effectiveness of areas that 

are only treated with prescribed fire would decline after 5–10 years as trees that were killed by the 

treatment fall to the ground, and other fuels accumulate to approximately 60–85 percent of pretreatment levels (Keifer et al. 2006). 

Conclusion. The Proposed Action would reduce fuel hazards on 25,815 acres, increasing the 

amount of surface fire in the Eddy Gulch LSR to 77 percent of the Assessment Area and reducing 

crown fires to 23 percent of the Assessment Area. The shift to surface fires as the dominant fire type 

in the Assessment Area meets the purpose and need for the project. The Rx Units would be resilient 

to damage from wildfires and allow suppression crews to control those fires. The FRZs would 

increase resistance to wildfires, allowing suppression crews to contain those fires and minimize the 

potential for those fires to escape to adjacent watersheds. Combined, the treatments would place 

conifer stands in a trajectory toward the historic fire regime and reduce the effects of wildfires on 

late-successional habitat, communities, important infrastructure, and municipal watersheds. These 

changes would result in short- and long-term beneficial effects on natural resources, infrastructure, 

and private property. 

3.3.5.3 Alternative C: No New Temporary Roads Constructed 

Direct and Indirect Effects of Fuel Reduction in FRZs. Under Alternative C, the effects of 

treatments would be similar to Alternative B (refer to Tables 3-22 and 3-23), except all or portions of 

six M Units (15, 17, 24, 36, 37, and 75), totaling 99 acres, would not be treated. As a result, 72 acres 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.3 – Fires, Fuels, and Air Quality 3-51

of those untreated areas would be subject to a crown fire, similar to the no-action alternative. 

Wildfires that ignite in or burn through these untreated areas would emit fire brands that could land in 

adjacent untreated area, potentially increasing the complexity and difficulty of suppression efforts and 

the number of acres burned by a stand-replacing crown fire. Important infrastructure (such as the 

Eddy Gulch Lookout and repeater sites) and municipal watersheds could be threatened by a wildfire. 

Direct and Indirect Effects of Fuel Reduction in Rx Units. Treatments in the Rx Units would 

reduce ground and ladder fuels on 16,790 acres, resulting in effects similar to Alternative B (refer to 

Table 3-23). The reduction in untreated acres (822 acres) compared to Alternative B, would result in 

600 acres of crown fires. Wildfires that ignite in or burn through these untreated areas would emit fire 

brands that could land in adjacent untreated areas, potentially increasing the complexity and difficulty 

of suppression efforts and the number of acres burned by a stand-replacing crown fire. 

Direct and Indirect Effects on Fire Type in the Assessment Area. Treatments in the FRZs and 

Rx Units would modify fire types in the Assessment Area (Table 3-26). This shift in fire type 

following treatments would result in less resource damage in the event of a wildfire. However, the 

inability to treat approximately 921 acres (99 acres in M Units and 822 acres in portions of Rx Units) 

would result in vulnerable areas that could allow wildfires to escape to other areas of the LSR. 

Table 3-26. Changes in fire type in the Assessment Area, resulting from 

implementation of Alternative C. 

Fire Type 

Current Acres in the 

Assessment Area 

Desired Acres in 

Assessment Area Fire Type 

Post-Treatment 

Fire Type 

Surface Fire 10,054 23,124–30,100 28,226 

Crown Fire 27,185 13,835–6,080 9,013 

As stated in the preceding paragraph, when completed, the treated areas would primarily support 

surface fires. Maps A-11a and A-11b in Appendix A show the treated areas in FRZs and Rx Units. In 

the strategically located FRZs, M Units would receive the most comprehensive treatments, where 

thinning would reduce ladder and crown fuels, resulting in an increase in crown base height and 

reduction in crown bulk density. The prescribed burning in FRZs would reduce ground fuels. 

Mastication would rearrange ground fuels and reduce ladder fuels up to 10 inches dbh. Treatments in 

M Units and masticated areas would maintain their effectiveness longer than the prescribed burn 

treatments because more fuels would be treated. The areas treated with only prescribed burning would 

reduce ground fuels and small ladder fuels up to 6 inches dbh. Burning in FRZs would be more 

effective than burning in Rx Units because the treatment areas in FRZs are smaller, and treatments 

would be more uniform. The Rx Units are larger, and treatments would not be as uniform due 

different ignition techniques and varying concentrations of fuels and fuel moisture, resulting in 

different fuel consumption rates. For instance, fuel treatments would be least effective in larger 

riparian areas that are moister than upland slopes, and less fuel would be removed in those areas.

When completed, the treated areas would primarily support surface fires, which is similar to that 

described under Alternative B. However, the 921 untreated acres would remain susceptible to standreplacing crown fires. Maps A-10a and 10b in Appendix A show the treated areas in FRZs and Rx 

Units and the 921 acres of untreated areas under Alternative C.
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-52 Chapter 3: Affected Environment and Environmental Consequences

Direct and Indirect Effects of RS Treatments. Approximately 44 miles of designated 

emergency access routes (SRFSC 2007) would be treated in FRZs and Rx Units—fire behavior along 

those routes would be similar to that in the post-treatment FRZ or Rx Units. Approximately 16 miles 

of RS treatments along emergency access routes are outside of FRZs and Rx Units—about 80 percent 

of those routes would be treated within 50 feet of the road. Indirect effects would include improving 

their status as emergency access routes, allowing residents to safely evacuate and suppression crews 

access to the Assessment Area. 

Direct and Indirect Effects on Community Protection Targets. Treatments in FRZs and 

Prescribed Burn Units would reduce fuel hazards on approximately 9,850 acres of municipal 

watersheds and approximately 800 acres of 0.25-mile WUI around communities in the Assessment 

Area (refer to Table 3-18), similar to Alternative B. The lack of treatments in M Units 15 and 37 and 

Rx Unit 5 would increase the probability that a crown fire in untreated areas could damage key 

infrastructure, such as the Eddy Gulch Lookout and repeater sites, which are necessary for fire 

detection and communication. 

Conclusion. Alternative C would reduce fuel hazards on 24,894 acres, increasing the amount of 

surface fire in the Eddy Gulch LSR Project Assessment Area to 75 percent and reducing crown fires 

to 25 percent. The inability to treat approximately 921 acres (99 acres in M Units and 822 in 

Rx Units) reduces the probability that wildfires could be controlled or contained, and increases the 

probability that wildfires will escape to other areas of the LSR. As a result, additional acres of latesuccessional habitat and municipal watersheds and key infrastructure would be threatened by crown 

fires. Thus, the purpose and need for the project would not be met as well as the Proposed Action. 

3.3.6 Methodology: Air Quality 

Data from the California Air Resources Board website, Siskiyou County Air Pollution Control 

District, and EPA were used to determine the current air quality for the county. Emissions from 

wildfires were modeled with First Order Fire Effects Model and emissions from dust generated 

during treatments were modeled with an emission factor (USFS 2008) and miles of dirt roads traveled 

during hauling. 

3.3.6.1 Scope of the Analysis 

Analysis Area. The analysis area for air quality includes all of Siskiyou County. 

Analysis Period. Emissions were calculated during a wildfire, during implementation of 

treatments, and for post-treatment fire emissions. 

3.3.6.2 Intensity of Effects 

Negligible. No changes would occur, or changes in air quality would be below or at the level of 

detection. If detected, the effects would be slight. 

Minor. The changes in air quality would be measurable but small and localized. 

Moderate. The changes in air quality would be measurable and would have consequences, 

although the effect would be relatively local. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.3 – Fires, Fuels, and Air Quality 3-53

Major. The changes in air quality would be measurable, would have substantial consequences, 

and would be noticed regionally. 

3.3.6.3 Measurement Indicators 

Air Quality. Emissions is the only measurement indicator that was used to assess current air 

quality in the Assessment Area and to predict air quality under Alternatives A, B, and C. 

Indicator: Emissions Output—Emissions are particulates or gases that are generated by soil 

disturbance (for example, disking, grading, or driving) or generated by an event, such as a wildfire. 

There are numerous sensitive receptors in the vicinity of the Eddy Gulch LSR that are potentially 

susceptible to emissions from large wildfires, forest management activities, off-road recreation, and 

wind-generated dust from exposed soil surfaces. The amount and duration of these emissions vary by 

season, with most emissions from wildfires, timber harvest, and recreational activities occurring between 

May and late August, and emissions from prescribed burning occurring from late September through 

mid-November. 

Attainment Status. Attainment refers to an area that meets air quality standards for a pollutant; 

an area that does not meet the standards is in nonattainment. Table 3-27 lists the air quality attainment 

status for Siskiyou County for ozone, carbon monoxide (CO), sulfur dioxide, and other compounds, 

including fine particulate matter (PM) less than 2.5 microns (PM2.5) and larger particles that are 

greater than 10 microns (PM10). The attainment status was derived directly from the 2006 report 

available on the California Air Resources Board website. Air Quality in the Eddy Gulch LSR is 

typically very good. Dust from recreational use of roads is the primary source of particle emission on 

a day-to-day basis. 

Table 3-27. Attainment designations for Siskiyou County compared to 

national standards. 

National Ambient 

Air Quality Standards State Air Quality Standards 

Compound Attainment Status 

Siskiyou County 

Attainment Status 

Ozone (1 hour) N/A Attainment 

Ozone (8 hour) Attainment/Unclassified Nonattainment 

Carbon monoxide (8 hour) Attainment/Unclassified Unclassified 

Nitrogen dioxide (annual) Attainment Attainment 

Sulfur dioxide (annual) Attainment/Unclassified Attainment 

PM10 (24 hour) Unclassified Attainment 

PM2.5 (24 hour) Unclassified Unclassified 

Source: EPA website (2008); California Air Resources Board website (2008). 

Currently, Siskiyou County is in attainment status for PM10 (county wide) and unclassified for 

PM2.5. According to the California Air Resources Board, the major contributors to both PM10 and 

PM2.5 levels include forestry management burns, woodstoves, residential open burning, vehicle traffic, 

and windblown dust. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-54 Chapter 3: Affected Environment and Environmental Consequences

3.3.7 Affected Environment (Existing Conditions): Air Quality 

The Eddy Gulch LSR Project Assessment Area is located in Siskiyou County, California, and the 

Siskiyou County Air Pollution Control District, which is within the Northeast Plateau Air Basin. The 

Northeast Plateau Air Basin includes all of Lassen, Modoc, and Siskiyou counties and is the fourth 

largest air basin in the state. 

3.3.8 Environmental Consequences: Air Quality 

3.3.8.1 Alternative A: No Action 

Indicator: Emissions Output 

Direct and Indirect Effects 

Increased Emissions from Wildfires—Smoke from wildfires increases particulate and 

gaseous emissions, particularly PM10, PM2.5, and CO. Emissions were estimated using FOFEM (First 

Order Fire Effects Model, version 5.7). A 7,200-acre wildfire burning for three days would generate 

approximately 2,300 tons of PM10, 1,900 tons of PM2.5, and 25,000 tons of CO (Table 3-28). These 

emissions could not be managed and may affect any of the sensitive receptors identified in Siskiyou 

County (refer to Table 3-27), possibly resulting in a short-term health hazard. 

Table 3-28. Selected emissions from a wildfire in the 

Assessment Area. 

Emissions

No Action with Wildfire 

(tons/acre)

Total Emissions 

(tons)

PM10 0.32 2,304 

PM2.5 0.27 1,944 

CO 3.48 25,056 

Cumulative Effects. The emissions from a wildfire would likely occur during summer, when 

vehicle traffic and windblown dust are the other primary sources of emissions. Implementation of the 

fuelbreak system west of Black Bear Ranch would have a temporary effect on emissions; however, 

the direct effects from implementation would occur during a single year and may or may not occur in 

the same year as the wildfire. Implementation of the fuelbreak system would do little to reduce 

emissions from a wildfire. Therefore, the cumulative effects may pose a temporary health threat; 

however, it would not change Siskiyou County’s attainment status for CO or PM10. 

Conclusion—A wildfire would have a temporary but potentially major increase in emissions 

and degradation of air quality; however, a single event would not affect the county’s attainment 

status. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.3 – Fires, Fuels, and Air Quality 3-55

3.3.8.2 Alternative B: Proposed Action 

and Alternative C: No New Temporary Roads Constructed 

Indicator: Emissions Output 

Direct and Indirect Effects 

Increased Emissions from Project Implementation—Implementation of Alternative B or C 

would increase emissions, with the greatest source being from 22,631 acres of prescribed burning 

(FRZs and Rx Units). For this analysis it was assumed that 2,263 acres would be burned annually for 

10 years. Annual emissions would increase but would only be approximately 20 percent of those 

generated by a wildfire (Table 3-29). It is unlikely that the estimated 24-hour emissions would exceed 

the California 24-hour standard for PM10 and PM2.5 in the burn location; it would definitely not exceed 

annual state or federal standards; and it would not degrade air quality or attainment status. Smoke 

emissions during prescribed burning may reduce the visibility in some locations, but implementation 

of smoke management practices and plans (such as burning during favorable weather conditions when 

smoke is carried away from sensitive areas) and using the best available fire and emission control 

measures would minimize visibility impairments. Thus, emissions can be directed away from 

sensitive receptors, minimizing health hazards, as opposed to the no-action alternative where 

emissions cannot be managed. 

Table 3-29. Selected annual emissions from prescribed 

burning in the Eddy Gulch LSR. 

Emissions

Alternatives B: 

Proposed Action 

(tons/acre)

Alternative B: 

Proposed Action 

(tons/year) 

PM10 0.214 484 

PM2.5 0.182 411 

CO 2.39 5,408 

Fugitive dust from timber hauling, logging, road reconstruction, maintenance, and 

decommissioning activities would generate particulate emissions into the atmosphere for short 

periods of time during the day, while these activities are taking place. Vegetation treatments would 

increase the amount of fugitive dust above the no-action alternative (Table 3-30). The dust generated 

by these activities, though certain to occur, would be minimal compared to emissions generated 

annually by other activities in Siskiyou County (14,364 tons). No additional analyses of fugitive dust 

were estimated because Siskiyou County is in attainment, and a conformity determination is not 

required. 

Table 3-30. Estimated amount of fugitive dust generated annually by the three alternatives 

proposed for the Eddy Gulch LSR Project. 

Alternative A Alternative B Alternative C 

Log haul fugitive dust emissions for the Eddy Gulch 

LSR Project, per year, with implementation of RPMs 

for 3-year haul. 

0 2.35 tons 3.25 tons 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-56 Chapter 3: Affected Environment and Environmental Consequences

Effects from project implementation would be short term, and use of RPMs would reduce those 

effects. The California Air Resources Board has promulgated changes to Title 17 Smoke Management 

Guidelines for Agricultural Burning and Prescribed Fires. The new regulations require (prior to onthe-ground implementation of burning) submission of smoke management plans to the local air 

district for each burn plan and require permitting and increased coordination between burners and the 

local air district. The Forest Service, Region 5 has also signed a Memorandum of Understanding on 

Prescribed Burning on July 13, 1999, with the California Air Resources Board. In this memorandum, 

the Forest Service agrees to limit public exposure to smoke by considering all practical alternatives to 

burning, applying all appropriate emission-reduction techniques, limiting the amount of material to be 

burned on any one day based on meteorological and air quality conditions, and consultation with the 

local district and Interagency Fire Forecast Warning Unit. During treatment activities, fugitive dust 

would be reduced 50–80 percent because minimal soil moistures must be present for mechanical 

equipment to operate, and roads would be treated with water to reduce dust. 

Decrease in Wildfire Emissions—Implementation of the project would have a beneficial 

indirect effect because the size and intensity of wildfires in the Assessment Area would be reduced 

and therefore result in fewer emissions. 

Cumulative Impacts. Implementation of the Eddy Gulch LSR Project and construction of a 

fuelbreak system west of Black Bear Ranch would increase emissions over the short term; however, 

adverse effects on sensitive receptors would be minimized because the timing and duration of 

activities can be managed through established RPMs (mitigation measures) to reduce those emissions. 

Compared to the no-action alternative, reduced emissions from future wildfires would be reduced 

because the size and intensity of the wildfire would be less, compared to the no-action alternative. 

Conclusion. Implementation of the project would increase emissions in the short term during 

treatment activities; however, the effects would be minimal compared to a wildfire. There would be 

an indirect beneficial effect because emissions from future wildfires would be reduced. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.4 – Wildlife and Habitat 3-57 

3.4 Wildlife and Habitat ___________________________________ 

3.4.1 Introduction 

The Eddy Gulch Late-Successional Reserve (LSR) Project is an ecosystem-based approach for 

maintaining and conserving late-successional forest ecosystems, which serve as habitat for latesuccessional-forest dependent species. This section discloses potential effects on wildlife that occur in 

the project Assessment Area and prefer the late-successional habitat, the most notable is the northern 

spotted owl (NSO) and its designated Critical Habitat protected through the Endangered Species Act 

(ESA), but also included are the Northern goshawk and the Pacific fisher. Existing habitat conditions 

were reviewed as well as preferred habitat conditions. The current conditions were used to discuss the 

potentially affected environment and therefore the impacts to each individual species listed in 

Section 1.3. All other Forest Sensitive Species and all MIS species and associations with potential to 

occur in or near the Project are addressed in detail in the Wildlife and Habitat Resources Report 

(2009) and the Biological Assessment/Biological Evaluation (BA/BE). 

3.4.2 Methodology 

3.4.2.1 Analysis Methods and Assumptions 

Wildlife species of particular interest and their associated habitats were analyzed using a 

combination of field assessments, aerial photos, and Geographic Information System (GIS) habitat 

maps based on the 1995 vegetation dataset or the stream dataset supplied by the Klamath National 

Forest. The 1995 dataset is the best available information on the vegetation in the Eddy Gulch LSR. 

Field assessments conducted by wildlife biologists and silviculturists concluded that, in general, the 

trend since development of the 1995 vegetation model has been continued forest growth and 

accumulation of hazardous fuels. 

Northern Spotted Owl 

Definitions of NSO nesting/roosting, foraging, and dispersal habitat for the NSO were translated 

into a model (USFS 1999:App. G) for use with the timber type vegetation data layer described in the 

1995 Klamath Land and Resource Management Plan (LRMP) (USFS 1995). This model (Klamath 

NSO Habitat Layer, updated in 1998) was used to estimate the amount of suitable habitat available 

for NSOs in the Eddy Gulch LSR and in the project Assessment Area (Private lands were excluded in 

order to be consistent with the Forestwide LSR Assessment [USFS 1999, p. 2-25]). The NSO habitat 

suitability model may slightly underestimate the amount of currently suitable nesting/roosting and 

foraging habitat because of recent forest growth. The habitat model was used to analyze the habitat in 

and around NSO home ranges. Most of the west side of the Assessment Area has been extensively 

surveyed for NSOs for the past 22 years (Franklin unpubl. data), and most of the remaining area was 

surveyed in 2007–2008 (Herrera 2008). The NSO habitat model was also used for other forestdependent species such as the northern goshawk and Pacific fisher. 

Pacific Fisher 

The Klamath National Forest has independently surveyed and is working with the FWS to survey 

fisher and fisher habitat. For example, 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-58 Chapter 3: Affected Environment and Environmental Consequences

 Camera station surveys were conducted on the Happy Camp, Scott River, and Salmon 

River Ranger Districts in the early 1990s. There has been a re-survey of areas surveyed in 

the 1990s in the vicinity of the Collins Baldy and Mt. Ashland LSRs (in conjunction with 

Timber Products and the FWS). 

 This is the fourth year of participating in a cooperative fisher genetic survey to determine 

preliminary population estimates for an area in northern Siskiyou County (in conjunction 

with Timber Products, California Department of Fish and Game, and the FWS). 

 A project to develop a habitat model is called the “Distribution and Habitat Suitability for 

Fishers in the Eastern Klamath and South Cascades Bioregions in Northern California 

Study Area.” The study area covers approximately 9,800 square kilometers (approximately 

6,089 square miles) and includes portions of Siskiyou, Shasta, and Trinity counties in 

northern California. Public forest lands include wilderness, late successional reserve, and 

general forest lands of the Klamath, Shasta-Trinity, and Rogue River National Forests. 

Private holdings vary from large contiguous industrial timberlands to checkerboard patterns 

and smaller private individual holdings. According to the FWS, the survey protocol is 

consistent with previous sampling and modeling efforts and ongoing development of 

landscape habitat models being conducted at USDA Pacific Southwest Research Station. 

The project used a robust Primary Survey Unit design associated with Forest Inventory and 

Analysis grid cells. For the project, the current model for the Klamath Region (Carroll et al. 

2005) will be used as a launching point in development of a model for the eastern Klamath 

and southern Cascades bioregion. Information from previous survey efforts, which used 

other protocols, will be used to evaluate the final FWS model. Jeffrey Dunk, from 

Humboldt State University, is currently under agreement with the FWS to conduct the 

habitat modeling and analysis in cooperation with Bill Zielinski, at Pacific Southwest 

Research Station. 

 Another project, which began in October 2009 in the vicinity of the Mt. Ashland Fuels 

Reduction Project on the Klamath National Forest, is part of a regional study to assess 

changes in fisher movement patterns and habitat selection between pre- and post-treatment 

monitoring, at both individual and local population scales and to evaluate the short-term 

impact of treatments. According to the FWS, this study will be combined with other 

replicates of the study into a regional analysis on the impacts of treatment alternatives on 

fishers. The study will be used to generate recommendations on how managers can achieve 

fuel reduction objectives while minimizing impacts on fishers. 

3.4.2.2 Scope of the Analysis 

Analysis Area. The Eddy Gulch LSR Project Assessment Area encompasses the 37,239 acres of 

the LSR that were considered for treatment (refer to Chapter 2, Section 2.5.1.4). The area analyzed 

for most wildlife species includes only 25,696 acres in the Assessment Area that are actually proposed 

for treatment (the treatment units that include FRZs, Rx Units, and RS treatments along emergency 

access routes) and is thus referred to as the analysis area. However, the analysis area for wildlife and 

habitat extends beyond the Assessment Area for species that occur outside that area and that may be 

indirectly affected by the proposed treatments. These species include the NSO, northern goshawk, 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.4 – Wildlife and Habitat 3-59 

fisher, and some aquatic species. For each NSO activity center, the estimated home range (1.3-mile 

radius) was analyzed, and in many cases, this home range radius fell outside of the Assessment Area. 

A similar analysis was done for goshawks using a 1-mile radius. The analysis area for Pacific fisher 

includes the treatment units, as well as a 1.5- to 2.0-mile buffer that would contain one or more 

Pacific fisher home ranges. The analysis area for some aquatic species extended to the North and 

South Forks of the Salmon River adjacent to the Assessment Area, if it was reasonable that project 

effects could be detected beyond the Assessment Area. The species listed in Table 3-31 were 

identified by the Klamath National Forest or the USFWS as having the potential to occur in or near 

the Eddy Gulch LSR and in habitats either present on the LSR or with the potential to occur on the 

LSR. 

Table 3-31. Wildlife species of special interest with the potential to occur in or near the Eddy Gulch 

LSR, Siskiyou County, CA. 

Common Name Statusa Preferred Habitat 

Potential Presence 

in Assessment Areab

Federally Listed or Candidate Species 

NSO 

(Strix occidentalis caurina) 

FT, CH Prefers old-growth or late-successional 

forests but can also occur in managed 

forest with dense structure. 

Occurs. Known to occur in the 

Assessment Area. 

Forest Service Sensitive and State-listed Species 

Tehama chaparral 

(Trilobopsis tehemana) 

FSS, Prefers talus, rock outcrops, or caves with 

subsurface moisture; refugia includes leaf 

litter, particularly deciduous leaf litter, and 

woody debris in forested habitat. 

Low. Suitable habitat exists within 

the Eddy Gulch LSR; species is not 

known to occur in the LSR but 

reportedly occurs on the Salmon 

River Ranger District (Duncan et al. 

2003). 

Southern torrent 

salamander 

(Rhyacotriton variegatus) 

FSS Cold, clear, well-shaded streams, waterfalls 

and seepages, particularly those running 

through talus and under rocks all year. 

Found from sea level to 4,500–5,000 feet. 

Unknown. Suitable habitat exists but 

the Eddy Gulch LSR appears to be 

at the edge of the species’ range. 

Cascades frog 

(Rana cascadae) 

FSS, MIS Small streams, ponds, lakes in meadows or 

open coniferous forest. 

Low. Occurs near the LSR, but there 

is only one known pond (private) and 

no lakes or languid streams in the 

Assessment Area. 

Foothill yellow-legged frog 

(Rana boylii) 

FSS Rocky streams and rivers in various 

habitats. Usually in streams with abundant 

boulders and cobbles and with mix of sun 

and shade. 

Moderate. The Assessment Area 

contains suitable habitat, but there 

are no reported records from the 

area. 

Western pond turtle 

(Actinemys marmorata) 

FSS Slack- or slow-water aquatic habitat with 

many basking sites. Hatchlings require 

shallow water habitat with relatively dense 

submergent or short emergent vegetation in 

which to forage. 

Moderate. Turtles may occur in lowgradient streams near the North and 

South Forks of the Salmon River or 

in ponds on private property. 

Bald eagle 

(Haliaeetus leucocephalus) 

FSS, 

SE 

Forages over a variety of open habitats. 

Nests near tops of large trees in association 

with open water. 

Low. There is no high-quality 

foraging habitat within 2 miles of the 

Assessment Area, but the lower 

Salmon Rivers may provide foraging 

habitat. 

Northern goshawk 

(Accipiter gentilis) 

FSS Mature conifer forest. Nests usually in 

dense stands with open understory, often 

near water. 

Occurs. Known to occur in the 

Assessment Area. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

Table 3-31. Wildlife species of special interest with the potential to occur in or near the Eddy Gulch 

LSR, Siskiyou County, CA (continued).

3-60 Chapter 3: Affected Environment and Environmental Consequences

Common Name Statusa Preferred Habitat 

Potential Presence 

in Assessment Areab

Peregrine falcon 

(Falco peregrines anatum) 

Prominent cliffs or other precipitous features 

with ledges or other platforms. 

Occurs. Known from two nesting 

sites just outside of the Project Area.

FSS and State-listed Species 

Great gray owl 

(Strix nebulosa) 

FSS, 

SE 

Mid- to high-elevation mature conifer stands 

adjacent to meadows with pocket gophers 

and/or voles. 

Low. There are no meadows or 

herbaceous habitats, other than 

small scattered patches. 

Willow flycatcher 

(Empidonax traillii brewsteri) 

FSS, 

SE 

Large patches of shrubby willows along 

streams or in wet meadows, generally over 

2,000 feet elevation. Also wet scrub 

following disturbance. 

Low. Willow patches may occur in 

Riparian Reserves, but these are 

most likely too small or shaded. 

Pallid bat 

(Antrozous pallidus) 

FSS Many habitat types, especially open dry 

habitats with rocky areas for roosting. Uses 

caves, buildings, hollow trees, rock 

outcrops, bridges, and many other roost 

sites. 

High. Suitable foraging and roosting 

habitat is widespread. 

Townsend’s big-eared bat 

(Corynorhinus townsendii) 

FSS Many habitats but may prefer moist areas. 

Roosting strongly associated with cave-like 

features, which may include buildings, 

tunnels, other man-made structures, usually 

cool. Sensitive to disturbance. 

Occurs. Known to occur in caves 

just outside of the Assessment Area.

American pine marten 

(Martes americana sierrae) 

FSS Late-successional forest, typically in 

relatively wet high-elevation forests above 

Ponderosa pine and/or mixed-conifer 

forests where winter snow is persistent (that 

is, fir forests above 5,000 feet). 

Moderate. Most likely to occur at 

high elevations. Recent surveys 

detected martens in the Marble 

Mountain Wilderness. 

Pacific fisher 

(Martes pennanti pacificus) 

FCc, FSS Mature, dense mid-elevation conifer forests 

with hardwoods, large snags and logs, and 

small brushy openings with diverse prey. 

Occurs. Known to occur in the 

Assessment Area. 

California wolverine 

(Gulo gulo luteus) 

FSS, 

ST 

Montane regions with persistent spring 

snowpack and openings in old-growth or 

mature forests that are isolated from man. 

Can travel widely. 

Low. Historical in region, but there 

are no recent records from this 

region. 

MIS: River and Stream Association 

Tailed frog 

(Ascaphus truei) 

MIS Cool, perennial streams in coniferdominated habitats; occurs more frequently 

in mature or late-successional stands, and 

uses submerged rocks and logs in streams 

for cover. 

Occurs. Known to occur in the 

Assessment Area.

Cascades frog 

(Rana cascadae) 

MIS, FSS Small streams, ponds, lakes in meadows or 

open coniferous forest. 

Low. Occurs near the LSR, but there 

is only one known pond (private) and 

no lakes or languid streams in the 

Assessment Area. 

American dipper 

(Cinclus mexicanus) 

MIS Along clear, fast-flowing, unpolluted 

perennial streams and rivers with rock 

faces, waterfalls, large boulders, or other 

features that provide similar niches for 

nesting. 

Occurs. Known to occur in the 

Assessment Area.

Northern water shrew 

(Sorex palustris) 

MIS Montane riparian habitats. High. Most likely common along 

most streams. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Table 3-31. Wildlife species of special interest with the potential to occur in or near the Eddy Gulch 

LSR, Siskiyou County, CA (continued).

Section 3.4 – Wildlife and Habitat 3-61

Common Name Statusa Preferred Habitat 

Potential Presence 

in Assessment Areab

Long-tailed vole 

(Microtus longicaudus) 

MIS Montane riparian, wetlands, grasslands, 

and wet meadow habitats. 

Moderate. Likely to be common in 

suitable habitat, but meadow-like 

habitats are sparse in the 

Assessment Area. 

MIS: Marsh/Lake/Pond Association 

Western pond turtle 

(Actinemys marmorata) 

MIS, FSS Slack- or slow-water aquatic habitat with 

many basking sites. Hatchlings require 

shallow water habitat with relatively dense 

submergent or short emergent vegetation in 

which to forage. 

Moderate. Turtles may occur in lowgradient streams near the North and 

South Forks of the Salmon River or 

in ponds on private property. 

MIS: Hardwood Association 

Acorn woodpecker 

(Melanerpes formicivorus) 

MIS Hardwood, hardwood-conifer, or conifer 

habitats with mature oaks and snags. 

High. Most likely in open oak/conifer 

habitats at lower elevations and 

perhaps locally common. 

Western gray squirrel 

(Sciurus griseus) 

MIS Mature oak and mixed-conifer habitats, 

requiring large trees, mast crops, and 

snags. 

Occurs. Known to occur in the 

Assessment Area.

MIS: Snag Association 

Vaux’s swift 

(Chaetura vauxi) 

MIS Late-successional coastal forests, but also 

known to occur in other conifer-dominated 

forests below the zone of true firs, burned 

forests, and in towns with no canopy cover 

as long as large hollow trees or chimneys 

are available for nesting. 

Moderate. Suitable habitat is 

widespread, but Vaux’s swifts are 

generally uncommon and local. 

Red-breasted sapsucker 

(Sphyrapicus ruber) 

MIS Montane riparian, montane hardwoodconifer, mixed-conifer, and true fir forests, 

preferring sites near meadows, clearings, or 

streams. 

Occurs. Known to occur in the 

Assessment Area.

Downy woodpecker 

(Picoides pubescens) 

MIS Riparian deciduous and associated 

hardwood and conifer habitats and closely 

associated with riparian softwoods. 

High. Most likely in ripariandominated woodlands at lower 

elevations where it is probably 

uncommon in the Assessment Area. 

Hairy woodpecker 

(Picoides villosus) 

MIS Open to moderately dense stands of mature 

conifers with snags of sparse to 

intermediate density; often favors burned 

stands. 

Occurs. Known to occur in the 

Assessment Area.

White-headed woodpecker 

(Picoides albolarvatus) 

MIS Montane coniferous forests up to higherelevation lodgepole pine and red fir 

habitats. 

Occurs. Known to occur in the 

Assessment Area.

Black-backed woodpecker 

(Picoides arcticus) 

MIS Confined to recently burned lodgepole pine, 

red fir, or other higher-elevation forests; 

may occur in unburned forests if adequate 

prey is present. 

Low. The Eddy Gulch LSR is on the 

edge of the species’ range, but it 

could occur in response to large 

fires. 

Pileated woodpecker 

(Dryocopus pileatus) 

MIS Mature conifer or hardwood-conifer habitats 

near permanent water; most common in 

late-successional and old-growth mixedconifer forests with moderate to dense 

canopy cover and large numbers of snags, 

stumps, and logs. 

Occurs. Known to occur in the 

Assessment Area.
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

Table 3-31. Wildlife species of special interest with the potential to occur in or near the Eddy Gulch 

LSR, Siskiyou County, CA (continued).

3-62 Chapter 3: Affected Environment and Environmental Consequences

Common Name Statusa Preferred Habitat 

Potential Presence 

in Assessment Areab

Other 

Klamath shoulderband 

(Helminthoglypta talmadgei) 

Formerly 

S&M 

Cat. D 

Talus slopes and rockslides, often in 

limestone substrates, especially near 

springs or streams. 

Occurs. Known to occur in the 

Assessment Area.

Tehama chaparral 

(Trilobopsis tehemana) 

FSS; 

Formerly 

S&M, 

Cat. A 

Prefers talus, rock outcrops, or caves with 

subsurface moisture; refugia includes leaf 

litter, particularly deciduous leaf litter, and 

woody debris in forested habitat. 

Low. Suitable habitat exists within 

the Eddy Gulch LSR; species is not 

known to occur in the LSR but 

reportedly occurs on the Salmon 

River Ranger District (Duncan et al. 

2003). 

Notes: a. Categories of special status recognition used by federal and state agencies. Not all categories imply legal protection. 

CH = Critical Habitat FC = Federal Candidate for Listing 

FT = Federal Threatened FSS = Forest Service Sensitive Species 

SE = State (California) Endangered ST = State (California) Threatened 

 b. Definitions of Potential to Occur 

Unknown: The probability of occurrence is unknown because the Eddy Gulch LSR is near the margin of the 

species’ known distribution; suitable habitat is available, but some species, especially those with limited 

dispersal capability, are limited by factors (geological history, for example) other than habitat structure. 

Low: Some habitat features may occur in the Eddy Gulch LSR, but important habitat features are lacking and 

habitat is marginal. If the species does occur, it is most likely a transient or occurs in very small 

numbers. 

Moderate: The most important habitat features present in the Eddy Gulch LSR, but most or all of the area lacks at 

least one important habitat component; or, habitat exists but species is near the edge of its known 

distribution. 

High: Species is expected to occur but has not been documented in the Eddy Gulch LSR. Habitat in Eddy 

Gulch LSR has all necessary components, species observed elsewhere in similar habitats. 

Occurs: Species documented or known to occur in the Assessment Area. 

 c. On April 8, 2004, the USFWS determined that fisher populations in California, Oregon, and Washington warrant 

protection under the ESA but that listing under the act is “precluded by the need to take other listing actions of higher 

priority” (USFWS 2004). Candidate Notice of Review published December 6, 2007, in Federal Register, Vol. 72, 

No. 234 gave this species a listing priority of 6. 

Analysis Period. The analysis period extends approximately 20 years, which is the maximum 

anticipated duration of the effectiveness of the proposed fuel reduction activities. The time frame for 

the effects analysis is 5 years for short-term effects and up to 30 years for long-term effects on 

wildlife habitat. The western slope of the Klamath Mountain in the Klamath National Forest has a 

relatively high rate of vegetation establishment and growth due to high annual precipitation and 

productive soils. Within this time frame (up to 20 years following treatment), vegetation, and thus 

habitat, would have sufficient opportunity to increase in canopy cover, basal area, and tree density to 

a point where subsequent treatments may need to be considered for wildlife habitat protection. 

3.4.2.3 Intensity of Effects Definitions 

“Intensity” refers to the severity of effects or the degree to which the action may adversely or 

beneficially affect a resource. The intensity definitions used in this analysis are described below. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.4 – Wildlife and Habitat 3-63

Negligible. An action would result in no observable or measurable effects on individual survival 

or on native wildlife populations, their habitats, or the natural processes sustaining them. Occasional 

individual responses to disturbance could be expected but without interference to reproduction or 

other factors affecting survival. 

Minor. An action would result in detectable effects on individuals or in small, short-term changes 

to populations, but it would not be expected to cause any measurable long-term effects on native 

species, their habitats, or the natural processes sustaining them. 

Moderate. An action would result in detectable effects on native wildlife populations, their 

habitats, or the natural processes sustaining them. Key ecosystem processes may experience 

disruptions that would be outside the natural range of fluctuation (but would return to natural 

conditions). Sufficient habitat would remain functional to maintain viability of native wildlife 

populations. 

Major. An action would result in large effects on native wildlife populations, their habitats, or the 

natural processes sustaining them. Key ecosystem processes would be disrupted for long periods or 

permanently. 

3.4.2.4 Measurement Indicators 

The affected environment for each species is described in terms of the amount and type of habitat 

present on the Klamath National Forest, and effects are estimated in terms of habitat amount and/or 

quality. The amount and type of habitat are described in terms of 

 acres of habitat or miles of streams; 

 canopy closure; 

 basal area; 

 large trees (diameter at breast height [dbh] of over 24 inches); 

 snags (over 15 inches dbh); 

 large CWD (over 15 inches dbh and longer than 10 feet); and 

 hardwoods (presence of). 

However, not all features will be used to describe habitat conditions for all species. 

3.4.3 Affected Environment (Existing Conditions) 

Approximately 45,220 acres of the 61,900-acre Eddy Gulch LSR (73 percent) are capable of 

producing late-successional habitat (USFS 1999, Table 2.38). Currently, at least 18,780 acres (or 

about 42 percent of the capable late-successional habitat [USFS 1999]) are vegetated by latesuccessional habitat. The combined acres vegetated by late-successional and mid-successional forest 

total 35,710 acres (or about 79 percent of the capable late-successional habitat). Relative to other 

LSRs in the Klamath National Forest, the Eddy Gulch LSR ranks moderate for both the proportion of 

late-successional and combined mid-successional/late-successional forested habitat (USFS 

1999, 2:49). 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-64 Chapter 3: Affected Environment and Environmental Consequences

The USFWS identified four priority protection areas (described in Section 2.5.1.4 of Chapter 2 

and depicted on Map A-3 in Appendix A), which contain large blocks of high-quality NSO habitat, 

provide for small clusters of NSO populations within the Eddy Gulch LSR, or are important on a 

landscape connectivity scale. 

3.4.3.1 Species Considered 

The species listed in Table 3-31 above were identified by the Klamath National Forest or the 

USFWS as having the potential to occur in or near the Eddy Gulch LSR and in habitats either present 

on the LSR or with the potential to occur on the LSR. All of the species that have potential to occur 

on or near the Eddy Gulch LSR Project are addressed in detail in the Wildlife and Habitat Resources 

Report (2009). 

3.4.3.2 Federally Listed Species 

Northern Spotted Owl. The NSO is the only terrestrial wildlife species listed under the ESA that 

occurs or has habitat in the Eddy Gulch LSR. Currently, the primary range-wide threats to NSO are 

habitat loss from timber harvest, habitat loss from fire (or other natural events such as insects and 

disease), and barred owls (Strix varia), which have expanded into the range of NSO (USFWS 2008a). 

Fire is now considered a greater threat to NSO habitat on federal lands than timber harvest or 

other management activities, especially in the relatively dry Klamath Province of Oregon and 

California, where loss of NSO habitat from fire has exceeded habitat loss from timber harvest since 

1994 (USFWS 2008a). Recognition of the threat of fire stimulated the USFWS to identify recovery 

actions unique to the Klamath Province, including developing a strategy to achieve sustainable, fireresilient and fire-resistant forests (Recovery Action 8) and the creation of a Dry Forest Landscape 

Work Group (Recovery Action 9) that will reexamine the effectiveness of the LSR system in the 

dynamic landscapes of the Klamath Province (USFWS 2008a).

Barred owls have displaced NSOs from many areas and are largely responsible for the alarming 

7.1 percent annual decline of NSOs in Washington (Lint 2005). Whether the NSOs will be able to 

persist in areas with barred owls is unknown, but evidence to date suggests that NSOs are more likely 

to persist in, or be displaced into, drier areas, steep slopes, or higher elevations because barred owls 

prefer riparian areas with gentler terrain (Gutiérrez et al. 2007; USFWS 2008a). Individual barred 

owls were first detected in the Assessment Area in 2003 and have been occasionally detected 

(J. Rockweit, pers. comm. 2008), but so far, none of the NSOs tracked by Franklin’s demographic 

study group have been displaced by barred owls, and no barred owl pairs have been observed in the 

Assessment Area (J. Rockweit, pers. comm. 2008). These factors suggest that the Eddy Gulch LSR, 

compared with other LSRs, may be relatively inhospitable to barred owls and an important refugium 

for NSOs. 

NSOs inhabit older forests because they contain the necessary structures for nesting, roosting, 

foraging, and dispersal (Forsman et al. 1984; Gutiérrez 1996; LaHaye and Gutiérrez 1999). The 

habitat features that support nesting and roosting include: 

 a multilayered, multispecies canopy with overstory trees larger than 30 inches dbh; 

 moderate to high canopy closure (60 to 90 percent); 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.4 – Wildlife and Habitat 3-65

 a high incidence of trees with large cavities or other types of deformities (such as broken 

tops, mistletoe infections, and other evidence of decadence) (White 1996; LaHaye and 

Gutiérrez 1999); 

 numerous large snags and an abundance of fallen trees and coarse woody debris (CWD); 

 sufficient open space below the canopy for NSOs to fly (Thomas et al. 1990); and 

 basal area in nest stands that may often exceed 200 square feet/acre (Solis and 

Gutiérrez 1990). 

Table 3-32 compares the minimum habitat requirements (considered by the USFWS 2008b to be 

necessary for supporting nesting/roosting in interior northern California) with current conditions in 

the project Assessment Area. The minimum habitat requirements are based on research (Franklin 

et al. 2000) and observational studies (USFWS 2008b) in the Klamath Mountains and California 

Cascades physiographic provinces. 

The nesting/roosting habitat currently occupied by NSOs in the Assessment Area has features 

consistent with those described in Table 3-32 (second column), but there are no quantitative data for 

occupied nesting/roosting stands in the Eddy Gulch LSR. The mid- to late-successional Douglas-fir 

stands sampled for this project (see Table 3-32 [fourth column] and Table 3-33) were mostly along 

ridges and not necessarily representative of nesting/roosting habitat that often occurs on the lower 

third of slopes, within 0.5-mile core areas more frequently used by owls. 

Table 3-32. Minimum NSO habitat requirements compared to current conditions. 

Minimum NSO Nesting / 

Roosting 

Habitat Requirement*

Current Nesting / 

Roosting Habitat 

Occupied by NSO in the 

Assessment Area*

Minimum NSO 

Foraging 

Habitat Requirement 

Current Foraging Habitat 

Occupied by NSO in the 

Assessment Area*

Basal area ranges from 150 

to more than 210 square 

feet per acre 

Average basal area of 

266 square feet per acre 

Mix of basal areas ranging 

from 120 to over 180 square 

feet per acre 

Average basal area ranges 

from 216 square feet per 

acre in Douglas-fir stands to 

355 square feet per acre in 

red fir stands 

Eight trees per acre over 

26 inches dbh 

Average 20 trees per acre At least 5 trees per acre 

over 26 inches dbh 

Average 5 to 43 trees per 

acre larger than 24 inches 

dbh 

At least 60 percent canopy 

cover 

Average 72 percent canopy 

cover 

Mix of canopy closures 

ranging from 60 to 

100 percent 

Average 58 to 73 percent 

canopy cover 

Note: *USFWS 2008b. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-66 Chapter 3: Affected Environment and Environmental Consequences

Table 3-33. Current stand structure on ridgetops where proposed M Units are located. 

SAF 

Forest Typea CWHR Successional Stageb TPAc TPA 

>10" 

TPA 

>24" 

BAc/ac 

>10” 

Average 

dbhc >10" 

Canopy 

Closure 

(percent) 

Douglas-fir Mid-successional (MS) 441 135 5 192 16.1 73 

Douglas-fir MS/Late-successional 

(LS) 235 120 

20 249 

19.5 72 

White Fir MS 299 190 9 302 17.1 61 

White Fir MS/LS 275 124 29 284 20.5 58 

Red Fir LS 613 113 43 350 23.8 59 

Mixed-conifer LS 255 159 28 320 19.2 69 

Notes: 

a. SAF = Society of American Foresters. 

b. CWHR = California Wildlife Habitat Relationship. 

c. TPA = trees per acre; BA = basal area; dbh = diameter at breast height.

Foraging habitat generally has attributes similar to those found in nesting/roosting habitat but 

may not always support successful nesting (USFWS 1992). Although general attributes, such as large 

trees, are common to foraging habitat across the NSO range, Irwin et al. (2007) suggest that optimal 

foraging conditions are found when the basal area is between 160 to 320 square feet per acre. The 

variability is in response to the main species of local prey (northern flying squirrels [Glaucomys 

sabrinus], or woodrats [Neotoma spp.]), which are the predominant prey both in biomass and 

frequency (Forsman et al. 1984; Zabel et al. 1995; Ward et al. 1998; Forsman et al. 2004). Woodrats 

are generally the dominant prey item in the drier forests typically found in the southern portion of the 

NSO range (Forsman et al. 1984; Zabel et al. 1995; Sztukowski and Courtney 2004), which includes 

the Eddy Gulch LSR (J. Rockweit, pers. comm. 2008). Dusky-footed woodrats (N. fuscipes) generally 

reside in brushy habitats (Williams et al. 1992), and densities have been found to be highest in 20- to 

30-year-old sapling/bushy pole timber (Sakai and Noon 1993) or, in older forests, typically near 

riparian areas with fruit- and mast-producing hardwoods (Carey et al. 1999). Forests with little 

understory appear to be poorly suited for dusky-footed woodrats but are used by flying squirrels. 

Where wood rats are the primary prey, studies have found that, although NSOs selectively forage in 

areas with large trees (Call et al. 1992; Irwin et al. 2007), they also selectively forage along forest 

edges (Zabel et al. 1995; Ward et al. 1998) and riparian areas (Irwin et al. 2007). Canopy cover may 

not be a strong predictor of foraging habitat (Irwin et al. 2007), but NSOs typically avoid areas with 

less than 40 percent canopy (Call et al. 1994). Based on research (USFWS 2008a, 2008c) and 

observational studies in the Klamath Mountains and California Cascades physiographic provinces, the 

USFWS (2008b) considers the minimum habitat requirements necessary to support foraging in 

interior northern California (also refer to Table 3-32 above) to include a combination of stands that 

contain a mix of basal areas ranging from 120 to over 180 square feet per acre, at least 5 trees per acre 

over 26 inches dbh, a mix of canopy closures ranging from 60 to 100 percent, and stands that contain 

a mix of basal areas ranging from 80 to 120 square feet per acre and at least 40 percent canopy 

closure. The mid- to late-successional stands sampled for this project contained average basal areas 

that ranged from 216 square feet per acre in Douglas-fir stands to 355 square feet per acre in red fir 

stands, 58 to 73 percent canopy cover, and from 5 to 43 trees per acre larger than 24 inches dbh (refer 

to Table 3-33 above). 

Dispersal habitat, at a minimum, consists of stands with adequate tree size and canopy closure to 

provide protection from avian predators and at least minimal foraging opportunities (USFWS 2008a). 

Neither stand- nor landscape-level forest attributes have been thoroughly evaluated in terms of 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.4 – Wildlife and Habitat 3-67

facilitating successful dispersal (Buchanan 2004), but dispersing juveniles that use open areas, such as 

clearcuts, suffer increased mortality if they cannot find cover (Franklin and Gutiérrez 2002). 

However, based on the movement of radio-tracked owls, openings do not appear to act as barriers to 

dispersal until they reach the size of large nonforested valleys or large water bodies (Forsman et al.

2002). It is unlikely that there are any limitations to NSO dispersal in the Assessment Area because 

most of the area is forested with at least 40 percent canopy cover, and adjoining drainages are 

typically connected by at least narrow patches of forest, even where most of the surrounding 

vegetation is dominated by nonforest types. 

The Eddy Gulch LSR provides approximately 12,577 acres of nesting/roosting habitat and 

16,220 acres of foraging habitat, for a total of 28,797 acres (47 percent of the 61,900-acre LSR) of 

NSO habitat (USFS 1999). Habitat acreages are useful, but acreage does not reflect other factors that 

affect NSO habitat use or their influence on NSO survival or reproduction. The most recent 

landscape-level analyses found that, in the southern portion of the subspecies’ range, highest fitness is 

achieved where a mosaic of large patches of late-successional habitat are interspersed with other 

vegetation types that increase the amount of edge habitats (Franklin et al. 2000; Franklin and 

Gutiérrez 2002; Zabel et al. 2003; Olson et al. 2004). Homogeneous expanses of older forests, while 

generally supporting greater adult survival than younger forests or small patches of older forests 

(Franklin et al. 2000; Olson et al. 2004; Dugger et al. 2005), did not support a stable or increasing 

population (Franklin et al. 2000; Olson et al. 2004; also see Dugger et al. 2005). Franklin et al. (2000) 

hypothesized that a mosaic of different vegetation and successional stages may offer a stable prey 

resource for NSOs while providing adequate protection from predators. In the Eddy Gulch LSR, 

nesting/roosting and foraging habitat are fairly widely distributed in patches that range in size from 

less than a few acres to more than 500 acres. Although some patches of NSO habitat are isolated by 

nonhabitat, most patches of nesting/roosting habitat are connected by suitable foraging or dispersal 

habitat. Overall, the size, distribution, and connectivity of nesting/roosting habitat and foraging 

habitat vary among NSO territories, but in general, the pattern suggests high habitat fitness potential 

(Franklin et al. 2000). 

The USFWS (Johnson et al. 2006) also used a landscape-level analysis to examine eight abiotic 

factors to help distinguish 36 activity centers from unused sites in three Klamath National Forest 

LSRs. The USFWS found that activity centers were associated with basin-like topography, the lower 

half of slopes, and streams. Additionally, numerous published articles have demonstrated that NSOs 

prefer use of lower-slope or mid-slope sites for foraging, roosting, and nesting, especially as sites are 

related to drainages or surface water (see Solis and Gutiérrez 1990; Blakesley et al. 1992; and Lahaye 

and Gutiérrez 1999). As might be expected, these abiotic habitat selection features coincide with 

conditions that favor forest growth and historically were relatively resistant to fire. Most of the 

activity centers in the Assessment Area are located in areas with similar topographic characteristics; 

that is, core areas are found no higher than mid-slope and are typically centered on prominent 

drainages. 

Distribution and Population Trends. A total of 23 activity centers have been identified within 

the boundary of the Eddy Gulch LSR, 20 of which are in or overlapping the project Assessment Area 

(see Maps A-1a and A-1b in Appendix A of the Wildlife and Habitat Report). However, scattered 

sections in the Assessment Area, totaling 10 to 15 percent of the LSR, have not been surveyed, and at 

least three activity centers have not been surveyed for the past 10 years. The mapped activity centers 

are widely distributed across the LSR, but almost all occur below 5,500 feet on the lower one-half to 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-68 Chapter 3: Affected Environment and Environmental Consequences

two-thirds of the slope and in areas with basin-like topography, consistent with the findings from 

Johnson et al. (2006). Areas that apparently lack NSOs, but that have physical attributes (such as lowelevation basins) associated with sustainable activity centers, include China Gulch, Counts Gulch, 

Crawford Creek southwest of Grouse Point, and Butcher Gulch. Butcher Gulch may currently contain 

sufficient nesting, roosting, and foraging habitat, but the other areas may lack sufficient NSO habitat 

at this time. 

The only portion of the Assessment Area that has been surveyed regularly is the long-term 

Klamath demographic study area on the west end of the Eddy Gulch LSR. This area has been 

surveyed annually since at least 1986 and includes five mapped activity centers3

 that are included in 

the data set analyzed by Franklin et al. (2000) and other demographic analyses, such as the 18-year 

(1985–2003) estimates of population growth, survivorship, and reproduction (Lint 2005; Anthony 

et al. 2006). These analyses found that the NSO has experienced a range-wide decline of about 

3.7 percent per year, and the northwestern California population has declined about 1.5 percent per 

year. Annual adult survival in the northwestern California population was 86.9 percent, and greater 

than the 85 percent thought to be key to stationary populations (Lint 2005), but has also been 

declining. Adult females fledged 0.33 young per year, which was slightly less than the range-wide 

average. The number of young fledged annually in the five activity centers tracked by Franklin in the 

Eddy Gulch LSR averaged 0.38 over the last 22 years. 

USFWS Section 7 Consultation Home Range Assessment. The amount of suitable habitat in a 

home range has been shown to influence NSO productivity and survivorship (Bart 1995; Franklin 

et al. 2000; Dugger et al. 2005). Consequently, when evaluating potential project effects on an NSO 

activity center, the USFWS evaluates the amount and type of habitat within an owl’s home range to 

assess the quality or apparent fitness potential of that activity center. The average home range size 

varies geographically (USFWS 1990; Zabel et al. 1995), but the estimated annual home range in the 

Klamath Province is approximately 3,330 acres. For planning purposes, the USFWS (1992, 2008a) 

uses a 1.3-mile radius circle containing 3,398 acres to estimate the size and amount of home ranges. 

The portion of the home range that receives disproportionately high use (the core area) during the 

breeding season is smaller than that used during the remainder of the year (Forsman et al. 1984; Sisco 

1990; Glenn et al. 2004; Bingham and Noon 1997; Irwin et al. 2000), so the USFWS also examines 

habitat within the core area, which is defined by a circle with a 0.5-mile radius (502 acres) from the 

activity center. 

The USFWS has concluded that NSO survivorship and productivity are reduced when the amount 

of nesting/roosting or foraging habitat within a 0.5-mile core area falls below 80 percent of the area, 

and the amount of suitable habitat within a home range falls below 40 percent of the area (SimonJackson 1989; Thomas et al. 1990; USFWS 1990; D. Johnson, pers. comm. 2008). In the California 

Klamath Province, this equates to approximately 400 to 1,335 acres of suitable habitat, respectively 

(USDA, USDI 1990; Thomas et al. 1990; see also Franklin et al. 2000). In 2001 an interagency team 

of USFWS and Forest Service personnel produced a habitat-based model to predict the probability of 

NSO occupancy (USFS, USDI 2001), and their modeling results suggest that the probability of 

 

3. The area includes six mapped Klamath National Forest activity centers, but two adjacent activity centers have never been 

occupied simultaneously, so Franklin’s demographic study group considers the area to be occupied by only one pair that 

may alternate activity centers. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.4 – Wildlife and Habitat 3-69

occupancy is highest when the ratio of nesting/roosting habitat to foraging habitat within a NSO core 

area is 2:1. Thus, the USFWS currently considers the minimum amount of NSO habitat to avoid 

“take” under the ESA to consist of at least 250 acres of nesting/roosting and 150 acres of foraging 

habitat within a 0.5-mile core area and at least 935 additional acres of foraging habitat within a 

1.3-mile home range outside the core area (D. Johnson, pers. comm., Jan. 2009). 

Approximately 28 home ranges of historic and recent activity centers overlap the Eddy Gulch 

LSR, with fewer than that found within the Assessment Area (Maps A-5a and A-5b in Appendix A). 

None of the activity centers in the Assessment Area meet or exceed 400 acres of nesting/roosting/ 

foraging habitat within the 0.5-mile core area. However, almost all of the activity centers meet or 

exceed the 1,335 acres of nesting/roosting and foraging habitat within the 1.3-mile home range. Of 

the five activity centers that have less than the target 1,335 acres in the home range, only one 

(KL1047) has an apparent habitat deficit (approximately 16 percent) greater than 10 percent in the 

1.3-mile home range. 

Managed Owl Conservation Area (MOCA). The Eddy Gulch LSR occurs within MOCA-35. 

The MOCAs are areas that contain or will develop habitat intended to support stable and welldistributed populations of NSOs over time and allow for movement of NSOs across a larger network 

of MOCAs and other suitable habitats (USFWS 2008a). The Eddy Gulch LSR is included within a 

Type 1 MOCA, which is expected to support 20 or more pairs of breeding NSOs now or in the future. 

MOCAs in the Klamath Provinces of Oregon and California, including MOCA-35 in the Eddy Gulch 

LSR, are considered parts of an interim network until a landscape-management strategy is developed 

and adopted in these fire-prone provinces (USFWS 2008a). 

Critical Habitat and Critical Habitat Units. The Eddy Gulch LSR occurs within the Scott and 

Salmon Mountains NSO CHU 25. The Scott and Salmon Mountains CHU subunit 35 includes all of 

the Eddy Gulch LSR, with the exception of 1,960 acres of private lands. NSO Critical Habitat and 

CHUs were originally designated by the USFWS in 1992 (USFWS 1992) but revised on August 13, 

2008 (USFWS 2008c). They are based on a network of MOCAs. 

The Assessment Area occurs within subunit 35 of the Scott and Salmon Mountains NSO CHU 25 

(USFWS 2008c). The boundaries of subunit 35 closely align with the USFWS 1992 designation of 

NSO CHU CA25. Therefore, any analysis conducted herein for subunit 35 would also be applicable 

to CA25 as designated by the USFWS in 1992. 

The goal of established CHUs is to maintain habitat that provides the Primary Constituent 

Elements (PCEs) that create self-sustaining and interconnected populations of the NSO over time. 

PCEs are the biological and physical features of critical habitat that are essential to the NSO 

conservation and recovery. The four PCEs identified in the Recovery Plan (USFWS 2008a) are 

nesting, roosting, foraging, and dispersal habitat. 

Subunit 35 of the Scott and Salmon Mountains CHU, combined with the contiguous habitat in the 

Marble Mountains Wilderness, is expected to support 22 nesting pairs over time (D. Johnson, pers. 

comm. 2008). Historical surveys indicate that the Eddy Gulch LSR has supported between 19 and 

25 NSO activity centers (USFS 1999), which is within or exceeds the Scott and Salmon Mountains 

CHU subunit 35 objective of 22 pairs. Subunit 35 also helps to connect the Western KlamathSiskiyou Mountains CHU across the high-elevation habitat in the Salmon-Trinity Alps Wilderness 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-70 Chapter 3: Affected Environment and Environmental Consequences

and east to the Shasta-McCloud area of concern. Existing dispersal habitat within and surrounding the 

Scott and Salmon Mountains CHU subunit 35 exceeds 50 percent (with the possible exception of the 

Lower South Fork Salmon River, which was estimated to be 48 percent in 1992) (USFS 1999, ch. 2, 

pg. 49). Thus, subunit 35 appears to be providing intra-provincial connectivity with adjacent 

Wilderness Areas and other CHUs. 

3.4.3.3 Forest Service Sensitive Species 

The Wildlife and Habitat Report provides discussions of all Forest Service Sensitive Species that 

are listed in Table 3-31 above, and those species are analyzed in the Environmental Consequences 

section below. 

Northern Goshawk. Northern goshawks are found in mid- to late-successional conifer forests; 

nest stands are usually characterized by a canopy cover that exceeds 50 percent, level terrain or 

“benches” of gentle slope, northerly aspects, proximity to water (usually less than one-third mile 

away), patches of larger trees, and proximity to meadows or forest openings. Telemetry studies 

suggest that foraging individuals avoid dense young forest stands and brush but use a wide variety of 

stand conditions, showing some preference for relatively mature stands with moderate canopy closure 

(Austin 1993; Hargis et al. 1994; Beier and Drennan 1997; Drennan and Beier 2003). 

There are approximately 28,897 acres of suitable nesting habitat in the Assessment Area and five 

Goshawk Management Areas (GOMAs) with 1.0-mile home ranges that overlap the Assessment Area 

(Table 3-34). Two new goshawk territories were found in 2008 during the first large-area, protocollevel goshawk surveys in the Assessment Area (Herrera 2008). Klamath LRMP Standards and 

Guidelines specify that these GOMAs and active territories maintain 300 acres of dense mature forest 

within a 0.5-mile Primary Nest Zone and 900 acres in a mosaic of mid- to late-successional forest 

conditions in a 1.0-mile Foraging Habitat Zone. 

Table 3-34. Northern goshawks in the Eddy Gulch LSR Project Assessment Area. 

Territory 

GOMA 

Established 

Latest 

Survey/Statusa Prior Occurrence/ 

Reproduction 

Home Range 

Overlaps 

Assessment Area 

Home Range 

Overlaps an FRZ 

Eddy Gulch Yes-SAR1 2008/U 1991/1991 Yes No 

Matthews Yes-SAR8 2008/U 1987/1987 Yes No 

Sixmile Yes-SAR11 2008/U 1987/R Yes Yes 

West Fork Whites Yes-SAR14 1989/R None Yes Yes 

Blue Ridge Ranch No 1994/R 1993/1993 No No 

Callahan Creek No 1994/R None No No 

Russian River Yes-SAR 13 2008/U Unknown Yes No 

Lower Shadow Creek No 2008/R 2007/R Yes Yes 

Lower Butcher Creek No 2008/U None Yes No 

Notes: 

a. R = reproducing (including number of fledged if known). 

 U = unknown. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.4 – Wildlife and Habitat 3-71

Pacific Fisher. The Pacific fisher is a Federal Candidate for listing under the ESA. The Pacific 

fisher was petitioned for listing in November 2000. After a 12-month review, the USFWS found 

Pacific fisher to be a distinct population segment and gave a “warranted but precluded” decision to 

the petition. As a result of that decision, the West Coast distinct population has become a Federal 

Candidate species under the ESA (USDI 2004) and will be annually reviewed for its status and may 

be listed at a later date. 

The Pacific fisher typically occurs in mid- to late-successional coniferous forest and deciduous 

riparian habitats. They prefer large blocks of dense multistoried (greater than 60 percent canopy 

closure), multispecies, mid- to late-successional coniferous forests with a high number of large (over 

30 inches diameter at breast height [dbh]) snags and downed logs and a hardwood component 

(Ruggiero et al. 1994; Krohn et al. 1997; Zielinski et al. 2004a). This complex forest structure 

supports prey, provides individuals access to prey during winter, and provides typical fisher resting 

and denning sites. Habitat usually also contains small openings with understory vegetation and woody 

debris that support an abundance of diverse prey (such as voles, hares, porcupines, squirrels, mice, 

chipmunks, carrion, and fruit). Their preferred habitats are often connected by riparian corridors, 

saddles, or other linkages that serve as movement corridors. Fishers will den in brush piles, logs, 

snags, rocky areas, upturned trees, or in other protected cavities; hollow logs and snags are 

particularly important for denning. Young are typically born in February through May and remain 

with the female until late autumn. 

The most influential variables affecting rest site selection in California fisher populations include 

maximum tree sizes and dense canopy closure, but other features are important to rest site choice as 

well, such as large-diameter hardwoods, large conifer snags, and steep slopes near water (Zielinski 

et al. 2004a). Across home ranges in a northern California study area, fishers selected sites made up 

of stands with large-diameter trees and dense canopy cover that were generally situated within 

drainage-bottoms (Yaeger 2005). Fishers select areas as rest sites where structural features are most 

variable but where canopy cover is least variable, suggesting that resting fishers place a premium on 

continuous overhead cover but prefer resting locations that also have a diversity of sizes and types of 

structural elements (Zielinski et al. 2004a, 2004b). Rest-site structures used by fishers include cavities 

in live trees, snags, hollow logs, fallen trees, canopies of live trees, mistletoe clumps, or large or 

deformed branches and to a lesser extent stick nests, rocks, ground cavities, and slash and brush piles 

(Heinemeyer and Jones 1994; Higley et al. 1998; Mazzoni 2002; Zielinski et al. 2004a, 2004b). 

The Pacific fisher is an uncommon permanent resident in the Klamath National Forest. Although 

no den sites have been located in the Assessment Area, suitable denning, resting, and foraging habitat 

for fisher is widespread in the Assessment Area, especially below 5,000 feet. Fishers have been 

detected on numerous occasions at data stations in the Eddy Gulch LSR (Yaeger 2008; Zielinski et al. 

2000). Additionally, camera stations have detected individuals near Etna Summit, on the south side of 

Etna Mill Creek, and in the Russian River Wilderness Area. The Eddy Gulch LSR is expected to 

support over 34,000 acres of suitable habitat (USFS 1999). 

3.4.4 Desired Conditions 

The Klamath LRMP specifies that LSRs are to be managed to maximize the amount of latesuccessional forest to a level reasonably sustainable because surrounding areas of Matrix and private 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-72 Chapter 3: Affected Environment and Environmental Consequences

lands are expected to contain relatively little late-successional forest habitat. However, dramatic 

differences in late-successional forest structure and process exist between forest community types in 

the LSR, and no single desired condition is appropriate for the entire landscape. It is desirable to have 

amounts of late-successional habitats that are between 45 and 65 percent identified functioning range 

to ensure continued functionality following inevitable natural disturbances. 

Processes that historically have lead to the development of late-successional ecosystems include 

tree growth and maturation; death and decay of large trees; low- to moderate-intensity disturbances 

(such as fire, wind, insects, and disease) that create canopy openings and gaps in various strata of 

vegetation; establishment of trees beneath the maturing overstory trees, either in gaps or under the 

canopy; and closing of canopy gaps by lateral growth or growth of understory trees. These processes 

result in forests moving through different stages of late-successional conditions that may span several 

hundred years. 

It is desirable to have variability in late-successional vegetative characteristics. It is neither 

desirable nor possible to have entire landscapes containing the same vegetative characteristics, 

stocking levels, tree sizes, and understory component. Within each vegetation community, desired 

conditions will vary according to site capability, which is influenced by elevation, slope, aspect, and 

soil conditions. Multistoried conditions will be scattered throughout the landscape, but they will be 

more prevalent on the lower half of the more mesic north and east aspects and in riparian areas. 

South- and west-facing slopes will have very few multilayered conditions, except in the Douglas-firtanoak series. Canopy closure will vary across the landscape, ranging from approximately less than 

40 percent on primary ridgetops and south and west slopes to greater than 50 percent on north and 

east slopes and riparian areas. The upper portions of all aspects, except in the true fir type, will 

generally have lower densities compared to lower portions of the slopes. Snag and down log 

accumulations will be higher on the lower portions of slopes and decrease as one moves up slope. 

It is desirable to provide habitat that contributes to the recovery of the NSO, especially the 

productivity of the existing pairs within the Eddy Gulch LSR. Variability in habitat attributes will be 

consistent with that described for late-successional habitats. Reintroduction of fire into LSRs may 

reduce the occurrence of habitat components locally. This is a recognized trade-off in order to create 

less hazardous fuels conditions that would otherwise put large areas of habitat at risk. 

3.4.5 Environmental Consequences 

3.4.5.1 Alternative A: No Action 

Federally Listed Species 

Direct and Indirect Effects on NSO Habitat in Areas Not Affected by Wildfire. Under the 

no-action alternative, and in the absence of wildfire, there would be no direct effects on NSOs or their 

habitat. 

The amount or quality of NSO habitat in the Assessment Area would change slowly in areas not 

affected by fire. Continued forest growth could have beneficial or adverse indirect effects, depending 

on local conditions. In relatively young or open stands, continued forest growth could benefit NSOs 

by allowing for a slow increase in tree size, basal area, canopy cover, snags, and CWD. This could 

lead to an increase in the number of activity centers and the amount of nesting/roosting or foraging 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.4 – Wildlife and Habitat 3-73

habitat in existing activity centers. Continued forest growth could also decrease fire risk as young or 

open stands develop a moister microclimate. In most stands, continued growth would increase stand 

density, density-related tree mortality, fuel hazards, and the probability of a stand-replacing fire. 

Continued growth could make some stands too dense for owls (Irwin et al. 2007) and reduce overall 

stand diversity. In summary, young or open stands not occupied by NSOs would most likely benefit 

from continued forest growth, but understory stand densities in many other areas, including stands 

occupied by NSOs, would most likely exceed the optimal stand density for nesting/roosting or 

foraging habitat because high understory density would limit owl movement. The risk of standreplacing fires will also increase as ladder fuels increase. 

Direct and Indirect Effects on NSO Habitat in Areas Affected by Wildfire. The modeled 

wildfire (refer to Section 2.4 in Chapter 2) would have various direct effects on Critical Habitat, 

NSOs, NSO habitat, and NSO prey, depending on the location, season, intensity, and pattern of the 

wildfire. Smoke may not affect most NSOs (Bevis et al. 1997); however, heavy and continuous 

smoke may affect NSOs during the nesting season when young birds cannot escape the fire (USDA 

2007). Fire may also increase the risk of predation on NSOs as they move to unfamiliar territory, into 

more open habitats, or during the day. 

There are approximately 28,797 acres of suitable NSO habitat within the portion of the Scott and 

Salmon Mountains CHU subunit 35 contained in Eddy Gulch LSR. Over time, if left untreated all of 

these acres have the potential to be affected by wildfire. 

The 7,200-acre modeled wild fire would include 1,368 acres of low- to moderate-intensity fire 

that could benefit NSOs immediately after the fire by removing cover and/or concentrating prey into 

remaining patches of habitat (Lyon et. al. 2000). Jenness et al. (2004) concluded that relatively lowintensity ground fires probably have little or no short-term effect on the presence or reproductive 

success of Mexican spotted owls (S. occidentalis lucida). Similarly, Bond et al. (2002) hypothesized 

that NSOs have the ability to withstand the immediate, short-term (1-year) effect of fire occurring at 

primarily low to moderate severity within their territory. Short-term benefits would result in a mosaic 

of small openings that would invigorate forest understory and create new snags and down woody 

debris used by NSO prey, resulting in additional prey. Low- to moderate-intensity fires would also 

reduce the likelihood of future stand-replacing fires. 

The modeled fire resulted in 81 percent crown fire (5,832 acres) where a moderate- to highintensity fire could consume NSO nesting/roosting or foraging habitat, and extensive consumption of 

snags, CWD, understory, and litter and duff layers would reduce prey abundance. The modeled fire 

would have various indirect effects. Crown fires would result in substantial mortality, initiating 

successional changes that would replace mid- and late-successional forest stands with brush fields and 

dense young forests and increase the probability of future high-intensity wildfire. Fire may also affect 

enough nesting/roosting or foraging habitats that it could lead to changes in NSO occupancy of the 

area (Clark 2007). Excessive habitat loss in a core area and/or home range would most likely cause 

abandonment of one or more activity centers during or shortly following fire. 

The USFWS considers habitat (in interior California) necessary to support NSOs to consist of 

400 acres of suitable habitat made up of at least 250 acres of nesting/roosting and 150 acres of 

foraging habitat in the 0.5-mile core area. All but one core area within the Eddy Gulch Assessment 

Area are currently below 250 acres of nesting/roosting habitat. A crown fire would result in 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-74 Chapter 3: Affected Environment and Environmental Consequences

75 percent mortality to trees greater than 20 inches dbh, removing most suitable nesting/roosting 

habitat, resulting in an adverse impact on NSO habitat in the Assessment Area. When the simulated 

fire behavior was compared to available nesting/roosting habitat, crown fires could adversely affect 

any of the 20 core areas. Table 3-35 below depicts the existing number of nesting/roosting acres with 

the potential number of acres and the percentage of nesting/roosting habitat that would be removed by 

the modeled fire in each of the 20 core areas, as any one of the core areas is susceptible to crown fire. 

Additionally, all four of the USFWS priority protection areas would lose a substantial amount of 

habitat in a wildfire. 

Table 3-35. NSO core areas, in or overlapping the Assessment Area, that are susceptible 

to the simulated wildfire under the no-action alternative. 

Activity 

Center 

Acres of Nesting / 

Roosting Habitat in 

Core Areas 

Acres of Nesting / Roosting 

Habitat in Core Areas 

Removed by Crown Fire 

Percentage of Nesting / 

Roosting Habitat in Core 

Areas Adversely Affected 

by Crown Fire 

KL0257 102 60 59 

KL0365 141 51 36 

KL1012a 174 140 80 

KL1013 150 73 49 

KL1014a 203 66 33 

KL1028a, b 266 249 94 

KL1030 244 150 61 

KL1031a 140 129 92 

KL1032a, b 161 154 96 

KL1033a 254 165 65 

KL1034a 209 138 66 

KL1035a 169 116 69 

KL1039 184 122 66 

KL1040 166 104 63 

KL1041 142 88 62 

KL1046a 165 71 43 

KL1047 100 89 89 

KL1090 93 20 22 

KL1258 132 23 17 

KL4026a 171 145 85 

Notes: 

a. Denotes activity centers within which core areas will be treated with prescribed burning under Alternative A, and 

therefore are not expected to be susceptible to crown fires and thus habitat loss. 

b. Denotes activity centers within which portions of the core areas would not be treated with prescribed burning under 

Alternative C, and therefore are expected to remain susceptible to crown fires and thus some habitat loss 

Direct and Indirect Effects on Critical Habitat With and Without Wildfire. Under the no-action 

alternative, and in the absence of wildfire, there would be no direct effects on Critical Habitat. The 

amount or quality of Critical Habitat in the Assessment Area would change slowly in areas not 

affected by fire. Continued forest growth could have beneficial or adverse indirect effects, depending 

on local conditions. In relatively young or open stands, continued forest growth could benefit Critical 

Habitat by allowing for a slow increase in tree size, basal area, canopy cover, snags, and CWD. This 

could lead to an increase in the amount of nesting/roosting or foraging habitat available within the 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.4 – Wildlife and Habitat 3-75

Assessment Area. Continued forest growth could also decrease fire risk as young or open stands 

develop a moister microclimate. In other stands (most stands), continued growth would increase stand 

density, density-related tree mortality, fuel hazards, and the probability of a stand-replacing fire. 

Continued growth could make some stands too dense for owls (Irwin et al. 2007) and reduce overall 

stand diversity. In summary, young or open stands not currently containing suitable habitat would 

most likely benefit from continued forest growth, but understory stand densities in many other areas, 

including stands containing suitable habitat, would most likely exceed the optimal stand density for 

nesting/roosting or foraging habitat as increased understory stand density would limit owl movement, 

and as ladder fuels increase so will the risk of stand-replacing fires.

There are approximately 28,797 acres of suitable NSO habitat in the portion of the Scott and 

Salmon Mountains CHU subunit 35 contained in Eddy Gulch LSR. Over time, if left untreated, all of 

these acres have the potential to be affected by wildfire. Approximately 81 percent of the 7,200-acre 

wildfire would adversely affect PCEs in 20 percent of the suitable NSO habitat in CHU subunit 35 in 

Eddy Gulch LSR. Thus, the no-action alternative would have long-term adverse effects on Critical 

Habitat and the four PCEs by taking no action and failing to reduce the risk of stand-replacing fire in 

the landscape in a minimum of 5,832 acres within the Eddy Gulch LSR. 

Moderate- to high-intensity fire could consume Critical Habitat. The modeled fire would have 

various indirect effects. Crown fires would initiate successional changes that would replace mid- and 

late-successional forest stands with brush fields and dense young forests and increase the probability 

of future high-intensity wildfire. Fire may also affect enough of existing Critical Habitat that it could 

lead to changes in NSO occupancy of the area. Excessive Critical Habitat loss would most likely 

cause abandonment of one or more activity centers during or shortly following fire. 

Cumulative Effects on NSO and Critical Habitat. Changes to NSO habitat would be as 

described under direct and indirect effects. In the absence of fire, continued forest growth may 

increase NSO habitat in some areas, but fire hazard would increase in most areas. Proposed future 

activities on the Salmon River and Scott River Ranger Districts include the following: installation of 

telephone and fiber-optic lines along existing roads through the Ranger District; North Fork Roads 

Stormproofing Project (stormproofing 76 miles of road requiring blading, improving road drainage, 

and protecting riparian and stream systems; decommissioning 36 miles of roads to reduce sediment 

delivery to streams and adding 2.4 miles of existing road); and the construction of a fuelbreak system 

west of Black Bear Ranch (approximately 700 acres of ridgetop fuel reduction). These proposed 

future activities would have little effect on future wildfire behavior in the Assessment Area; therefore, 

the no-action alternative increases the potential for fire to remove the existing physical and biological 

features important to functioning Critical Habitat as well as dispersal habitat. Local community fuel 

reduction projects on private lands are small and would have little effect in reducing the risk or extent 

of fire in the Assessment Area. 

Forest Service Sensitive Species 

Tehama Chaparral and Klamath Shoulderband—

Direct and Indirect Effects. No measurable direct effects on the Tehama chaparral or the 

Klamath shoulderband are expected in areas that are affected by wildfires because the species lives in 

moist talus, especially during the dry season when fires are most likely. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-76 Chapter 3: Affected Environment and Environmental Consequences

Negligible to moderate indirect effects could be expected to occur, depending on the location and 

severity of wildfire. Their habitat is generally resistant to fire, but extensive loss of forest surrounding 

talus slopes and rocky area could lead to conditions that are to dry and inhospitable for these species. 

Under the no-action alternative, there would be no direct or indirect effects on the Tehama chaparral 

or Klamath shoulderband in areas that are not affected by wildfire. 

Cumulative Effects. Under the no-action alternative, no incremental effects are expected as a 

result of present or future projects because no actions are proposed under this alternative. However, 

loss of riparian or overstory vegetation could reduce habitat suitability for the Tehama chaparral or 

the Klamath shoulderband in immediately affected areas, and this risk is higher in areas with 

accumulated fuels. 

Southern Torrent Salamander— 

Direct and Indirect Effects. In the absence of wildfire there would be no direct effects on 

salamanders. Over the long term, however, indirect effects could result as succession continues and 

the amount of late-successional habitat increases, providing benefits to the southern torrent 

salamander preferred habitat. Large diameter shade trees, CWD, and a deep litter layer would all 

continue to slowly increase as a result of the Alternative A. 

Wildfire is not likely to directly affect individuals because southern torrent salamanders are rarely 

found away from aquatic habitat. However, fire could consume forest canopy that is an important 

component of the salamander’s habitat. The loss of forest canopy would result in indirect effects that 

would vary with fire intensity. Areas that burn with high intensity are likely to contribute sediment to 

streams. This sediment could fill interstitial spaces in coarse substrate that are used for cover by this 

species. Loss of vegetation that results in reduced shading may adversely affect the salamander, and 

perhaps small populations, because adults prefer cold, clear streams and are known to have a narrow 

range of preferred water temperatures (Welsh and Lind 1996). The loss of CWD and litter layer 

would reduce available cover for any individuals that may move out of aquatic habitat. 

Cumulative Effects. There are no other proposed or anticipated actions that would combine 

with Alternative A to cause cumulative effects to the southern torrent salamander or its habitat beyond 

the project’s direct and indirect effects discussed above. Local community fuel reduction projects 

would decrease the risk of fire in the Assessment Area, but those areas represent a small fraction of 

the area surrounding the Assessment Area and would not affect fire behavior originating in the 

Assessment Area. 

Cascades Frog, Foothill Yellow-legged Frog, and Western Pond Turtle—

Direct and Indirect Effects. The effects on the Cascades frog, foothill yellow-legged frog, 

and Western pond turtle are discussed together because they primarily occupy aquatic habitats and 

similar effects are expected. In the absence of wildfire, and with no fuel reduction activities under the 

no-action alternative, there would be no direct or indirect effects on either species or their habitat. 

Wildfire is not likely to directly affect individuals because these species are rarely found away 

from aquatic habitat during the fire season. Fire would not directly affect aquatic habitats used by 

these species, but it could remove shoreline vegetation (sometimes used by frogs) or harm turtles near 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.4 – Wildlife and Habitat 3-77

upland nest sites depending on the timing of the fire. The indirect effects of fire would vary with fire 

intensity. Areas that burn with high intensity are likely to contribute sediment to aquatic habitats that 

could suffocate egg masses and/or tadpoles or reduce the macro-invertebrate prey base. This is 

generally more likely in low-gradient reaches where sediment may accumulate. Sedimentation could 

also reduce pond longevity. Loss of vegetation that results in reduced stream shading may benefit 

these species because adults require basking sites for thermoregulation, and increased stream 

temperatures would likely benefit larval or juvenile development, especially for the species near their 

upper elevational limits. For turtles, the loss of habitat components (such as large CWD) could 

remove basking sites, but recruitment of CWD and reduced vegetation would potentially create more 

basking sites and upland nest sites, especially in areas that are now densely shaded. 

Cumulative Effects. There are no other proposed or anticipated actions in upland areas that 

would combine with Alternative A to cause cumulative effects on these species or their habitat beyond 

the project’s direct and indirect effects discussed above. Local community fuel reduction projects 

would decrease the risk of fire in the Assessment Area, but those areas represent a small fraction of 

the area surrounding the Assessment Area and would not affect fire behavior originating in the 

Assessment Area. 

Bald Eagle—

Direct and Indirect Effects. Direct effects would result if wildfire were to kill young eagles 

unable to escape the nest or roost area. Fire could also consume large nest trees or nesting habitat. 

Areas that burn with high intensity could lead to increased sedimentation and, in turn, affect prey 

(fish) adversely; however, this indirect effect would be short-term and negligible. In the absence of 

wildfire, and with no fuel reduction activities under the no-action alternative, there would be no direct 

or indirect effects on the bald eagle or bald eagle habitat. 

Cumulative Effects. The no-action alternative would not provide for the long-term 

protection of nesting habitat from stand-replacing fire. Large-scale changes in stream conditions that 

could reduce prey availability are possible but unlikely. No other effects are expected as a result of 

ongoing or future projects. 

Northern Goshawk— 

Direct and Indirect Effects. In the absence of wildfire, and with no fuel reduction activities 

under the no-action alternative, there would be no actions that would directly affect northern 

goshawks or their habitat. The amount or quality of northern goshawk habitat in the Assessment Area 

would change slowly in areas not affected by wildfire. The continued forest growth could result in 

either beneficial or adverse indirect effects, depending on local conditions. In relatively young or 

open stands, continued forest growth would benefit nesting habitat for northern goshawks by allowing 

for a slow increase in tree size, basal area, and canopy cover. It could also decrease fire risk as 

maturing stands develop a moister microclimate. In most other stands, continued growth would 

increase stand density, density-related tree mortality, fuel hazards, and the probability of a standreplacing fire. Continued growth could also make some stands too dense for northern goshawks and 

reduce overall stand diversity. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-78 Chapter 3: Affected Environment and Environmental Consequences

The modeled fire would have various effects on northern goshawks, northern goshawk habitat, 

and prey depending on the location, season, intensity, and pattern of the fire. Fire or smoke may injure 

or kill northern goshawks, most likely during the nesting season when young birds may be unable to 

escape the nest or roost area. Direct effects would result if moderate- to high-intensity wildfire could 

reduce suitability of northern goshawk nesting, roosting, or foraging habitat, and extensive loss of 

snags, CWD understory, and litter and duff layers reduces prey abundance. Based on the modeled 

wildfire of 7,200 acres, up to 5,832 acres (81 percent) of the forested habitat could be removed or 

adversely affected. Depending on the exact location of the fire, this habitat loss would most likely 

cause adverse effects on or abandonment of one or more activity centers. 

The modeled fire would cause various indirect effects. Excessive habitat loss in a core area and/or 

home range would most likely cause abandonment of one or more activity centers during or shortly 

following fire (although changes in goshawk occupancy may be delayed if some habitat remains 

following fire or if tree mortality is delayed; delayed mortality is common in low- to moderateseverity fire). Moderate- to high-intensity fire would initiate successional changes that could increase 

the probability of future stand-replacing fire as forest is replaced with brush fields and dense young 

forest. Low- to moderate-intensity fire could benefit northern goshawks by reducing the likelihood of 

future stand-replacing fire and by creating a mosaic of openings that would invigorate forest 

understory and create prey habitat. 

Cumulative Effects. There are no proposed or anticipated actions that would combine with 

Alternative A to cause cumulative effects to the northern goshawk or its habitat beyond the project’s 

direct and indirect effects discussed above. Continued forest growth may increase northern goshawk 

habitat in some areas, but fire hazard would increase in proportionally larger areas. Local community 

fuel reduction projects would decrease the risk of fire in the Assessment Area, but those areas 

represent a small fraction of the area surrounding the Assessment Area and would not affect fire 

behavior originating in the Assessment Area. 

Peregrine Falcon— 

Direct and Indirect Effects. Wildfire would likely not result in direct effects on peregrine 

falcons because nest sites are in rocky cliffs, and heavy smoke is not likely to persist around an eyrie. 

Areas that burn with high intensity may create patches of reduced vegetation, which can reduce prey 

availability; however, this is expected to be a negligible indirect effect. In the absence of wildfire, and 

with no fuel reduction activities under the no-action alternative, there would be no direct or indirect 

effects on the peregrine falcon. 

 Cumulative Effects. There are no other proposed or anticipated actions that would combine 

with Alternative A to cause cumulative effects to the peregrine falcon or its habitat beyond the 

project’s direct and indirect effects discussed above. Local community fuel reduction projects would 

decrease the risk of fire in the Assessment Area, but those areas represent a small fraction of the area 

surrounding the Assessment Area and would not affect fire behavior originating in the Assessment 

Area. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.4 – Wildlife and Habitat 3-79

Willow Flycatcher— 

Direct and Indirect Effects. In the absence of wildfire, and with no fuel reduction activities 

under the no-action alternative, individual flycatchers in the Assessment Area and Riparian Reserve 

would not be disturbed, so there would be no direct or indirect effects on individual flycatchers. No 

suitable habitat is currently known to occur in the Assessment Area, so there would be no direct or 

indirect effects on habitat. 

In areas affected by wildfire, those areas that burn with high intensity are more likely to benefit 

willow flycatchers by removing most or all of the forest canopy, allowing for extensive growth of a 

riparian shrub layer and nesting habitat for approximately 10–12 years. Vigorous brush fields created 

by stand-replacing fires could potentially provide suitable breeding habitat, just as clearcuts have 

sometimes led to the creation of suitable breeding habitat elsewhere in northwestern California 

(Harris 2006) and Oregon (Altman et al. 2003). Those areas that burn with low intensity would not 

benefit flycatchers because the overstory layer would remain intact. 

Cumulative Effects—There are no other proposed or anticipated actions that would combine 

with Alternative A to cause cumulative effects to the willow flycatcher or its habitat beyond the 

project’s direct and indirect effects discussed above. Local community fuel reduction projects would 

decrease the risk of fire in the Assessment Area, but those areas represent a small fraction of the area 

surrounding the Assessment Area and would not affect fire behavior originating in the Assessment 

Area. 

Pallid Bat and Townsend’s Big-eared Bat— 

Direct and Indirect Effects. These two bats are analyzed together, but pallid bats are more 

likely to be directly affected because of their more general use of the forest for roosting. In the 

absence of wildfire, and with no fuel reduction activities under the no-action alternative, there would 

be no affect on habitat or disturbance to roosting bats in the Assessment Area and, therefore, there 

would be no direct effects on the pallid bat or Townsend’s big-eared bat. 

The amount or quality of habitat would change slowly in areas not affected by wildfire. The 

continued forest growth could have either beneficial or adverse effects, depending on local 

conditions. In relatively young or open stands, continued forest growth would benefit bats by 

allowing for a slow increase in snags. This could hypothetically lead to an increase in the number of 

maternal colonies, although it seems unlikely that pallid bats in the Project Area are limited by 

suitable roost sites. It could also decrease fire risk as maturing stands develop a moister microclimate. 

In other areas, continued growth would increase stand density, density-related tree mortality, fuel 

loads, and the probability of a stand-replacing fire. Continued growth could also make some stands 

too dense for foraging bats and reduce overall stand diversity. 

In areas affected by the modeled wildfire, direct effects would occur if bats (specifically, juvenile 

bats or maternal colonies) are killed or harmed by fire or smoke, depending on the timing of fire. Fire 

could also consume snags and large hollow trees used as maternal colonies or roost sites, but fire 

would also create snags and cavities. Short-term loss of vegetation would reduce the abundance of 

aerial and terrestrial insect prey. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-80 Chapter 3: Affected Environment and Environmental Consequences

The modeled fire would have various indirect effects. Moderate- to high-intensity fire would 

initiate successional changes that could increase the probability of future stand-replacing fire (and the 

loss of large trees and snags) as forest is replaced with brush fields and dense young forest. Low- to 

moderate-intensity fire could benefit bats by creating snags and cavities and by creating a mosaic of 

openings that would invigorate forest understory and increase the abundance of insect prey. 

Cumulative Effects. There are no proposed or anticipated actions that would combine with 

Alternative A to cause cumulative effects on the bats or their habitat beyond the project’s direct and 

indirect effects discussed above. Local community fuel reduction projects would decrease the risk of 

fire in the Assessment Area, but those areas represent a small fraction of the area surrounding the 

Assessment Area and would not affect fire behavior originating in the Assessment Area. 

American Pine Marten and Pacific Fisher— 

Direct and Indirect Effects. In the absence of wildfire, there would be no actions that would 

directly affect martens, fishers or their habitat. However, over the long term, the amount or quality of 

habitat in the Assessment Area would change slowly in areas not affected by wildfire. The continued 

forest growth could result in either beneficial or adverse indirect effects, depending on local 

conditions. In some young or open stands, continued forest growth would benefit these species by 

allowing for a slow increase in tree size, basal area, canopy cover, snags, and CWD. This could lead 

to an increase in denning and resting habitat or foraging habitat. It could also decrease fire risk as 

maturing stands develop a moister microclimate. In other areas, however, continued growth would 

increase stand density, density-related tree mortality, fuel hazards, and the probability and extent of 

stand-replacing fire. 

The modeled wildfire could have various direct effects on martens or fishers, their habitat, and 

their prey, depending on the wildfire’s location, season, intensity, and pattern. Fire or smoke may 

injure or kill individuals, most likely during the breeding season when young animals may be unable 

to escape. Fire may also increase the risk of predation as individuals move into more open habitats. 

Any type of fire could reduce the amount of resting, denning, and subnivean access habitat, and 

extensive consumption of snags, CWD, understory, and litter and duff layers would reduce prey 

abundance in the short-term. Beneficial direct effects would include the creation of snags that could 

be used as resting or denning sites. Fire could also increase prey availability by removing cover 

and/or concentrating prey into remaining patches of habitat 

Areas that burn with moderate to high intensity would reduce the overall number of available 

acres over the long term. Based on the modeled fire of 7,200 acres, up to 5,832 acres (81 percent) of 

forested habitat could be removed or adversely affected. Depending on the exact location of the fire, 

this habitat loss would likely cause adverse effects on or abandonment of one or potentially two 

territories. 

The modeled wildfire would have various indirect effects. Low- to moderate-intensity fire could 

benefit habitat by reducing the likelihood of future stand-replacing fire and by creating a mosaic of 

openings that would invigorate forest understory and increase recruitment of snags and CWD used as 

denning and resting sites as well as by prey (and as subnivean access). Moderate- to high-intensity 

fire would initiate successional changes that could increase the probability of future stand-replacing 

fire as forest is replaced with brush fields and dense young forest. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.4 – Wildlife and Habitat 3-81

Cumulative Effects. There are no proposed or anticipated actions that would combine with 

Alternative A to cause cumulative effects to the marten, fisher or their habitat beyond the project’s 

direct and indirect effects discussed above. Local community fuel reduction projects would decrease 

the risk of fire in the Assessment Area, but those areas represent a small fraction of the area 

surrounding the Assessment Area and would not affect fire behavior originating inside the Assessment 

Area. 

California Wolverine— 

Direct and Indirect Effects. In the absence of wildfire, it is unlikely that the amount of 

potential habitat available for the wolverine in the Assessment Area would change in the short term. 

Over the long term, however, continued forest growth would increase stand density, density-related 

tree mortality, fuel loads, and the probability of a stand-replacing fire. Currently, there would be no 

direct or indirect effects on the wolverine because none are known to occur in the Assessment Area. 

The modeled fire could have various direct effects on wolverines, wolverine habitat, and 

wolverine prey depending on its location, season, intensity, and pattern. Fire or smoke may injure or 

kill wolverines, most likely during the breeding season when young animals may be unable to escape. 

Moderate- to high-intensity fire could consume wolverine habitat, but the effect from a fire the size of 

the modeled fire may be minor with respect to a wolverine’s large home range. Extensive 

consumption of snags, CWD, understory, and litter and duff layers would reduce prey abundance in 

the short-term, but fire could increase prey availability by removing cover, by concentrating prey into 

remaining patches of habitat, or by killing or injuring animals and thus providing a source of carrion. 

The amount or quality of wolverine habitat in the Assessment Area would change slowly in areas 

not directly affected by wildfire, but the modeled fire would have various indirect effects. Moderateto high-intensity fire would initiate successional changes that could increase the probability of future 

stand-replacing fire as forest is replaced with brush fields and dense young forest. However, this 

could benefit wolverines if the early successional habitats increase the availability of large prey and if 

large prey, such as deer, are limiting to wolverines in the region. Low- to moderate-intensity fire 

would reduce the likelihood of future stand-replacing fire and create a mosaic of openings that would 

invigorate forest understory used by prey species. This would also create a more variable landscape 

that is closer to the historical landscape condition when wolverines regularly occurred in California. 

Cumulative Effects. There are no proposed or anticipated actions that would combine with 

Alternative A to cause cumulative effects to the wolverine or its habitat beyond the project’s direct 

and indirect effects discussed above. Local community fuel reduction projects would decrease the risk 

of fire in the Assessment Area, but those areas represent a small fraction of the area surrounding the 

Assessment Area and would not affect fire behavior originating inside the Assessment Area. 

Forest Service MIS Associations 

River and Stream MIS Association— 

Direct and Indirect Effects. In the absence of wildfire, and with no fuel reduction activities 

under the no-action alternative, there would be no direct effects on river and stream habitats or to 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-82 Chapter 3: Affected Environment and Environmental Consequences

current population trends. Large-diameter shade trees and CWD would increase over the long term, 

resulting in indirect beneficial effects. 

Wildfires may consume vegetation that adjoins aquatic habitats, but fire would not directly affect 

aquatic habitat. Wildfires, especially a high-intensity fire, could remove riparian vegetation, which 

would adversely affect stream temperatures and other habitat components. Areas that burn with high 

intensity are likely to contribute sediment to aquatic habitats that could suffocate egg masses and/or 

tadpoles or reduce the macroinvertebrate prey base. Sedimentation effects would vary with stream 

type, as low-gradient reaches are more likely to accumulate sediment and small debris than highgradient reaches. Fire could increase the recruitment of CWD to streams, but very long-term 

recruitment (well beyond 20 years) of CWD would eventually approach zero in areas burned by 

stand-replacing fire. 

 Cumulative Effects. There are no proposed or anticipated actions that would combine with 

Alternative A to broadly cause cumulative effects to the River and Stream MIS Association beyond 

the project’s direct and indirect effects discussed above. Local community fuel reduction projects 

would decrease the risk of fire in the Assessment Area, but those areas represent a small fraction of 

the area surrounding the Assessment Area and would not affect fire behavior originating inside the 

Assessment Area. Mining effects would continue to create habitat quality problems in local areas, 

including sedimentation and bank cutting. 

Marsh, Lake, and Pond MIS Association— 

Direct and Indirect Effects. In the absence of wildfire, and with no fuel reduction activities 

under the no-action alternative, there would be no direct or indirect effects on individuals, population 

trends, or aquatic habitats, including Riparian Reserves. 

The modeled wildfire would not directly affect aquatic habitats or current population trends, but it 

could remove shoreline vegetative cover. Wildfires, especially the high-intensity fire, could remove 

all or a portion of overstory vegetation, which could affect water temperature. Areas that burn with 

high intensity are likely to contribute sediment to aquatic habitats, which could suffocate egg masses 

and/or tadpoles or reduce the macroinvertebrate prey base. Sedimentation could also reduce pond 

longevity. 

Cumulative Effects. There are no proposed or anticipated actions that would combine with 

Alternative A to cause cumulative effects on the Marsh, Lake, and Pond MIS Association beyond the 

project’s direct and indirect effects discussed above. Local community fuel reduction projects would 

decrease the risk of fire in the Assessment Area, but those areas represent a small fraction of the area 

surrounding the Assessment Area and would not affect fire behavior originating inside the Assessment 

Area. 

Hardwood MIS Association— 

Direct and Indirect Effects. In the absence of wildfire, and with no fuel reduction activities 

under the no-action alternative, there would be no direct effects on hardwood habitats or to population 

trends of the individual species. In areas not affected by fire, tree size and snags are expected to 

slowly increase. However, areas not affected by wildfire would likely become increasingly dominated 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.4 – Wildlife and Habitat 3-83

by a dense conifer overstory, which would decrease hardwood productivity and dominance and thus 

decrease use of the habitat by species that prefer hardwoods but avoid conifer forests. 

Based on the modeled fire, up to 81 percent of the hardwood habitat in a given area could be 

removed or adversely affected. Any kind of fire could consume hardwood snags and CWD, but fire 

would also create snags and cavities that provide nest or roost sites. Fire could benefit hardwoods by 

removing competition from encroaching young conifers. 

The modeled fire would have various indirect effects. Moderate- to high-intensity fire would 

initiate successional changes that could increase the probability of future stand-replacing fire as forest 

is replaced with brush fields and dense young forest. This would prevent the development of mature 

hardwood habitats. Low- to moderate-intensity fire is likely to benefit hardwood habitats by reducing 

the likelihood of future stand-replacing fire, by creating a mosaic of openings, by initiating tree and 

snag decay that would create foraging opportunities and nesting/roosting structure, and by reducing 

competition from conifers. 

Cumulative Effects. There are no proposed or anticipated actions that would combine with 

Alternative A to cause cumulative effects to the Hardwood MIS Association beyond the project’s 

direct and indirect effects discussed above. Local community fuel reduction projects would decrease 

the risk of fire in the Assessment Area, but those areas represent a small fraction of the area 

surrounding the Assessment Area and would not affect fire behavior originating inside the Assessment 

Area. 

Snag MIS Association— 

Direct and Indirect Effects. In the absence of wildfire, and with no fuel reduction activities 

under the no-action alternative, there would be no direct effects on snags or population trends of 

species associated with snag habitat within the Assessment Area, and snags would slowly increase in 

areas not affected by wildfire. This could increase habitat suitability in some stands, but habitat in 

other stands would suffer from reduced tree growth and accumulation of only small snags, which are 

much less valuable to wildlife than large snags. Snags would not be produced by fire, which is an 

important factor in snag recruitment. The risk of high-severity fire would increase in most areas. 

Any kind of fire could consume snags, but fire would also create snags and cavities that provide 

nest or roost sites. Although fire generally creates more snags than it destroys, most of the snags 

created by moderate- to high-intensity fire would not be located in live forests. Based on a modeled 

fire, up to 81 percent of the forested habitat could be removed or adversely affected. 

The modeled wildfire would have various indirect effects. The extent of these effects, whether 

beneficial or adverse, would vary by species and fire intensity, size, and pattern (Saab et al. 2007), but 

is unlikely to affect current population trends. The modeled fire may benefit snag-associated species 

by recruiting snags and by increasing foraging opportunities in the short term as beetles and other 

insects colonize newly killed trees. However, high-intensity wildfire would remove forest overstory 

(required by some snag-dependent species) and could initiate successional changes to brush fields that 

would reduce long-term snag recruitment. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-84 Chapter 3: Affected Environment and Environmental Consequences

Cumulative Effects. The no-action alternative would not provide for the long-term 

protection of Snag MIS Association habitat in forested settings from the effects of high-severity 

wildfire. No other effects are expected as a result of ongoing or future projects. 

3.4.5.2 Alternative B: Proposed Action 

Federally Listed Species 

Direct and Indirect Effects on NSO Habitat from Treatments in M Units (Inside FRZs). 

Thinning in M Units could reduce three features that are used to define suitable NSO nesting/roosting 

or foraging habitat: canopy cover, basal area, and the number of large-diameter trees. Treatments in 

M Units would have little effect on individual NSO or their Critical Habitat because 

 the M Units are along ridges, and the physiographic features associated with most of the 

M units indicate a low probability of use by foraging or nesting/roosting individuals; 

 the M Units avoid all but one NSO core area, part of which occurs along a ridgeline; and 

 all NSO home ranges in which M Units occur will retain habitat sufficient to support NSOs 

following treatment. 

Mechanical thinning of M Units in NSO home ranges would downgrade4

 36.4 acres of 

nesting/roosting habitat to foraging habitat (Table 3-36), and 199.7 acres of foraging habitat within 

home ranges would be modified. In some cases affected habitat polygons are shared by more than one 

NSO activity center (see Table 3-37), and individual M Units are counted more than once, but acreage 

calculations are not. 

Treatments would modify 199.7 acres of foraging habitat in nine 1.3-mile radius home ranges. 

Treatments in M Unit 19 would modify 5.7 acres of foraging habitat within a core area (KL 1032), 

where foraging habitat exceeds the required 150 acres of foraging habitat (Table 3-37). The Proposed 

Action has been designed to maintain basal area and trees per acre that are characteristic of NSO 

foraging habitat, and thus proposed treatments are not expect to create habitat changes that would 

affect occupancy of the activity centers. 

Treatments in M Units would remove small trees and reduce the basal area and canopy cover in 

36.4 acres of nesting/roosting habitat in home ranges of six activity centers (Table 3-37), two of 

which overlap the same M Units. Treatments would downgrade mapped nesting/roosting habitat in 

two NSO home ranges (8 acres in KL1033 and 14.7 acres in KL1034). Treatments in M Units would 

also downgrade additional acres of mapped nesting/roosting habitat (11.2 acres in KL1028, 2.4 acres 

in KL1031, 0.4 acre in KL1035, and 11.2 acres in KL 4026) in four NSO home ranges. All treatments 

occur on ridgetops, a landscape feature not typically used as nesting/roosting habitat (Irwin et al. 

2000; Irwin et al. 2004), thus it probably functions as foraging habitat, which is in excess in all of the 

activity centers (Table 3-37). 

 

4. Definitions for treatments to owl habitat: 

 Downgrade—proposed treatment will change the habitat suitability classification from nesting/roosting to foraging or 

from foraging to dispersal. 

 Modify—treatment proposed within owl home ranges will not change the habitat suitability class, but will alter the 

current canopy cover, basal area, and/ or trees per acres. 

 Remove—proposed treatment will remove habitat, no habitat suitability classification will apply to remaining habitat. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.4 – Wildlife and Habitat 3-85

Table 3-36. Breakdown of NSO habitat within M Units, pre- and post-treatment. 

Pre-Treatment NSO 

Habitat Within M Unit

(acres) 

Habitat Removed or 

Downgraded in M Unit 

(acres) 

Post-Treatment NSO 

Habitat in M Unit 

(acres) 

M Unit 

Total 

Acres 

Within Home 

Range (HR) or 

Core Area (CA)a N/Rb F

b N/R F N/R F 

3 7 HR 0 1.5 0 0 0 1.5 

4 33 HR 0 30 0 0 0 30 

7N 14 No habitat 0 0 0 0 0 0 

7S 19 HR 0 1.3 0 0 0 1.3 

8 5 HR 1.4 0 1.4 0 0 1.4 

9 29 HR 1.1 23.6 1.1 0 0 24.7 

10 32 HR 0 6.14 0 0 0 6.14 

10c 32 1.2 2.6 1.2 0 0 3.8 

11 3 No habitat 0 0 0 0 0 0 

12 22 HR 0.2 2.37 0.2 0 0 2.39 

13 32 9.7 16.5 9.7 0 0 26.2 

15 138 0 6.3 0 0 0 6.3 

16 4 No habitat 0 0 0 0 0 0 

17 12 HR 0 10.36 0 0 0 10.36 

19 46 HR and CA 0 5.7 0 0 0 5.7 

20 13 HR 0 0.18 0 0 0 .18 

21 108 HR 0 15.80 0 0 0 15.8 

21c 108 5.3 58.6 5.3 0 0 63.9 

22 7 HR 0 4.6 0 0 0 4.6 

23 42 HR 2.5 29.1 2.5 0 0 31.6 

24 45 HR 8.7 28.6 8.7 0 0 37.3 

25 27 No habitat 0 0 0 0 0 0 

30 9 0 8.8 0 0 0 8.8 

31 20 HR 0 7.54 0 0 0 7.54 

32 5 HR 0 0.9 0 0 0 0.9 

35 4 No habitat 0 0 0 0 0 0 

36 21 No habitat 0 0 0 0 0 0 

37 12 No habitat 0 0 0 0 0 0 

38 12 No habitat 0 0 0 0 0 0 

39 14 HR 0 0.38 0 0 0 0.38 

40 7 HR 0 3.41 0 0 0 3.41 

43 12 HR 1.1 2.21 1.1 0 0 3.31 

51 12 HR 0.2 2.8 0.2 0 0 3 

52 19 0 10.7 0 0 0 10.7 

54 37 0 1.4 0 0 0 1.4 

60 17 No habitat 0 0 0 0 0 0 

61 25 HR 0 1.5 0 0 0 1.5 

65 6 HR 0 1.57 0 0 0 1.57 

65c 6 0 2.6 0 0 0 2.6 

66 2 HR 0 2 0 0 0 2 

73 26 HR 14.5 7.76 14.5 0 0 22.26 

75 9 HR 2.4 6.44 2.4 0 0 8.84 

76 8 HR 4.3 3.91 4.3 0 0 8.21 

79 13 0 12.3 0 0 0 12.3 

80 3 No habitat 0 0 0 0 0 0 

 52.6 319.47 52.6 0 0 371.89 

Notes: a. All M Units are found within Critical Habitat. c. M Units also found partially within home range. 

 b. N/R = nesting/roosting; F = foraging. 
3-86 Chapter 3: Affected Environment and Environmental Consequences

Table 3-37. Acres of proposed thinning in M Units in occupied NSO habitats. 

Pre-project Habitat Within 

0.5-Mile Core Area 

Acres Habitat 

Downgradeda or 

Removedb in 

0.5-mile Core Area

Post-project 

Acres Habitat in 

0.5-mile Core Area 

Pre-project Habitat Within

1.3-mile Home Range 

Acres Habitat 

Downgraded or 

Removed in 1.3-mile 

Home Range 

Activity 

Center 

NR 

[250]c F [150] Total [400] NR F NR F NR F Total [1,335]d NR F 

KL1012 174 111 285 0 0 174 111 865 909 1,774 0 0 KL1013 150 115 365 0 0 150 115 838 751 1,589 0 0 KL1014 203 152 355 0 0 203 152 797 951 1,748 0 0 KL1028 267 84 351 0 0 267 84 826 592 1,418 11.2 0 KL1029 207 156 363 0 0 207 156 920 760 1,680 0 0 KL1030 244 94 338 0 0 244 94 727 552 1,279 0 0 KL1031 140 199 339 0 0 140 199 775 774 1,549 2.4 0 KL1032 161 192 353 0 0 161 192 521 947 1,468 0 0 KL1033 254 133 387 0 0 254 133 987 1,042 2,029 8 0 KL1034 209 46 255 0 0 209 46 1,003 985 1,988 14.7 0 KL1035 169 230 399 0 0 169 230 793 1,231 2,024 0.4 0 KL1047 100 187 287 0 0 100 187 316 748 1,064 0 0 KL4026 171 159 330 0 0 171 159 747 1,000 1,747 11.2 0 

Notes:a. Defined as changing the current habitat classification from nesting/roosting to foraging. b. Defined as changing the current habitat classification to an unclassified state. c. USFWS minimum acres necessary to support breeding pairs. d. USFWS minimum acres of combined nesting/roosting and foraging habitat necessary in NSO home ranges. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.4 – Wildlife and Habitat 3-87

The Proposed Action is designed to retain trees larger than 20 inches dbh, and the post-treatment 

basal area will meet or exceed standards for foraging habitat. Because the treatment units will 

maintain the targets for basal area and trees per acres (greater than 24 inches), these units are expected 

to function as NSO foraging habitat post-treatment. Reducing the canopy cover is consistent with that 

of the pre-European fire regime (refer to Section 3.2 [Forest Vegetation] above), and it will allow 

more sunlight to reach the forest floor, increasing surface resources in the long term and increasing 

prey that are dependent on those resources. 

All home ranges in which there are M Units exceed the 1,335 acres of suitable habitat and the 

935 acres of suitable foraging habitat outside the core area, so M Unit treatments would not affect 

occupancy. Additionally, creating such mosaics of different vegetation and successional stages may 

offer a stable prey base (Franklin et al. 2000). 

Limited thinning outside of core areas is unlikely to affect NSO habitat use because the thinning 

activities are either along ridgetops away from known usage areas, or thinned acres are found within 

home ranges that have an excess of habitat (beyond USFWS minimum requirements). Some owls 

may shift their activity centers in response to thinning, but changes in home range sizes attributable to 

thinning treatments are unlikely (Irwin et al. 2000). Effects are especially unlikely where thinning 

prescriptions are designed to retain foraging habitat or where thinning occurs along ridges or on the 

periphery of the home range. 

The construction of 1.03 miles of new temporary roads, disturbing 1.7 acres on ridgetops, under 

Alternative B would remove 0.60 acre of foraging habitat and 0.02 acre of habitat classified as 

nesting/roosting. However, based on the ridgetop location of the 0.02 acre of nesting/roosting habitat, 

it is presumed to function as foraging habitat for NSOs. None of the temporary roads occur in NSO 

core areas, and the roads will be closed (ripped and mulched, as needed) following treatment, so there 

would be no long-term effects on NSOs. No new landings are proposed, and existing landings will 

not be expanded under Alternatives B and C, thus no long-term effects on NSOs are expected. 

Direct and Indict Effects of Treatments in Fuel Reduction Areas in FRZs and Along 

Emergency Access Routes. Treatments along emergency access routes would be similar to the FRZ 

or Rx Unit the route passes through. These treatments would have little effect on canopy cover 

because burning would remove smaller trees that do not contribute substantially to canopy cover in 

the overstory. Fuel reduction treatments would cause changes in the amount and/or types of snags, 

CWD, understory vegetation (including small trees), and prey. Treatments could potentially consume 

existing snags but may also create new snags. Typically, large trees and snags are not lost during 

prescribed fire. The burn plan (developed prior to implementing any treatments for the Eddy Gulch 

LSR Project) will design a prescribed fire that consumes smaller-diameter trees. Prescribed fire would 

consume most of the smaller down woody debris and some of the CWD, but much of the CWD 

would likely remain when burning in spring prescriptions. A study by Stephens and Moghaddas 

(2005b) noted that the reduction in volume of existing snags and CWD following prescribed fire 

treatments depends on both tree diameter and decay class (decay classes 1–3 for snags and CWD 

denote sound structural integrity of the heartwood, wherein decay class 4 denotes rotten heartwood 

and decay class 5 denotes no structural integrity). For example, total sound CWD (decay classes 1 

and 2) was not significantly reduced by treatments. The most dramatic change of CWD in this study 

was the reduction of rotten CWD, especially in decay class 4, as a result of prescribed fire treatments. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-88 Chapter 3: Affected Environment and Environmental Consequences

Treatments would remove or consume existing snags and individual hazard trees along 16 miles 

of emergency access routes outside of FRZs or Rx Units, but effects on NSOs would be negligible 

because (1) treated areas would generally avoid NSO nest stands; (2) snag retention would follow 

Klamath LRMP guidelines in NSO nesting/roosting and foraging habitat treated mechanically or by 

hand; and (3) snag loss would be concentrated in ridgetop FRZs where NSOs are not likely to nest or 

roost. NSOs in KL1047, the only core area where roadside hazard fuel reductions are proposed, 

would be protected by resource protection measures designed to avoid disturbance effects on owls, 

suitable habitat would be maintained by following Klamath LRMP guidelines and resource protection 

measures, and hazard trees are expected to be individual trees along only the road prisms and is not 

expected to affect canopy cover. Similarly, treatments would destroy or consume most of the smaller 

woody debris and some of the CWD, but CWD retention would follow Klamath LRMP Guidelines in 

NSO nesting/roosting/ and foraging habitat treated mechanically or by hand, and some CWD would 

also remain when burning in spring prescriptions. Stephens and Moghaddas (2005b) note that most 

understory vegetation would also be removed in fuel reduction areas. Mastication would not remove 

trees greater than 10 inches dbh, and burning would not remove trees greater than 4 inches dbh. 

Removing small trees and brush would have no effect on existing foraging or nesting habitat. 

Overall, snag, woody debris, and understory removal are not likely to directly affect NSOs, but 

fuel reduction activities could affect NSOs by impacting their prey, including woodrats (Wirtz et al. 

1988; Lyon et al. 2000). However, treatments are designed to minimize effects on prey by limiting 

treatments to no more than 50 percent of the suitable habitat within a home range within a given year, 

and treatments in the Assessment Area would be spread over a 5-year period. Prescribed fire is also 

designed to leave a mosaic of burned and unburned areas so some shrubs, snags, and CWD would 

remain to provide cover or food for prey species (Lyon et al. 2000; Lehmkuhl et al. 2006b) and 

minimize effects on NSOs. NSOs may temporarily benefit from fuel reduction activities as rodent 

prey move to avoid disturbance or concentrate in remaining patches of habitat. A reduction in 

understory cover may also facilitate NSO foraging efficiency. After treatment, NSO prey species are 

likely to increase as understory vegetation and litter layers recover and down woody debris is 

recruited from the snag population (Waters et al. 1994; Carey and Wilson 2001; Suzuki and Hayes 

2003; Gomez et al. 2005). Reduced vegetative competition would also accelerate tree growth in some 

areas (refer to Tables 3-6, 3-7, and 3-8 in Section 3.2 above). 

Direct and Indirect Effects of Treatments in Rx Units. Prescribed fire would cause changes in 

the amount and/or types of snags, CWD, understory vegetation, and prey. These treatments would 

have little effect on canopy cover because burning would remove smaller trees that do not contribute 

substantially to canopy cover in the overstory. There is the potential that treatments could consume 

existing snags but may also create new snags. Typically, large trees and snags are not lost during 

prescribed fire. The burn plan (developed prior to implementing any treatments for the Eddy Gulch 

LSR Project) will design a prescribed fire that consumes smaller-diameter trees. Prescribed fire would 

consume most of the smaller down woody debris and some of the CWD, but much of the CWD 

would likely remain when burning in spring prescriptions. A study by Stephens and Moghaddas 

(2005b) noted that the reduction in volume of existing snags and CWD following prescribed fire 

treatments depended on both tree diameter and decay class (decay classes 1–3 for snags and CWD 

denote sound structural integrity of the heartwood, wherein decay class 4 denotes rotten heartwood 

and decay class 5 denotes no structural integrity). For example, total sound CWD (decay classes 1 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.4 – Wildlife and Habitat 3-89

and 2) was not significantly reduced by treatments. The most dramatic change of CWD in this study 

was the reduction of rotten CWD, especially in decay class 4, as a result of prescribed fire treatments. 

Prescribed fire is likely to kill, injure, or displace NSO prey, including woodrats (Wirtz et al. 

1988; Lyon et al. 2000). However, treatments are designed to minimize effects on prey by limiting 

treatments to no more than 50 percent of the suitable habitat within a core area or home range within 

a given year. Burning may also provide a temporary benefit as prey move from burned areas to 

unburned areas, increasing their availability to NSO. Additionally, treatments in the Assessment Area 

would be spread over the 11-year timeframe to complete treatments (refer to Section 2.5.4 in 

Chapter 2 of this final EIS), thus reducing effects over time. Prescribed fire is also designed to leave a 

mosaic of burned and unburned areas (the total sum of all openings in any given burn unit would not 

exceed 10 percent) so some shrubs, snags, and CWD would remain to provide cover or food for prey 

species (Lyon et al. 2000; Lehmkuhl et al. 2006b), minimizing the effects on NSOs. 

CWD and litter layers would begin to accumulate after treatment, and understory vegetation 

would regenerate in most areas. These changes are expected to benefit NSO prey (Waters et al. 1994; 

Carey and Wilson 2001; Suzuki and Hayes 2003; Gomez et al. 2005). Reduced vegetative 

competition would also accelerate tree growth in some areas (refer to Tables 3-6, 3-7, and 3-8 in 

Section 3.2 above). Prescribed low-intensity fire, as described in Chapter 2, is unlikely to affect 

activity center occupancy or reproduction (Bond et al. 2002; Jenness et al. 2004; Clark 2007). 

Prescribed fire treatments would benefit NSOs and NSO habitat by reducing fuels to a level that 

would decrease the likelihood of a crown fire. Fire would still burn with sufficient intensity to create 

small openings in untreated areas. This type of pattern would be consistent with patterns under 

historic fire regimes and is consistent with the recommendations for maintaining habitat for northern 

flying squirrels (Lehmkuhl et al. 2006a; Lehmkuhl et al. 2006b) and woodrats in inland forests, while 

managing for fire and healthy forest ecosystems. Additionally, prescribed fires and under thinning 

would create a patchwork of small openings within the forest that support mature hardwoods and a 

variable understory of hardwoods and shrubs used by woodrats and other prey. Denser forest (at least 

60 percent canopy cover), with numerous large snags and large CWD, would remain widespread and 

continue to provide habitat for flying squirrels. 

Direct and Indirect Effects on NSOs from Barred Owl Competition. It is unclear whether 

forest management has an effect on the outcome of interactions between barred owls and NSO 

(Gutiérrez et al. 2007). However, the proposed thinning and fuel reduction treatments are not likely to 

influence the outcome of such potential interactions because they would have limited effects on the 

factors most likely to be responsible for management-related outcomes: NSO habitat, habitat use, or 

prey species or prey availability. If barred owls were to out-compete NSOs in the LSR, it is very 

unlikely that the proposed fuel reduction activities would have influenced the outcome. 

Direct and Indirect Effects on NSO Habitat and NSOs in Areas Affected by Wildfire. Fire 

behavior modeling in the Eddy Gulch LSR Project Assessment Area showed that a wildfire ignited in 

an Rx Unit would burn 62 acres with a low-intensity fire during a 3.5-day period (refer to Figure 3-8

in Section 3.3 of this final EIS). This would provide sufficient time for suppression forces to 

effectively contain and control that fire, leaving potential NSO habitat with an underburn and creating 

minimal disturbance or effects on existing NSO habitat. Wildfires ignited in FRZs would be 

controlled and contained at smaller sizes. Wildfires allowed to burn under an appropriate management 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-90 Chapter 3: Affected Environment and Environmental Consequences

response could be larger. It is unknown how much of the area affected by a crown fire would be NSO 

habitat. Under either scenario, 10 NSO core areas (5,000 acres) would not be adversely affected in 

treated areas but are more likely to experience more low- to moderate-intensity surface fires (instead 

of crown fires) based on the fire model (refer to Table 3-35). Ten core areas (5,000 acres) may still be 

adversely affected in untreated areas and would continue to be susceptible to loss of habitat if affected 

by a crown fire. 

Additionally, treatments would modify fire behavior and reduce the loss of habitat in all or 

substantial portions of the four USFWS priority protection areas (refer to Section 3.4.3 above). All 

four areas are likely to have similar conditions to those found in the Assessment Area and thus are 

likely to benefit from reductions in the fuel load and the potential for future stand-replacing wildfires. 

Only two of these priority protection areas are entirely within the Assessment Area, and both would 

directly benefit from proposed treatments to protect them against stand-replacing wildfires. The other 

two areas are within nventoried roadless areas and would indirectly benefit by having fuel hazard 

reduction projects in adjacent habitat, thus increasing the ability of suppression crews to limit the size 

of wildfires. 

 Direct and Indirect Effects on NSO Critical Habitat. Approximately 16.2 additional acres 

of nesting/roosting Critical Habitat outside of existing home ranges would be downgraded to foraging 

habitat as a result of treatments in M Units (refer to Table 3-36); the total of 52.6 acres of 

nesting/roosting habitat downgraded in the entire Assessment Area represents less than 0.5 percent of 

existing nesting/roosting habitat in the entire CHU subunit 35. Treatments to all 52.6 acres of 

nesting/roosting habitat are scattered throughout 13 M Units and range in habitat patch size from 

0.2 acre to 14.5 acres. These treatments would result in a decrease in basal area (trees greater than 

10 inches dbh, ranging from 140 to 206 square feet per acre), a decrease in canopy cover (ranging 

from 37 percent in mid-successional white fir habitats to 50 percent in late-successional Douglas fir 

and mixed-conifer habitats), and reducing the trees per acre over 24 inches dbh (ranging from 6 trees 

per acre in mid-successional to 28 trees per acre in late-successional habitat). The decreases in basal 

area, canopy cover, and trees per acre (over 24 inches dbh) are all relatively minor changes from 

existing conditions and are not considered habitat downgrading. Please refer to Table 3-6 in 

Section 3.2 above for further details. 

Approximately 200 additional acres of foraging Critical Habitat would be modified by the 

proposed treatments. The total of 319.5 acres of foraging habitat modified by thinning activities 

represents 3 percent of existing foraging habitat in the Assessment Area, and approximately 2 percent 

of the total foraging habitat in the CHU. However, silvicultural prescriptions are designed to retain 

habitat function in these stands post-treatment. Treatments in 91 acres of foraging habitat in midsuccessional Douglas-fir stands would result in basal area of 140 square feet per acre, canopy cover of 

approximately 48 percent, and six trees per acre over 24 inches dbh. All other treatments would retain 

approximately 200 square feet basal area per acre, greater than 12 trees per acre over 24 inches dbh, 

and trees greater than 20 inches dbh. In addition, because the patches of foraging habitat to be 

modified are along ridgetops and are widely dispersed in less than 1-acre to 59-acre patches across 

the Assessment Area (refer to Table 3-36), fuel reduction activities are not expected to affect the 

ability of the LSR or the Scott and Salmon Mountains CHU subunit 35 to provide NSO foraging 

opportunities or create barriers to intra-provincial connectivity. Thinning in red fir and some other 

stands may target trees heavily infected by dwarf mistletoe, but mistletoe removal is not likely to 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.4 – Wildlife and Habitat 3-91

affect NSO habitat use or prey densities because mistletoe would remain widespread on the 

landscape. 

NSO dispersal is common and widespread throughout the Assessment Area and is not considered 

to be a limiting factor. All habitat that is currently classified as dispersal will remain dispersal habitat 

under the proposed treatments; no treatment will drop canopy cover to below 33 percent (in red fir 

stands) to 54 percent (in Douglas fir stands), and basal area will not drop below 183 square feet per 

acre for trees over 10 inches dbh. 

Treated stands would be more resistant to large-scale fires but would burn with sufficient 

intensity to create small openings (less than 1 acre) in untreated patches. This type of pattern, which 

would create a mosaic of stands in different successional stages, would be consistent with patterns 

under historic fire regimes; such patterns would likely enhance Critical Habitat function by providing 

horizontal diversity of habitat across the landscape (Franklin et al. 2000; Irwin et al. 2007). Treated 

stands that may burn under future conditions are not expected to affect the overall suitability of 

existing habitat. 

Over time prescribed fires are expected to enhance the function of Critical Habitat within 

CHU25. Prescribed fire treatments would benefit Critical Habitat by reducing fuels to a level that 

would decrease the likelihood of a crown fire. Fire would still burn with sufficient intensity to create 

small openings in untreated areas. This type of pattern would be consistent with patterns under 

historic fire regimes and is consistent with the recommendations for maintaining habitat for northern 

flying squirrels (Lehmkuhl et al. 2006a; Lehmkuhl et al. 2006b) and woodrats in inland forests, while 

managing for fire and healthy forest ecosystems. Additionally, prescribed fires would create a 

patchwork of small openings within the forest that would support mature hardwoods and a variable 

understory of hardwoods and shrubs used by woodrats and other prey. Denser forest (at least 

60 percent canopy cover), with numerous large snags and large CWD, would remain widespread and 

continue to provide habitat for prey species. 

Effects on Critical Habitat from other proposed project activities throughout the Assessment Area, 

such as road construction, are expected to be minimal. Under Alternative B the construction of 

1.03 miles of new temporary roads would create a loss of approximately 0.60 acre of foraging habitat 

and 0.02 acre of habitat classified as nesting/roosting. However, based on the physiographic features 

of the locations of the 0.62 acre, it is more likely to function as dispersal habitat. The roads will be 

closed (ripped and mulched, as needed) following treatment, so no long-term effects are expected on 

Critical Habitat. No new landings are proposed, and existing landings will not be expanded under 

Alternatives B and C, thus no long-term effects on Critical Habitat are expected. 

Late-successional habitat will not be removed during project activities. Thinning and fuel 

reduction treatments have been designed to minimize the removal of trees greater than 20 inches dbh, 

and all prescriptions retain adequate canopy cover in existing NSO habitat, and LSRA 

recommendations for snag and CWD retention are followed. Thus, the project is not expected to 

affect connectivity of late-successional habitats or the ability of the Eddy Gulch LSR to provide a 

functional, interactive, late-successional forest. 

Cumulative Effects on NSOs and Critical Habitat. Alternative B, combined with local 

community fuel reduction projects, including the proposed fuelbreak system west of Black Bear 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-92 Chapter 3: Affected Environment and Environmental Consequences

Ranch, would further decrease the risk of high-intensity fire inside and near the Eddy Gulch LSR. 

The other proposed or anticipated actions include the installation of a fiber-optic line and North Fork 

Roads Stormproofing Project and, when combined with Alternative B, would cause no cumulative 

effects on NSOs, Critical Habitat, or NSO prey beyond the project’s direct and indirect effects. 

There are approximately 28,797 acres of suitable NSO habitat within the portion of the Scott and 

Salmon Mountains CHU subunit 35 contained in Eddy Gulch LSR. Cumulatively, the project would 

affect the Scott and Salmon Mountains CHU subunit 35 by removing less than 0.5 percent of the 

existing nesting/roosting habitat and modifying 2 percent of the existing foraging habitat within this 

subunit; all of these acres would continue to function as foraging habitat. Due to the limited effects on 

the PCEs, Alternative B would not significantly increase the cumulative effects on the CHU 

regardless of other reasonably foreseeable future actions, including installation of a fiber optic line, 

North Fork Roads Stormproofing Project, and the fuelbreak system west of Black Bear Ranch. 

Reducing fuel levels would have long-term beneficial effects on Critical Habitat by reducing the risk 

of stand-replacing fire in the landscape. 

Forest Service Sensitive Species 

Tehama Chaparral and Klamath Shoulderband— 

Direct and Indirect Effects. No direct effects are anticipated to the Tehama chaparral, the 

Klamath shoulderband, or their habitat. The animals are likely to be subsurface during the burning 

season, and no fuel reduction activities are proposed that would significantly affect conditions on 

talus. Thinning and fuel reduction treatments are expected to have a beneficial indirect effect by 

substantially reducing the chances and extent of stand-replacing fires which can remove riparian 

vegetation and lead to increased temperatures and desiccation. Large-diameter shade trees and CWD 

would increase over the long-term as a result of Alternative B. 

The construction of 1.03 miles of new temporary roads (which would disturb approximately 

1.7 acres) is not expected to have any significant effect on the species because all temporary roads are 

on ridgetops or near-ridgetop locations, and the amount of disturbance is small at the landscape level. 

All of the temporary roads would be closed using normal erosion control measures (ripped and 

mulched, as needed). Implementation of hazard tree removal is not expected to have any effect on the 

overall amount of suitable habitat for these species because the removal of a few scattered trees 

would not affect canopy shade. 

Cumulative Effects. Alternative B, alone or in concert with other ongoing or reasonably 

foreseeable future actions listed in Section 3.1.4 above, is not expected to cause any cumulative 

effects on these species or their habitat. These projects are expected to have either no effect (fiber 

optic project) or to result in net improvement (North Fork Roads Stormproofing Project and fuelbreak 

system west of Black Bear Ranch) to overall habitat conditions and natural resources. Combined with 

local community fuel reduction projects, which will not be removing habitat, Alternative B would 

decrease the risk of high-intensity fire in and near the Assessment Area. No other actions would 

combine to create any significant effects on the Tehama chaparral or the Klamath shoulderband. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.4 – Wildlife and Habitat 3-93

Southern Torrent Salamander and Foothill Yellow-legged Frog— 

 Direct and Indirect Effects. Thinning and mastication would not have any direct effects on 

these two species because they are protected by design standards and Resource Protection Measures 

designed to minimize effects on aquatic habitats and Riparian Reserves. Prescribed fires that burn in 

Riparian Reserves may reduce vegetative cover, but limited low-intensity fire in Riparian Reserves is 

not likely to affect individuals because they are not likely to occur in terrestrial habitats that would be 

affected by fire. Direct effects from road-related activities are highly unlikely because all temporary 

roads are on ridgetops or near-ridgetop locations, and the amount of disturbance is small at the 

landscape level. No proposed roads are near Riparian Reserves, none require any stream crossing 

structures, none traverse unstable slopes, and none are proposed on granitic or similarly noncohesive 

soils. All of the temporary roads would be closed using normal erosion control measures (ripped and 

mulched, as needed). 

Thinning and fuel reduction treatments are expected to have a beneficial indirect effect in the 

long-term on southern torrent salamander by reducing the chances and extent of stand-replacing fires 

(to approximately 10 percent of existing conditions), which can remove riparian vegetation and lead 

to increases in increases in stream temperature and sedimentation. Large-diameter shade trees and 

CWD would increase over the long term under Alternative B. 

The indirect effects on southern torrent salamander from temporary road construction and fuel 

reduction activities would be negligible because any sedimentation would be minimized by the 

retention of buffers around all Riparian Reserves. These buffers, as well as Best Management 

Practices (BMPs), would minimize the sediment load that could reach stream channels. 

Thinning and fuel reduction treatments may have a minor beneficial indirect effect on foothill 

yellow-legged frogs by reducing the chances and effects of sedimentation from stand-replacing fires. 

Thinning and mastication would not cause sedimentation of streams because Klamath LRMP 

Standards and Guidelines would be followed, including Riparian Reserve buffers and implementation 

of BMPs. 

Limited low-intensity prescribed fire in Riparian Reserves is not likely to affect habitat for 

foothill yellow-legged frogs because such fires are not likely to affect aquatic habitat or substantially 

affect stream shading. However, reduced fire frequency resulting from proposed treatments may 

reduce fire-return intervals below historical intervals and reduce habitat available for species that 

benefit from sunlight on aquatic habitats. 

Cascades Frog and Western Pond Turtle— 

Direct and Indirect Effects. Thinning and mastication would not have any direct effects on 

these species because their habitat is protected by design standards and Resource Protection Measures 

designed to minimize effects on aquatic habitats and Riparian Reserves. Prescribed fires that burn in 

Riparian Reserves may reduce vegetative cover, but limited low-intensity prescribed fire in Riparian 

Reserves is not likely to affect frogs because they are not likely to occur in terrestrial habitats that 

would be affected by fire. Treatments on land adjacent to Riparian Reserves may affect upland turtle 

nest sites, although these effects should be rare events because turtles select open areas dominated by 

grasses and herbaceous annual plants, and fuel reduction activities would be focused on forest or 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-94 Chapter 3: Affected Environment and Environmental Consequences

shrub habitats on forested ridges. Direct effects from road-related activities are highly unlikely 

because effects are similar to those described above for the southern torrent salamander and foothill 

yellow-legged frog. 

Fuel reduction activities are not expected to affect the amount of habitat along the edge of the 

Salmon Rivers or along the edge of private ponds. Underburns would not be expected to have a 

significant effect on shade within Riparian Reserves. Creation of temporary roads, followed by 

subsequent closure following thinning, may have negligible, short-term indirect effects on stream 

habitat as a result of the potential for sediment delivery to streams within the Assessment Area. 

Implementation of BMPs and protection measures for fish would eliminate any potential downstream 

effects (in the Salmon Rivers) of sedimentation from roadwork. There would be no indirect effects on 

Cascades frog or pond turtle habitat as a result of sedimentation. 

Alternative B supports habitat components of late-successional forests that would provide for 

increased CWD and thus potential basking structure for the pond turtle over the long-term. However, 

reduced fire frequency promoted by the proposed treatments may reduce fire-return intervals below 

historical intervals and reduce habitat available for species that benefit from sunlight on aquatic 

habitats. 

Cumulative Effects—Southern Torrent Salamander, Cascades Frog, Western Pond Turtle, 

and Foothill Yellow-legged Frog. Alternative B, combined with local community fuel reduction 

projects, would decrease the risk of high-intensity fire in and near the Assessment Area. No other 

ongoing or reasonably foreseeable future actions within the Assessment Area would combine to create 

any significant cumulative effects on the southern torrent salamander, the Cascades frog, Western 

pond turtle, the foothill yellow-legged frog, or their habitat. 

Bald Eagle— 

Direct and Indirect Effects. No direct effects are expected to occur from implementation of 

Alternative B. Fuel reduction activities could potentially affect bald eagles through the production of 

fire, smoke, and visual and noise disturbance near their nests. There are no known nests, but if a new 

nest is discovered, a seasonal restriction of January 1 to August 31 would protect eagles from all 

activities that that modify habitat within 0.5 mile, or that create smoke or noise above ambient levels 

within 0.25 mile of any nest sites that are discovered within the Assessment Area. 

Thinning and other fuel reduction treatments are not likely to directly affect bald eagle habitat 

because, there is only one FRZ (FRZ 7) within 2 miles of potential foraging habitat, and no M Units 

or other overstory thinning would occur in FRZ 7. Understory treatments would not be expected to 

affect bald eagle habitat. 

Thinning and fuel reduction treatments may have beneficial indirect effect by reducing the 

potential loss of nest trees or nest stands from higher-intensity fires and by reducing potential 

sedimentation effects on foraging habitat from stand-replacing fires. Thinning and mastication would 

not cause sedimentation of the Salmon River because Klamath LRMP Standards and Guidelines 

would be followed, including Riparian Reserve buffers and implementation of BMPs. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.4 – Wildlife and Habitat 3-95

Cumulative Effects. Alternative B, combined with other ongoing or reasonably foreseeable 

future actions listed in Section 3.1.4 above, is not expected to cause any cumulative effects on the 

bald eagle, their prey, or their habitat. These projects are expected to have either no effect (fiber optic 

project) or to result in net improvement (North Fork Roads Stormproofing Project and fuelbreak 

system west of Black Bear Ranch) to overall habitat conditions and natural resources. Combined with 

local community fuel reduction projects, which will not be removing habitat, Alternative B would 

decrease the risk of high-intensity fire in and near the Assessment Area. No other actions would 

combine to create any significant effects. 

Northern Goshawk—

 Direct and Indirect Effects. Habitat use by goshawks and NSOs in the Klamath region are 

similar. Thus the nesting/roosting and foraging habitat discussions for the NSO also apply to the 

goshawk. 

Thinning and, to a much lesser extent, prescribed burning and mastication would reduce features 

that are used to define suitable goshawk nesting and foraging habitat: canopy cover, basal area, and 

the number of large-diameter trees. However, thinning and other fuel reduction activities would not 

affect goshawk habitat because the prescriptions avoid downgrading existing habitat. Fuel reduction 

activities would have little effect on canopy cover because burning would remove smaller trees that 

do not substantially contribute to canopy cover in the overstory. All M Units in FRZs would have 

canopy cover reduced below 60 percent, but all stands would still function as foraging habitat as the 

prescriptions maintain at least 40 percent canopy cover and retain all trees greater than 20 inches dbh. 

The construction of 1.03 miles of temporary roads under Alternative B would create a loss of less 

than one acre of forested habitat; additionally, these roads are scattered, thus habitat losses are small 

and dispersed and the roads would be closed upon project completion. No temporary roads are 

proposed in or near known goshawk activity centers. 

The 1.0-mile home ranges of two GOMAs (Sixmile and West Fork Whites) and another activity 

center located during 2008 surveys (Shadow) lie within proposed FRZs. The proposed treatments 

would not harm any of these protected areas because thinning or other fuel reduction activities would 

retain foraging habitat and because nesting habitat would not be reduced to less than 300 acres in the 

one activity center for which mechanical treatments are proposed (approximately 37 acres within the 

Primary Nest Zone of the Shadow Creek territory). No overstory thinning is proposed for the West 

Fork Whites GOMA, with the exception of the removal of individual roadside hazard trees, which 

would not affect the number of acres of suitable habitat. Thinning prescriptions in the Sixmile GOMA 

ensure that thinned stands in the Foraging Habitat Zone (FHZ) would retain at least 40 percent 

canopy and all trees greater than 20 inches dbh, meeting Klamath LRMP Standards for goshawk FHZ 

Fuel reduction activities, primarily fire and mastication, may kill, injure, or displace prey, but is 

not expected to reduce overall canopy cover. Although prey densities may be reduced in affected 

areas, treatments are designed to minimize effects on prey by limiting treatments to no more than 

50 percent of NSO suitable habitat within a year. Prescribed fire is also designed to leave a mosaic of 

burned and unburned areas so some shrubs and snags would remain to provide cover for prey species 

and minimize effects on goshawks. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-96 Chapter 3: Affected Environment and Environmental Consequences

Limited thinning outside of nest areas is unlikely to affect goshawk occupancy of historic nest 

stands. Many thinned stands that downgrade habitat would also become at least foraging habitat over 

time as canopy cover increases. 

Thinning and fuel reduction treatments are expected to benefit goshawk habitat by substantially 

reducing the forest’s susceptibility to stand-replacing crown fires. Fire would still burn with sufficient 

intensity to create small openings within forested habitat. This type of pattern, which would create a 

mosaic of stands in different successional stages, would be consistent with patterns under historic fire 

regimes. This pattern would likely benefit goshawks by providing horizontal diversity of habitat 

across the landscape. 

Fuel reduction treatments would cause changes in the amount and/or types of snags, CWD, 

understory vegetation including small trees, and prey. Treatments would remove or consume many 

existing snags and hazard trees, but effects on northern goshawks would be negligible because 

prescribed burning would create some new snags and seasonal restrictions would apply to all treated 

areas within historic or additional sites within the Assessment Area (please refer to the Resource 

Protection Measures, Section 2.9.1.2 in Chapter 2 of this final EIS). Most understory vegetation 

would also be removed in fuel reduction areas. Mastication would not remove trees greater than 

10 inches dbh, and burning would not remove trees greater than 4 inches dbh. Emergency access 

routes are hand treatments along sides of roads, and hazard tree removal would follow pre-approved 

guidelines (USFS 2005). Removing small trees would have no effect on existing foraging or nesting 

habitat. 

Fuel reduction treatments would initiate successional changes in forest understory, including 

snags and CWD. The CWD would accumulate from fallen snags and understory vegetation would 

regenerate in most areas. Reduced vegetative competition would also accelerate tree growth in some 

areas. Northern goshawk prey species are likely to increase as understory vegetation and litter layers 

recover, CWD is recruited from the snag population, and additional snags are recruited. Thus, effects 

on goshawk prey species abundance and distribution are expected to be minimal. 

Thinning and fuel reduction activities have the potential to affect northern goshawks through the 

production of fire, smoke, visual, and noise disturbance. Northern goshawks are sensitive to noise 

disturbances during nesting and will often exhibit defensive territorial behavior around nest sites 

when disturbed (CDFG 1990). Noise produced during fuel reduction activities may alter nesting 

behavior. 

Disturbance may also occur from fire, smoke, or other activities associated with prescribed fire. 

Heavy smoke at ground level and in forested stands may have adverse effects, but light to moderate 

smoke that is mixing or venting well is probably of little consequence to northern goshawks. It is 

expected that adults are sufficiently mobile to avoid direct injury by fire. To ensure that breeding 

goshawks are not disturbed by activities that create noise above ambient levels or smoke near nest 

stands, seasonal restrictions will be in place from March 1 to August 31 that apply to all activities that 

modify habitat within 0.5 mile, or create smoke or noise above ambient levels within 0.25 mile of 

historic sites or any additional nest sites that are discovered within the Assessment Area. Dates for 

seasonal restrictions cover the time period from which adult goshawks typically initiate breeding 

activity to the point where juveniles are physically capable of moving away from such disturbances. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.4 – Wildlife and Habitat 3-97

Temporary roads proposed for construction under Alternative B would be closed (ripped and 

mulched, as needed) following thinning and thus become available as habitat over the long term. 

Cumulative Effects. Alternative B, combined with other ongoing or reasonably foreseeable 

future actions listed in Section 3.1.4 above, is not expected to cause any cumulative effects on 

northern goshawks, their prey, or their habitat. These projects are expected to have either no effect 

(fiber optic project) or to result in net improvement (North Fork Roads Stormproofing Project and 

fuelbreak system west of Black Bear Ranch) to overall habitat conditions and natural resources. 

Combined with local community fuel reduction projects, which will not be removing habitat within 

established GOMAs, Alternative B would decrease the risk of high-intensity fire in and near the 

Assessment Area. No other actions would combine to create any significant effects. 

Peregrine Falcon— 

Direct and Indirect Effects. Peregrine falcon nesting/roosting habitat would not be directly 

or indirectly affected by the proposed fuels reduction activities. Peregrine falcons are known to be 

susceptible to disturbance near their nests. There are no known nests in the vicinity; if a new nest is 

discovered, a seasonal restriction of February 1 to July 31 would protect peregrines from all activities 

that create noise above ambient levels within 0.25 to 0.5 mile (dependent on topographic features) of 

active eyries. 

Cumulative Effects. Alternative B, combined with other ongoing or reasonably foreseeable 

future actions listed in Section 3.1.4 above, is not expected to cause any cumulative effects on the 

peregrine falcon, their prey, or their habitat. These projects are expected to have either no effect (fiber 

optic project) or to result in net improvement (North Fork Roads Stormproofing Project and fuelbreak 

system west of Black Bear Ranch) to overall habitat conditions and natural resources. Combined with 

local community fuel reduction projects, which will not be removing habitat, Alternative B would 

decrease the risk of high-intensity fire in and near the Assessment Area. No other actions would 

combine to create any significant effects. 

Willow Flycatcher— 

 Direct and Indirect Effects. Thinning and fuel reduction treatments are not expected to have 

any direct or indirect effects on willow flycatchers. However, the prevention of stand-replacing fire—

the only process that would likely create mostly treeless riparian scrub required by the flycatcher—

would likely preclude use of the Assessment Area by willow flycatchers. Limited low-intensity 

prescribed fire in Riparian Reserves could affect individuals if suitable patches of riparian scrub (not 

known from the Assessment Area, but possible) were burned. 

 Cumulative Effects. Alternative B, combined with other ongoing or reasonably foreseeable 

future actions listed in Section 3.1.4 above, is not expected to cause any cumulative effects on the 

willow flycatcher, their prey, or their habitat. These projects are expected to have either no effect 

(fiber optic project) or to result in net improvement (North Fork Roads Stormproofing Project and 

fuelbreak system west of Black Bear Ranch) to overall habitat conditions and natural resources. 

Combined with local community fuel reduction projects, which will not be removing habitat, 

Alternative B would decrease the risk of high-intensity fire in and near the Assessment Area. No other 

actions would combine to create any significant effects. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-98 Chapter 3: Affected Environment and Environmental Consequences

Pallid Bat and Townsend’s Big-eared Bat—

 Direct and Indirect Effects. Fuel reduction treatments and temporary road construction are 

expected to have short-term minor adverse direct effects on both bat species. Project activities may 

remove individual trees or snags that may be used for roosting, especially by the pallid bat, which 

occurs widely in many forest types. Destruction of active roosts through felling and/or removal of 

trees or snags may kill or harm individual bats, especially during the breeding season when young 

may be unable to escape. However, effects on roosting habitat are expected to be minimized by the 

lack of thinning in NSO core areas, by employing the Klamath LRMP Standards and Guidelines for 

snag and large-diameter tree retention in most of the FRZs, and by implementing limited operating 

periods for the NSO and northern goshawk that overlap the period when bats rear their young. Noise 

from project activities could disturb bats and cause temporary roost abandonment. Abandonment of 

maternity roosts could result in lowered reproductive success or death of the young of the year. 

However, disturbance at any specific roost would be short term and occur only during the year of 

project implementation. 

Prescribed fires may affect prey availability, either positively or adversely, as vegetation and litter 

layers are consumed. Thinning and other fuel-reduction treatments are expected to have long-term 

beneficial effects by promoting the development of large-diameter trees, which may provide suitable 

roosting sites. Reintroduction of fire would also be likely to create basal hollows and other cavities 

used by bats. Additionally, these activities would change expected fire behavior over time, resulting in 

fires of less intensity, thus reducing the potential that existing habitat would be removed. 

Prey availability would most likely increase over time because prescribed fire promotes vigorous 

growth of understory vegetation and insect production. Felling of snags and removal of logs may 

reduce the amount of microhabitat available for some insects, but new fire-killed snags would also 

provide a new resource for some insects such as wood-boring beetles. 

Cumulative Effects. Alternative B, combined with other ongoing or reasonably foreseeable 

future actions listed in Section 3.1.4 above, is not expected to cause any cumulative effects on the 

pallid and Townsend’s bats, their prey, or their habitat. These projects are expected to have either no 

effect (fiber optic project) or to result in net improvement (North Fork Roads Stormproofing Project 

and fuelbreak system west of Black Bear Ranch) to overall habitat conditions and natural resources. 

Combined with local community fuel reduction projects, which will not be removing habitat, 

Alternative B would decrease the risk of high-intensity fire in and near the Assessment Area. No other 

actions would combine to create any significant effects. 

American Pine Marten— 

Direct and Indirect Effects. All proposed activities, including road-related activities, in the 

vicinity of suitable habitat could disrupt marten use and movement in the area and create short-term 

adverse direct effects on individuals. Thinning and fuel reduction activities have the potential to affect 

martens through the production of fire, smoke, and noise disturbance. Noise produced during fuel 

reduction activities may alter marten behavior, but preliminary studies have not found martens to be 

particularly sensitive to noise (Zielinski et al. 2004c). Underburning in the vicinity of den sites could 

cause mortality of young if dens are above ground or are not well ventilated. It is expected that adult 

animals are sufficiently mobile to avoid direct injury by fire. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.4 – Wildlife and Habitat 3-99

Thinning of 931 acres in FRZs (approximately 3.8 percent of the mid- and late-successional 

habitat in the Assessment Area), and, to a much lesser extent, prescribed burning and mastication, 

would reduce canopy cover, basal area, and the number of large-diameter trees. All thinned stands in 

FRZs would have canopy cover reduced below 60 percent, but many stands would still function as 

habitat because they would retain large trees and at least 40 percent canopy cover. 

Fuel reduction treatments, primarily prescribed fire but also mastication and thinning, would also 

cause changes in the amount and/or types of snags, CWD, and understory vegetation, but would have 

little effect on canopy cover because burning would remove smaller trees that do not substantially 

contribute to canopy cover in the overstory. Thinning would remove snags, but the effects on martens 

would most likely be negligible because the treated areas would be limited in extent (approximately 

11 percent of the FRZ area) and would also avoid NSO core areas and Riparian Reserves. 

Mastication would destroy small down woody debris, and some snags but would retain large 

snags and large-diameter down woody debris according to Klamath LRMP guidelines. Prescribed fire 

would consume much of the smaller down woody debris and some snags but would create many new 

snags. Much of the large down woody debris would likely remain when burning in spring-like 

conditions, and this would help ensure that subnivean access is available in winter. Temporary 

displacement of individuals may occur; however, no long-term adverse effects on the species are 

expected from the loss of smaller CWD and occasional snags. 

Fuel reduction activities, primarily fire and mastication, may also kill, injure, or displace prey. 

Although prey densities may be reduced in affected areas, treatments are designed to minimize effects 

on prey by limiting treatments to no more than 50 percent of the suitable NSO habitat within a year. 

Prescribed fire is also designed to leave a mosaic of burned and unburned areas so some shrubs, 

snags, and CWD would remain to provide cover for prey species and minimize effects on martens. 

Martens may temporarily benefit from fuel reduction activities as rodent prey move to avoid 

disturbance or concentrate in remaining patches of habitat. 

Thinning, mastication, and prescribed burning activities may result in short-term reductions in 

available prey as CWD and understory vegetation are reduced. However, fuel reduction treatments 

are expected to benefit martens by substantially reducing the forest’s susceptibility to stand-replacing 

crown fires. As the habitat develops over time, it is expected that there would be an increase in 

denning and resting sites (with an increase in CWD), as well as complex structure near the forest 

floor that would provide prey habitat and marten direct access to the subnivean zone for marten. 

Cumulative Effects. Alternative B, combined with other ongoing or reasonably 

foreseeable future actions listed in Section 3.1.4 above, is not expected to cause any cumulative 

effects on the marten, their prey, or their habitat. These projects are expected to have either no effect 

(fiber optic project) or to result in net improvement (North Fork Roads Stormproofing Project and 

fuelbreak system west of Black Bear Ranch) to overall habitat conditions and natural resources. 

Combined with local community fuel reduction projects, which will not be removing habitat, 

Alternative B would decrease the risk of high-intensity fire in and near the Assessment Area. No other 

actions would combine to create any significant effects. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-100 Chapter 3: Affected Environment and Environmental Consequences

Pacific Fisher— 

Direct and Indirect Effects. The potential direct effects on Pacific fishers from vegetation 

management activities under Alternative B consist of modification or loss of habitat or habitat 

components, especially with regard to denning and resting habitat and foraging and movement 

habitat. Direct effects would also include behavioral disturbance to denning from thinning, road 

construction, prescribed fire, or other associated activities. 

Direct effects from noise and prescribed fires can lead to the displacement of individuals or the 

disruption of foraging and breeding activities. Denning effects are expected to be negligible because 

Resource Protection Measures put in place to protect the NSO during the breeding season would 

indirectly protect denning individual fishers. Fishers are also a highly mobile species such that effects 

on foraging individuals would be minor, as areas with human disturbance would likely be avoided by 

foraging individuals. Temporary displacement of individuals may occur as a result of the proposed 

treatments; however, the Resource Protection Measures put in place to protect 50 percent of all 

suitable NSO habitat, over the course of any one season, would minimize disturbance to any fisher 

sharing similar habitat. Additionally, by ensuring that breeding NSOs are not disturbed by activities 

that create noise above ambient levels or have an intrusion of smoke at the nest, the seasonal 

restriction within owl habitat would indirectly reduce disturbance likelihood on fishers. 

Fisher habitat is typically characterized as mature, structurally diverse, closed canopy stands, but 

fisher will occupy managed or burned stands if remnant structures are maintained (Jones 1991; 

Yaeger 2005). Thinning in FRZs and, to a much lesser extent, prescribed burning and mastication, 

would reduce four features that are used to define suitable resting, denning, and foraging habitat: 

canopy cover, basal area, CWD, and the number of large-diameter trees. However, because fisher 

denning and resting habitat is considered a subset of suitable NSO habitat, thinning and other fuel 

reduction activities would downgrade 47 acres and is therefore unlikely to affect individuals or 

overall habitat in size and scope of the landscape and total available habitat that remains. 

Additionally, the prescriptions modifying 323 additional acres of suitable habitat will adhere to NSO 

standards and would indirectly protect features preferred by the Pacific fisher. 

All thinned stands in FRZs would have canopy cover reduced below 60 percent (no less than 

48 percent in Douglas-fir or mixed-conifer stands), but stands that retain at least 40 percent canopy 

cover would still function as movement habitat and as foraging habitat because they would retain 

large trees (with basal areas in the range of 132 to 230 square feet per acre), and thinning would 

generally proceed from below so that the larger trees would remain, including all trees larger than 

28 inches (except hazard trees). Thinning would reduce canopy cover below 40 percent (to no less 

than 32 percent) in some white and red fir stands, but preferred habitat is common and widespread in 

the Assessment Area, so a small reduction in ridgetop movement habitat would not create any 

dispersal barriers for individuals. Additionally, Resource Protection Measures for Riparian Reserves 

would ensure habitat connectivity and movement patterns for individuals. 

Fuel reduction treatments, primarily prescribed fire, but also mastication and thinning, would 

cause changes in the amount and/or types of snags, CWD, and understory vegetation, but would have 

little effect on canopy cover because burning would remove smaller trees that do not substantially 

contribute to canopy cover in the overstory. Thinning would remove snags but the effects on 

individuals would most likely be negligible because the treated areas would be limited in extent 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.4 – Wildlife and Habitat 3-101

(approximately 11 percent of the FRZ area), and would be located along ridges, which are used less 

frequently by resting individuals. Mastication would destroy small down woody debris and some 

snags but would retain large snags and large-diameter down woody debris. Prescribed fire would 

consume much of the smaller down woody debris and some snags but would create many new snags. 

Much of the large down woody debris is likely to remain when burning in spring-like conditions. 

Effects on fisher would also be minimized by retaining unburned habitat (at least 10 percent) in the 

ridgetop FRZs. 

Fuel reduction activities, primarily fire and mastication, may kill, injure, or displace preferred 

prey. Although prey densities may be reduced in affected areas, treatments are designed to minimize 

effects on NSO prey, and therefore indirectly to fisher prey, by limiting treatments to no more than 

50 percent of the NSO suitable habitat within a year. Prescribed fire is also designed to leave a mosaic 

of burned and unburned areas so some shrubs, snags, and CWD would remain to provide cover for 

prey species and minimize effects on the Pacific fisher. 

Construction of 1.03 miles of temporary roads under Alternative B would create a short-term loss 

of approximately 0.62 acre of suitable NSO habitat; the habitat loss is small and widely scattered, and 

includes only 0.5 acre of late-successional habitat. Additionally, the roads would be closed (ripped 

and mulched, as needed) following thinning, and those areas would become available as habitat over 

the long term. 

Approximately 47.3 acres of resting/denning would be downgraded within the entire Assessment 

Area, but large-diameter trees, snags, and CWD would be retained on the landscape. Because the 

patches of habitat to be removed are along ridges and are dispersed across the Assessment Area, fuel 

reduction activities are not expected to affect the ability of remaining habitat to provide foraging 

opportunities or create barriers to movement. Therefore, the action alternatives are not expected to 

affect the ability of the habitat to provide resting, foraging, and dispersal abilities for the Pacific 

fisher. 

The prescriptions for thinning and fuels treatments are consistent for maintaining habitat for small 

mammals in northern interior forests while managing for fire and healthy forest ecosystems. Fuel 

reduction treatments would initiate successional changes in forest understory, including snags and 

CWD. Prey species are likely to increase as understory vegetation and litter layers recover and CWD 

is recruited from the snag population. Reduced vegetative competition would also accelerate tree 

growth in some areas (see Tables 3-6, 3-7, and 3-8 in Section 3.2 above). Thus, effects on Pacific 

fisher prey species abundance and distribution are expected to be minimal. 

Thinning and fuel reduction treatments are expected to benefit fisher habitat by reducing the 

forest’s susceptibility to stand-replacing crown fires to approximately 10 percent of current 

conditions. Fire would still burn with sufficient intensity to create small openings within forested 

habitat. This type of pattern, which would create a mosaic of stands in different successional stages, 

would be consistent with patterns under historic fire regimes. This pattern would likely benefit fisher 

and their prey by providing horizontal diversity of habitat across the landscape. 

The protection of NSO activity centers, northern goshawk habitat, and Riparian Reserves would 

provide connectivity between large blocks of suitable habitat. Implementation of either action 

alternative would not increase any large-scale, high-contrast fragmentation above current levels. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-102 Chapter 3: Affected Environment and Environmental Consequences

Riparian zones (used as movement corridors) would not be altered by the proposed treatments; 

therefore, indirect effects that could result from implementation of either action alternative would 

have minimal effects on the movement patterns of Pacific fishers. Implementation of Alternative B 

should have little effect on the suitable denning and foraging habitat. Additionally, design features of 

FRZs would retain habitat elements within the range of those used by fisher for foraging and 

dispersal, such that the FRZs would likely not create large barriers to further expansion and 

connectivity to fisher habitat. Temporary roads under Alternative B would be closed (ripped and 

mulched, as needed) following thinning, and those areas would become available as habitat over the 

long term. 

The risk for potential stand-replacing fires would be considerably higher under the no-action 

alternative than Alternative B, which could mean a loss of many more acres of potentially suitable 

denning, foraging, roosting, and travel habitat in the long term. The Pacific fisher may be affected by 

project activities, but the activities are not expected to result in significant indirect effects. 

Cumulative Effects. Alternative B, combined with other ongoing or reasonably foreseeable 

future actions listed in Section 3.1.4 above, is not expected to cause any cumulative effects on the 

fisher, their prey, or their habitat. These projects are expected to have either no effect (fiber optic 

project) or to result in net improvement (North Fork Roads Stormproofing Project and fuelbreak 

system west of Black Bear Ranch) to overall habitat conditions and natural resources. Combined with 

local community fuel reduction projects, which will not be removing habitat, Alternative B would 

decrease the risk of high-intensity fire in and near the Assessment Area. No other actions would 

combine to create any significant effects. 

California Wolverine— 

Direct and Indirect Effects. The effects of the proposed treatments on wolverine habitat 

would be similar to the effects on fisher and marten habitat, except that wolverines are most likely 

less dependent on closed-canopy forest and more susceptible to disturbance. Thinning, mastication, 

and road-related activities would employ heavy machinery and may require repeated visits to a site. 

Because wolverines are sensitive to human disturbance, these activities would likely prevent 

wolverines from using portions of the Assessment Area during project implementation. Short-term 

disturbance effects on movement and foraging activities are possible, but these effects would be 

localized and would not affect the population’s viability over time given the species’ low likelihood of 

presence in the region. 

Fuel reduction treatments, primarily prescribed fire but also mastication and thinning, would 

cause changes in the amount and/or types of snags, CWD, and understory vegetation. Thinning would 

remove snags, but the effects on individuals would most likely be negligible because the treated areas 

would be limited in extent (approximately 11 percent of the FRZ area). Mastication would destroy 

small down woody debris and some snags but would retain large snags and large-diameter down 

woody debris. Prescribed fire would consume much of the smaller down woody debris and some 

snags but would create many new snags. Much of the large down woody debris is likely to remain 

when burning in spring-like conditions. Effects on wolverine would also be minimized by retaining 

unburned habitat (al least 10 percent) in the ridgetop FRZs. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.4 – Wildlife and Habitat 3-103

Fuel reduction activities, primarily fire and mastication, may kill, injure, or displace preferred 

prey. Although prey densities may be reduced in affected areas, treatments are designed to minimize 

effects on NSO prey and therefore indirectly to some wolverine prey, by limiting treatments to no 

more than 50 percent of the suitable habitat within a year. Prescribed fire is also designed to leave a 

mosaic of burned and unburned areas so some shrubs, snags, and CWD would remain to provide 

cover for prey species and minimize effects on the wolverine. 

The construction of 1.03 miles of temporary roads under Alternative B would create a short-term 

loss of approximately 0.62 acre of habitat; however, the habitat loss is small and scattered and 

includes only 0.5 acre of late-successional habitat. Additionally, the roads would be closed (ripped 

and mulched, as needed) following thinning, and those areas would become available as habitat over 

the long term. 

Over time, thinning and fuel reduction treatments are expected to benefit wolverines by reducing 

fuels to a level that would decrease the likelihood of extensive, high-intensity fire. Fire would still 

burn with sufficient intensity to create small openings within forested habitat. This type of pattern, 

which would create a mosaic of stands in different successional stages, would be consistent with 

patterns under historic fire regimes. This pattern would likely benefit wolverines by providing 

horizontal diversity of habitat across the landscape, including habitat conditions favored by prey such 

as deer and elk. 

Cumulative Effects. Alternative B, combined with other ongoing or reasonably foreseeable 

future actions listed in Section 3.1.4 above, is not expected to cause any cumulative effects on the 

wolverine, their prey, or their habitat. These projects are expected to have either no effect (fiber optic 

project) or to result in net improvement (North Fork Roads Stormproofing Project and fuelbreak 

system west of Black Bear Ranch) to overall habitat conditions and natural resources. Combined with 

local community fuel reduction projects, which will not be removing habitat, Alternative B would 

decrease the risk of high-intensity fire in and near the Assessment Area. No other actions would 

combine to create any significant effects. 

Forest Service MIS Associations 

River and Stream MIS Associations— 

 Direct and Indirect Effects. Thinning and mastication would not have any direct effects on 

the habitat because it would be protected in the Riparian Reserves. Prescribed fires that would be 

implemented in Riparian Reserves may reduce vegetative cover over the short term, but limited lowintensity fire in Riparian Reserves is not likely to affect the overall habitat. 

Thinning and fuel reduction treatments are expected to have a beneficial indirect effect in the long 

term by reducing the chances and effects of stand-replacing fires, which can remove riparian 

vegetation and lead to increases in increases in stream temperature and sedimentation. Large-diameter 

shade trees and CWD would increase over the long term as a result of Alternative B. 

Road-related activities have the potential to affect habitat. The construction of 1.03 miles of new 

temporary roads would not have a significant effect on riparian-associated species because all new 

temporary roads would be on ridgetops or near-ridgetop locations. None of the new temporary roads 
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3-104 Chapter 3: Affected Environment and Environmental Consequences

would be near Riparian Reserves, none require any stream crossing structures, none traverse unstable 

slopes, and none are proposed on granitic or similarly non-cohesive soils. All of the new temporary 

roads would be closed using normal erosion control measures (ripped and mulched, as needed). Thus, 

direct adverse effects from road-related activities would be negligible. 

Temporary road construction and fuel reduction effects would be negligible because any 

sedimentation would be minimized by the retention of buffers around all Riparian Reserves. These 

buffers, as well as BMPs, would minimize the sediment load that could reach stream channels. 

Implementation of hazard tree removal would not change canopy cover at the stand or landscape 

level because the individual trees that are removed would be limited to road prisms and scattered 

throughout the landscape. Removal of a few scattered trees would not have a significant effect on 

habitat suitability or function for these species. 

In summary, the amount and quality of river and stream habitat in the Assessment Area would be 

the same pre- and post-project. Degradation of habitat components (such as riparian vegetation, 

individual shade trees) would occur in Riparian Reserves. A temporary shift or relocation of 

individuals may result from proposed activities in the landscape, but it is not expected to affect 

populations or population trends for tailed frogs, American dippers, or Cascade frogs. 

Cumulative Effects—River and Stream MIS and Marsh, Lake, and Pond MIS 

Associations. Future actions on upland areas in the Assessment Area are not expected to affect 

aquatic habitats, individuals, or population numbers. Therefore, Alternative B would not increase 

cumulative effects on species in these associations. 

Marsh, Lake, and Pond MIS Associations— 

Direct and Indirect Effects. No direct effects are expected to occur as a result of thinning or 

mastication under Alternative B because aquatic habitats are protected by Resource Protection 

Measures, BMPs, and Riparian Reserves. 

Although riparian habitat is not the vegetation type proposed for prescribed burns, the burns 

could move into riparian habitat; however, protective measures would be in place to ensure that 

upland habitat is protected while benefiting from the positive effects of a light underburn. 

Fuel reduction activities are not expected to affect the amount of habitat along the edge of the 

Salmon Rivers nor along the edge of private ponds. Underburns would not be expected to have a 

significant effect on shade within Riparian Reserves. The creation of temporary roads, followed by 

closure after thinning is complete, could deliver sediment to pond habitats, but implementation of 

BMPs would reduce any indirect effects to negligible. Treatments on land adjacent to Riparian 

Reserves may affect upland turtle nest sites, although these effects should be rare events because 

turtles select open areas dominated by grasses and herbaceous annual plants, and fuel reduction 

activities would be focused on forest or shrub habitats on forested ridges. 

Temporary road construction (under Alternative B) and fuel reduction effects would be negligible 

because any sedimentation would be minimized by the retention of buffers around all Riparian 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.4 – Wildlife and Habitat 3-105

Reserves. These buffers, as well as BMPs, would minimize the sediment load that could reach stream 

channels. 

Implementation of hazard tree removal would not change canopy cover at the stand or landscape 

level because the individual trees that would be removed are limited to road prisms and scattered 

throughout the landscape. Removal of these trees would not have a significant effect on habitat 

suitability or function for these species. 

 Cumulative Effects. Refer to the cumulative effects discussion above for the River and 

Stream MIS Association. 

In summary, the amount and quality of marsh, lake, and pond habitat in the Assessment Area 

would be the same pre- and post-project. Temporary degradation of some habitat components (such as 

riparian vegetation, basking sites, and upland nest areas) would occur in Riparian Reserves. A 

temporary shift or relocation of individuals may result from proposed activities in the landscape, but 

it is not expected to affect populations or population trends for the Western pond turtle. 

Hardwood MIS Associations— 

 Direct and Indirect Effects. Thinning in FRZs and construction 1.03 miles of temporary 

roads may remove important structural components of hardwood habitats such as large-diameter 

trees, snags, and CWD under Alternative B. However, the removal of large-diameter trees would only 

occur under limited circumstances; large snags or groups of snags would be retained over most of the 

landscape, and large-diameter hardwoods and CWD would be retained where consistent with FRZ 

objectives. Therefore, effects on the distribution and abundance of these habitat components are 

expected to be minimal. 

Fuel reduction treatments (prescribed fire and mastication) also have the potential to remove 

hardwoods, snags, and CWD. However, prescriptions are designed to imitate low-intensity fire and 

are designed to retain these components, especially hardwoods. Thus, fuels treatments are not 

expected to have a significant effect on important structural components of hardwood habitats. 

Thinning and fuel reduction treatments are expected to benefit hardwood habitats by reducing 

fuels to a level that would decrease the likelihood of extensive, high-intensity fire. Treatments would 

also increase hardwood dominance in some areas by reducing conifer overstory and competition from 

young conifers that have encroached into mature hardwood stands during the era of fire suppression. 
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Klamath National Forest Eddy Gulch LSR Project

3-106 Chapter 3: Affected Environment and Environmental Consequences

Hardwood MIS and Snag MIS Associations— 

 Cumulative Effects. Alternative B, combined with local community fuel reduction projects, 

including the proposed fuelbreak system west of Black Bear Ranch, would further decrease the risk of 

high-intensity fire inside and near the Assessment Area. The other proposed or anticipated actions 

include the installation of a fiber-optic line and North Fork Roads Stormproofing Project and, when 

combined with Alternative B, would cause no cumulative effects on hardwood habitat beyond the 

project’s direct and indirect effects. 

Overall, the amount of hardwood habitat in the Assessment Area would be the same pre- and 

post-project. Degradation of habitat components (such as individual trees) would occur with the 

removal of some hardwoods in mixed hardwood-conifer stands and plantations and the removal of 

large conifers. Shifting or relocation of territories may result from proposed activities in the 

landscape, but it is not expected to affect populations or population trends for western gray squirrels 

or acorn woodpeckers. 

Snag MIS Associations— 

Direct and Indirect Effects. Thinning, hazard tree removal, and construction of 1.03 miles 

of temporary roads may remove large-diameter snags. However, the removal of large-diameter snags 

would only occur under limited circumstances, and snags would be retained at Klamath LRMP 

Standards and Guidelines. Removal of snags and CWD is consistent with the Alternative B treatment 

objectives in effectively reducing the existing fuel loads. Though the objectives are to reduce fuels 

loading in proposed M Units and FRZs, components for adequate amounts of snag and CWD will be 

met at a landscape level as described in the Klamath LRMP Standard and Guidelines (pages 4-25 and 

4-39). Naturally, there is a high degree of variability of snags and CWD across the stands of the Eddy 

Gulch LSR. Prescribed fire and mastication would also remove snags; however, prescriptions are 

designed to imitate low-intensity fire and would also create many snags. Thus, habitat for snagdependent species would remain abundant and well distributed throughout the Assessment Area, and 

the effect is considered negligible to populations and population trends. 

Thinning and fuel reduction treatments would benefit snag-dependent species in forested habitats 

by reducing fuels to a level that would decrease the likelihood of extensive stand-replacing fire. Fire 

would still burn with sufficient intensity to create snags within forested habitat. This type of pattern 

would be consistent with patterns under historic fire regimes. 

Cumulative Effects. Alternative B, combined with other ongoing or reasonably foreseeable 

future actions, is not expected to cause any cumulative effects on snag habitats, individual species 

associated with the snag habitat, or population numbers. Combined with local community fuel 

reduction projects, Alternative B would decrease the risk of high-intensity fire both inside and near 

the Assessment Area. 

3.4.5.3 Alternative C: No New Temporary Roads Constructed 

Federally Listed Species 

 Direct and Indirect Effects on NSO Habitat from Treatments in M Units (Inside FRZs). 

Alternative C would be similar to Alternative B; however, the 1.03 miles of temporary roads would 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.4 – Wildlife and Habitat 3-107

not be constructed, resulting in 99 fewer acres being treated. This would result in no treatments or 

changes to 30 acres of foraging habitat outside of any NSO core area but within home ranges. These 

30 acres would, however, be susceptible to a wildfire. 

Direct and Indirect Effects of Treatments in Fuel Reduction Areas in FRZs and Along 

Emergency Access Routes. Effects would be the same as found under Alternative B. 

Direct and Indirect Effects of Treatments in Rx Units. Treatments under Alternative C would 

have the same effect as those found under Alternative B, but 822 fewer acres would be treated 

because no temporary roads would be created for access to these acres. These untreated areas would 

be susceptible to a wildfire, which could remove habitat in the home range of KL1028. 

Direct and Indirect Effects on NSO from Barred Owls Competition. Effects would be the 

same as under Alternative B. 

Direct and Indirect Effects on NSO Habitat and NSOs in Areas Affected by Wildfire.

Effects on NSO under Alternative C are very similar to Alternative B, except 1.03 miles of temporary 

roads would not be constructed, and 99 acres of M Units and 822 acres in Rx Units would not be 

treated. Without temporary roads only two NSO core areas would be treated differently than under 

Alternative B. KL1028 would have fewer acres treated (less than 400 acres) with prescribed fire and 

thus would leave greater than 80 percent of the core area and nesting/roosting habitat at risk of a 

crown fire, as well as the activity center. If a wildfire were to occur, approximately 81 percent of the 

400 acres that would not be treated would be subject to a crown fire, substantially removing that 

habitat. Under Alternative C, KL1032 approximately 10 percent of foraging habitat and 1 percent of 

nesting/roosting habitat, which is along or over a ridgetop from the activity center, would not be 

treated and could be subject to a crown fire. However, loss of such a small portion of the core area in 

KL1032 is not likely to affect a nesting pair or the status of the activity center. Fire brands from 

crown fires in untreated areas could land in other untreated areas, which could escape initial attack 

and adversely affect other NSO core areas or NSO Critical Habitat. Failure to treat 400 acres in 

KL1028 would also remove habitat should a wildfire occur in the Grasshopper Ridge USFWS 

priority protection area. 

Direct and Indirect Effects on NSO Critical Habitat. Approximately 30 acres of foraging 

habitat would not be affected by thinning activities under Alternative C, otherwise effects are the 

same as discussed under Alternative B. The 30 acres of foraging habitat that were treated in M Units 

under Alternative B are outside of any NSO core area and found only within home ranges that had an 

excess of foraging habitat. This was not considered to be an adverse effect on Critical Habitat. 

Treatments under Alternative C would have the same effect as Alternative B; however, 822 fewer 

acres would be treated in Rx Units because no temporary roads would be created for access to these 

acres. The 822 acres of Critical Habitat that were treated under Alternative B will not be treated under 

Alternative C and would therefore be subject to a higher fire danger and potential loss. 

Alternative C would be similar to Alternative B; however, the 1.03 miles of temporary roads 

would not be constructed, and this would result in 30 fewer acres of suitable habitat being treated. 

These 30 acres of Critical Habitat that would be treated in M Units under Alternative B, would not be 

treated under Alternative C and would thus be subject to a higher fire danger and potential loss. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-108 Chapter 3: Affected Environment and Environmental Consequences

Cumulative Effects on NSOs and Critical Habitat. The cumulative effects on NSOs under 

Alternative C are similar to Alternative B, except additional habitat could be burned during a wildfire 

if that fire occurred in one of the untreated areas. 

Forest Service Sensitive Species 

Tehama Chaparral and Klamath Shoulderband— 

 Direct and Indirect Effects. Affects are the same as found under Alternative B. 

 Cumulative Effects. Cumulative effects are the same as found under Alternative B. 

Southern Torrent Salamander and Foothill Yellow-legged Frog— 

 Direct and Indirect Effects. Affects are the same under Alternative B. 

 Cumulative Effects—Southern Torrent Salamander, Cascades Frog, Western Pond 

Turtle, and Foothill Yellow-legged Frog. Future actions in or near the Assessment Area are not 

expected to affect aquatic habitats; therefore, Alternative C would not result in cumulative effects on 

these species. 

Cascades Frog and Western Pond Turtle— 

Direct and Indirect Effects. Affects are the same as found under Alternative B. 

Cumulative Effects. See cumulative effects above under southern torrent salamander and 

foothill yellow-legged frog. 

Bald Eagle— 

Direct and Indirect Effects. Effects are expected to be the same as found under 

Alternative B. The untreated habitats in Alternative C are not near potential nesting habitat. 

Cumulative Effects—Eagle, Northern Goshawk, Peregrine Falcon, Willow Flycatcher, 

Pallid Bat, Townsend’s Big-Eared Bat, American Pine Marten, Pacific Fisher, and California 

Wolverine. Alternative C, alone or in concert with other ongoing or reasonably foreseeable future 

actions in or near the Assessment Area, is not expected to cause any cumulative effects on these 

species, their habitat, or prey. Combined with local community fuel reduction projects, which will not 

be removing habitat, Alternative C would both decrease the risk of high-intensity fire in and near the 

Assessment Area. No other actions would combine to create any significant effects. 

The cumulative effects on bald eagles under Alternative C are expected to be the same as under 

Alternative B. 

Northern Goshawk— 

 Direct and Indirect Effects. Without temporary roads 921 acres will remain untreated. Eight 

hundred twenty-two fewer acres treated with prescribed fire would thus leave habitat at risk of a 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.4 – Wildlife and Habitat 3-109

crown fire. Ninety-nine fewer acres would be treated within M Units, but these units are outside of 

any protected GOMAs. 

Habitat use by goshawks and NSOs in the Klamath region are similar under Alternative C. Thus 

the nesting / roosting and foraging habitat discussions for the NSO also apply to the goshawk, please 

refer to NSO effects under Alternative C. 

 Cumulative Effects. Refer to the cumulative effects discussion above for the NSO. 

Peregrine Falcon— 

 Direct and Indirect Effects. Peregrine falcon nesting/roosting habitat would not be directly 

or indirectly affected by the proposed fuels reduction activities under Alternative C. Peregrine falcons 

are known to be susceptible to disturbance near their nests, but a seasonal restriction of February 1 to 

July 31 would protect peregrines from all activities that create noise above ambient levels within 0.25 

to 0.5 mile (dependent on topographic features) of active eyries. 

Cumulative Effects. Cumulative effects are the same as found under Alternative B. 

Willow Flycatcher— 

 Direct and Indirect Effects. Effects are expected to be similar to Alternative B, but 

additional untreated habitat may slightly increase the potential for stand-replacing fire to initiate early 

successional habitats used by willow flycatchers. 

 Cumulative Effects. Effects are expected to be similar to Alternative B, but additional 

untreated habitat may slightly increase the potential for stand-replacing fire to initiate early 

successional habitats used by willow flycatchers. 

Pallid Bat and Townsend’s Big-eared Bat—

 Direct and Indirect Effects. Effects are expected to be the same as found under 

Alternative B. 

 Cumulative Effects. Refer to the cumulative effects discussion above for the NSO. 

American Pine Marten, Pacific Fisher, and California Wolverine—

 Direct and Indirect Effects. All proposed activities in the vicinity of suitable habitat under 

Alternative C could disrupt marten, fisher, and wolverine use and movement in the area and create 

short-term adverse direct effects on individuals just as was described under the Alternative B effects. 

Without temporary roads 921 acres will remain untreated. Eight hundred twenty-two fewer acres 

treated with prescribed fire within drainages and 99 fewer acres would remain untreated along 

ridgetops. These areas would thus leave dispersal, foraging, and denning / resting habitat at risk of a 

crown fire. 

 Cumulative Effects. Refer to the cumulative effects discussion above for the NSO. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-110 Chapter 3: Affected Environment and Environmental Consequences

Forest Service MIS Associations 

River and Stream MIS Association—

 Direct and Indirect Effects. Affects are expected to be the same as found under 

Alternative B. 

 Cumulative Effects—River and Stream MIS and Marsh, Lake, and Pond MIS 

Associations. Future actions in the Assessment Area are not expected to affect aquatic habitats; 

therefore, Alternative C would not increase cumulative effects on species in these associations. 

Marsh, Lake, and Pond MIS Association— 

 Direct and Indirect Effects. Affects are expected to be the same as found under 

Alternative B. 

 Cumulative Effects. Refer to the cumulative effects discussion above for the River and 

Stream MIS Association. 

Hardwood MIS Association —

 Direct and Indirect Effects. Affects are expected to be the same as found under 

Alternative B. 

Cumulative Effects—Hardwood MIS and Snag MIS Associations. Alternative C, alone or 

in concert with other ongoing or reasonably foreseeable future actions in the Assessment Area, is not 

expected to cause any cumulative effects on hardwood habitats. Combined with local community fuel 

reduction projects, Alternative C would decrease the risk of high-intensity fire both inside and near 

the Assessment Area. 

Refer to the cumulative effects discussion above for the NSO. 

Snag MIS Association—

Direct and Indirect Effects. Affects are expected to be the same as found under 

Alternative B. 

Cumulative Effects. Refer to the cumulative effects discussion above for the Hardwood MIS 

Association. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-111

3.5 Aquatic Resources ____________________________________ 

3.5.1 Introduction 

This section summarizes information contained in the July 2009 “Aquatic Resources Report for 

Water Quality and Fisheries” and the April 2009 “Biological Assessment / Biological Evaluation 

(BA/BE) for Threatened, Endangered, Proposed, and Sensitive Fish Species That May be Affected by 

the Eddy Gulch Late-Successional Reserve Fuels / Habitat Protection Project. This document also 

describes the effects on the environment that would result from taking no action (Alternative A) or 

from implementation of actions Alternative B or C. Refer to “Section 3.5.4.4 Summary of Effects on 

Special Status Species and Their Habitat.” 

Five facts are central to the analysis of the Proposed Action for the Eddy Gulch LSR Project. The 

first fact derives from natural elements—hot dry summers, steep slopes, and an abundance of forest 

growth—that create conditions that lead to frequent fires. The potential for increased fire intensity 

also presents risks related to soil erosion and accelerated sediment delivery to streams. The second 

fact is the Salmon River watershed (within which the project is located) is a designated Key 

Watershed (USFS 1995a), with its attendant management guidelines aimed at preserving aquatic and 

riparian habitats for anadromous salmonids and other riparian-dependent species. The third fact 

considered is the management emphasis in the Klamath Land and Resource Management Plan 

(LRMP) on promoting and protecting late-successional terrestrial habitats. Fourth, most of the North 

Fork Salmon River and South Fork Salmon River are congressionally designated under the Wild and 

Scenic Rivers Act, a legal status precluding dam construction and placing further emphasis on 

management for habitat and other noncommodity values. The fifth fact is that there are seven 

municipal watersheds within the analysis area for aquatic resources capable of supplying water to 

approximately 250 residents in the Salmon River subbasin. 

3.5.2 Methodology 

3.5.2.1 Analysis Methods and Assumptions 

The aquatic resources analysis for the Eddy Gulch LSR Project has five basic components: 

(1) a review of known information; (2) thorough examination of aerial imagery; and (3) field review 

of proposed treatment units, Riparian Reserves, current water uses, and areas of sensitivity; 

(4) application of the Klamath National Forest Cumulative Watershed Effects (CWE) model to assess 

aggregated effects of the Proposed Action and alternatives to the risk of sediment delivery to streams 

through surface erosion and landsliding and potential change in flow, and (5) use of the Water Erosion 

Prediction Project (WEPP) model to estimate the magnitude of post-wildfire surface erosion rates. 

Aerial Imagery. Aerial imagery was used to identify sensitive watershed areas such as active 

landslides, active surface erosion, and stream channels undergoing scour and enlargement. 

Information collected in this phase was used to focus the field review of areas outside of or adjacent 

to the proposed treatment units. 

The field review included the following elements: 

 Traverses of all proposed thinning units where ground-based yarding or fuel treatments are 

proposed. 
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3-112 Chapter 3: Affected Environment and Environmental Consequences

 Field review of the most actively unstable areas in or near proposed treatment units. 

 Collection of information on erosion or drainage problems on existing roads. 

 Stream survey of selected stream reaches to validate and supplement existing information 

on channel type, channel stability, pool frequency, sedimentation, and stream temperature. 

 Field review of Riparian Reserves with proposed treatments. 

Cumulative Watershed Effects Model. The CWE model tracks watershed disturbance and 

management activities to gauge the relative risk of impairing watershed functions (such as 

infiltration) that can then produce secondary off-site effects. The CWE model used by the Klamath 

National Forest has three components. 

1. The “Equivalent Roaded Acre” (ERA) component tracks acres of soil disturbance by 

converting all disturbances to the common currency of an ERA. 

2. The GEO component looks at the potential for the generation of sediment from 

management-induced landslides. 

3. The third component is based on the Universal Soil Loss Equation (USLE) and models 

project effects on surface rill and gully erosion. 

Water Erosion Protection Project. WEPP is a soil erosion prediction model developed by the 

National Soil Erosion Laboratory of the USDA Agricultural Research Service. It uses soil, 

topography, and climate data to predict soil erosion rates and probabilities of sediment delivery to 

streams. The Forest Service WEPP interface was used in this application. 

3.5.2.2 Scope of the Analysis 

Analysis Area. The Eddy Gulch LSR is within the Salmon River basin on the Klamath National 

Forest. The LSR is approximately 61,900 acres in size and lies primarily within tributary watersheds 

(7th-field hydrologic units) between the North Fork (5th-field hydrologic unit) and South Fork (5thfield hydrologic unit) Salmon River. A small portion of the LSR (6,771 acres) overlaps into the 

headwaters of Etna and Mill creeks (6th-field hydrologic units), tributary to the South Fork Scott 

River (5th-field hydrologic unit). 

With the exceptions noted below, the analysis area includes all areas within the 7th-field 

watersheds in which project activities are proposed, and areas downstream that could be affected by 

proposed activities. These watersheds are listed in Table 3-38. Because the proposed FRZs tend to 

drape across ridges as a matter of their design, a few of the 7th-field watersheds make the list but 

actually contain very small acreages of treatment. Three of the twenty 7th-field watersheds (KanakaOlsen, Robinson-Rattlesnake, and Upper Etna) have proposed treatments covering less than 20 acres. 

In each instance, the proposed treatments involve a low-impact combination of underburning and 

mastication. These three watersheds are included in the CWE analysis (Appendix D of the Aquatic 

Resources Report) but will not be discussed further in this document because fisheries biologists and 

hydrologists determined that these activities would have no effect on water quality, aquatic species, or 

their habitat. All twenty 7th-field watersheds are shown in Table 3-38. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-113

Table 3-38. Analysis area 7th-field watersheds, proposed treatment acres, and 

miles of fish-bearing streams. 

7th-Field Watershed 

Proposed 

Treatment Acres 

Miles of 

Fish-Bearing 

Streams 

Black Bear Creek 5,217 4.3 

Cody-Jennings 1,577 5.3 

Crawford Creek 6,600 4.2 

Eddy Gulch 1,022 2.7 

Gooey-Ketchum 86 4.8 

Gould-East Fork, South Fork Salmon River 974 0.5 

Indian Creek 82 1.0 

Lower North Russian Creek 1,006 4.7 

Lower South Russian Creek 461 2.2 

Matthews Creek 1,799 1.5 

Shadow Creek 5,064 1.9 

Sixmile Creek 441 2.5 

Tanner-Jessups 89 2.6 

Taylor Creek 683 0.0 

Timber-French 204 7.1 

Upper North Russian Creek 1,011 1.2 

Whites Gulch 574 1.6 

Kanaka-Olsen 18 3.6 

Robinson-Rattlesnake 2 4.6 

Upper Etna 0.02 1.1 

The 7th-field watersheds listed in Table 3-38 are within three 5th-field watersheds (North Fork 

Salmon River, South Fork Salmon River, and the South Fork Scott-French). The main streams within 

these 5th-field watersheds are part of the affected environment because water quality and aquatic 

habitat in the LSR is hydrologically linked to these downstream areas. The South Fork Scott-French 

watershed contains less than 1 acre of treatment area within the Upper Etna 7th-field watershed. For 

the same reasons cited earlier (minimal acreage proposed, resulting in no effect on water quality, 

aquatic species, and their habitat) for the Upper Etna watershed, the South Fork Scott-French 

5th-field watershed is not analyzed further in this document. 

In summary, in addition to the 7th-field watersheds listed in Table 3-38 above, the following 

5th-field watersheds are also within the analysis area because aquatic habitat in the LSR is 

hydrologically linked to downstream areas: 

 North Fork Salmon River 

 South Fork Salmon River 

 South Fork Scott-French 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-114 Chapter 3: Affected Environment and Environmental Consequences

Analysis Period. Relative to vegetation recovery and soil cover, short-term effects refer to 

0–5 years and long-term effects refer to longer than 5 years. Relative to sedimentation and streams, 

short-term effects refer to pulse effects that subside almost immediately and long-term effects refer to 

chronic effects. 

3.5.2.3 Intensity of Effects 

“Intensity” refers to the severity of effects or the degree to which the action may adversely or 

beneficially affect a resource. The intensity definitions used throughout the effects analysis are 

described below: 

No Effect. The appropriate conclusion when it has been determined the Proposed Action will not 

affect species or their habitat. 

Negligible or Discountable. The appropriate conclusion when effects on species or their habitat 

are expected to be discountable (extremely unlikely to occur) or insignificant. 

Minor. Chemical, physical, or biological changes to water quality and hydrology would be 

detectable in and/or immediately adjacent to treatment units but would be well below limits set by 

state and federal water quality standards or criteria and would be within historical or desired water 

quality and hydrologic conditions. 

Moderate. Chemical, physical, or biological changes to water quality and hydrology would be 

detectable downstream of treatment units but would not be detectable in 5th-field receiving streams. 

Any changes would be at or below limits set by state and federal water quality standards or criteria. 

Water quality and hydrology would be altered compared to historical baseline or desired water quality 

and hydrologic conditions. 

Major. Chemical, physical, or biological changes to water quality and hydrology would be readily 

measurable in 5th-field receiving stream and would be frequently altered from the historical baseline 

or desired water quality and hydrologic conditions. Chemical, physical, or biological water quality 

standards or criteria would be periodically exceeded. 

3.5.3 Affected Environment (Existing Conditions) 

3.5.3.1 Fisheries 

The following Pacific salmonid Evolutionarily Significant Units and their habitat occur in the 

area affected by the Proposed Action: 

 Endangered: None 

 Threatened: Southern Oregon Northern California Coasts (SONCC) coho 

salmon 

 Critical Habitat: SONCC coho salmon 

 Proposed: None 

 Sensitive: Upper Klamath-Trinity (UKT) Chinook salmon; Klamath 

Mountain Province (KMP) steelhead 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-115

 Essential Fish Habitat: SONCC coho salmon; UKT Chinook salmon 

 Management Indicator 

Species: Steelhead; resident rainbow trout 

Conclusions regarding anadromous fish and their habitat (including critical habitat) occurrence 

are based on field review of habitat suitability, professional judgment, District fish survey records, 

and California Department of Fish and Game (CDFG) information (refer to Maps A-13a and A-13b

for fish distribution in the Assessment Area). Field surveys, CDFG information and professional 

judgment of fisheries biologists were compiled into the Klamath National Forest steelhead trout 

distribution layer in their Geographic Information Systems (GIS) electronic library. The steelhead 

trout distribution over-estimates the extent of coho salmon, critical habitat, Chinook salmon, and 

Pacific salmon Essential Fish Habitat, except where site-specific field surveys refine Chinook salmon, 

coho salmon, and critical habitat distribution (such as the habitat is found to be inaccessible for coho 

salmon, Chinook salmon, or both). The Klamath National Forest considers the use of their Steelhead 

Trout Distribution Layer to define Chinook salmon habitat, and coho salmon critical habitat, as a 

conservative (inclusive) approach for assessment of effects on coho and Chinook habitat (including 

critical habitat) because coho and Chinook salmon may not occupy the same waters as steelhead due 

to the differences in jumping abilities. The maximum jumping height for coho is approximately 

2.2 meters (7 feet), Chinook salmon is 2.4 meters (8 feet), and steelhead is 3.4 meters (11 feet) 

(Meehan 1991). 

North Fork Salmon River. The North Fork Salmon River (5th-field watershed) is one of two 

major forks of the Salmon River and is part of the National Wild and Scenic River System. The North 

Fork Salmon River provides habitat for the Klamath River’s largest wild run of spring Chinook, as 

well as KMP summer-run steelhead. These wild Salmon River runs are unaffected by hatcheryproduced salmonids because there are no fish hatcheries in the Salmon River basin. The watershed is 

comprised of approximately 130,200 acres. Approximately 1 percent of the watershed is privately 

owned, and the remainder is federal land managed by the Klamath National Forest. The forest 

manages 43 percent as wilderness, and the remainder is managed for other resource values. 

The North Fork stream lacked down woody material, fine sediment was a problem, 

embeddedness was high, and there was a lack of pool habitat (USFS 1995c). The North Fork of the 

Salmon River met desired pool frequency in 2 out of 17 reaches surveyed and did not meet fine 

sediment in the lowest seven reaches, which are below Little North Fork. Water quality, including 

water temperature, is a concern in the Salmon River basin. Shade is lacking along the entire North 

Fork of the Salmon, with the exception of the upper-most reaches. Tributary temperatures were below 

lethal levels. The Little North Fork had the largest cooling effect on the North Fork of the Salmon 

River due to its significant flow contribution. The North Fork of the Salmon River exceeds maximum 

recommended temperatures (below 70oF) during the summer. High water temperatures have resulted 

in fish kills of spring-run Chinook salmon and summer steelhead during warm low-flow drought 

conditions of some summer seasons, such as in 1994. 

Approximately 29 percent of the watershed is designated as Riparian Reserves (refer to 

Maps A-12a and A-12b), which include unstable or potentially unstable lands and stream buffers. 

Current conditions and uses of Riparian Reserves are related to historic uses, which have included 
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3-116 Chapter 3: Affected Environment and Environmental Consequences

grazing, roads, stream crossings, and mining. An analysis of air photos from 1944 showed that, at the 

time, most stream channels were fully vegetated with a mixture of conifer and hardwood species. The 

1964 flood resulted in major changes to the stream channel in that the channel widened and long 

segments were scoured out. The entire length of the North Fork of the Salmon River was modified 

and stripped of riparian vegetation. In 1995 the Klamath National Forest estimated that the main stem 

North Fork of the Salmon River showed 20 percent initial recovery since the 1964 flood. This may be 

because, in general, larger streams recover more slowly than smaller streams (the Klamath National 

Forest also studied recovery of smaller streams) due to larger surface areas affected by scour and 

larger streamflows acting on this surface. Unstable areas and disturbed streams that have poorly 

defined primary channels may recover slowly due to frequent re-disturbance by subsequent high flow 

events. 

Significant portions of Riparian Reserves were burned in the past with moderate to high severity 

by the Hog, Yellow, and Specimen fires. Riparian vegetation recovery to a mature state within granitic 

terrains takes approximately 80 years (to re-establish large conifers). 

In addition to fires, landsliding is a significant watershed process of concern in the North Fork 

Salmon River. During the Twentieth Century, 75 percent of the landslide-derived sediment, which 

entered the stream, was associated with flood and storm events that occurred from 1964 to 1975. 

Roads produced landslides at a rate much higher than undisturbed lands. Harvested or burned areas 

produced landslides at a rate much lower than roads but higher than undisturbed lands. 

The CDFG estimated spawning populations in the Salmon River for a five-year period—

population estimates ranged from 1,000 to 4,000 (CDFG 1994 in USFS 1995c). The North Fork of 

the Salmon River “holding” summer steelhead population estimates for the period of 1980 through 

1994 were less than 75 individuals per year observed. The North Fork of the Salmon River “holding” 

spring-run Chinook salmon populations for the same time period ranged from 3 to 363 individuals. 

On average, 25 percent (of total observed from 1980 through 1994) of spring-run Chinook salmon 

and summer steelhead were in the main stem Salmon River and 20 percent in the North Fork of the 

Salmon River. These surveys also showed that 75 percent of adult spring-run Chinook salmon and 

summer steelhead holding in the North Fork of the Salmon River use the reach, which extends from 

the mouth of the North Fork of the Salmon River to the Little North Fork, and on average, 94 percent 

of the Chinook salmon spawning occurs in the same reach. 

South Fork Salmon River. The South Fork Salmon River (5th-field watershed) provides 

important habitat for native fish, including steelhead, spring and fall-run Chinook salmon, coho 

salmon, Pacific lamprey, sturgeon, dace, Klamath small-scale sucker, and sculpin. The South Fork 

Salmon River is important refugia for the last remaining wild-run spring Chinook salmon in the 

Klamath River basin and provides important holding and spawning habitat for summer steelhead. 

Watershed conditions have been impacted by fires, roads, and historic timber harvest practices 

associated with mining. Wildfire is probably the largest single disturbance affecting watershed 

conditions in the lower South Fork. Subwatersheds in the lower South Fork considered as Areas With 

Watershed Concern (AWWCs) include Indian Creek, and Black Bear Creek. The original road system 

was developed to provide access to gold mines and later was extended for timber harvest. Inner 

gorges are found along streams in all parts of this watershed and have naturally high debris slide 

rates. Debris sliding, surface erosion, and channel erosion all contribute sediment to streams. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-117

Flooding with debris torrents have occurred and have triggered debris slides and torrents. The 

Klamath National Forest rated large wood as sparse in most reaches. Summer water temperatures are 

a concern in the lower South Fork, which has low shade values due to the width of the stream and 

bedrock dominated terrain. The lower South Fork has had high turbidities attributed to landsliding in 

the wilderness headwaters of the upper South Fork watershed. 

The 7th-field watersheds in the Eddy Gulch LSR are described below in the context of existing 

conditions of the three habitat indicators selected for this analysis: sediment, temperature, and LWD. 

3.5.3.2 Sediment 

The Klamath National Forest rates many of the 7th-field watersheds in the Eddy Gulch LSR as 

being “at risk” for the sediment indicator, which means that the amount of fine sediment was higher 

than desired, and/or cobble embeddedness was 20 percent or greater, or watersheds had relatively 

high CWE ratings. Crawford Creek and Black Bear Creek were rated at “properly functioning” for 

sediment. The following watersheds were rated as “at risk” for watershed disturbance history (see 

checklists in the fish BA/BE for this project): Shadow Creek, Taylor Creek, Crawford Creek, 

Mathews Creek, Black Bear Creek, Upper North Russian Creek, Lower North Russian Creek, Lower 

South Russian Creek, Whites Gulch, and Eddy Gulch. 

Disturbances 

Landslides. Channel and valley morphology (steep, structurally controlled slopes within 

narrow valleys) in the Eddy Gulch LSR have the greatest influence on fish habitat, including channel 

gradients, wood storage, gravel availability/storage, and fine sediment distribution. Stream channels 

in the LSR are primarily moderate to high gradient, boulder dominated, step/pool beds with high 

energy and confined within steep inner gorges. Thus, these streams have low sedimentation potential 

(that is, sediment accumulation potential) due to gradients and generally confined channel conditions 

that result in high stream power and transport of sediment downstream. Fish habitat (such as pools 

and spawning substrate) is periodically and frequently reset due to sediment inputs from streamside 

landslides and debris flows. These are the dominant natural landscape processes relative to sediment 

that drive existing conditions of fish habitat in the LSR. 

Floods. Floods have been a dominant disturbance process that periodically affect fisheries 

habitat. The major floods that have occurred in the Salmon River basin corresponded with 

landsliding, which produced sediment to stream channels. The 1964 flood resulted in major channel 

widening, and the flood of 1997 resulted in loss of pool depths and riparian vegetation. 

The most vulnerable rock types from the standpoint of mass movement and surface soil erosion 

are highly weathered granodiorites (coarse-grained igneous rock) and the unconsolidated sedimentary 

deposits formed from them. Only South Russian Creek has significant areas in this rock type, and 

none of it lies within areas planned for project activities. Incredibly destructive debris torrents are the 

most common mass movement in this rock type. South Russian Creek experienced just such an event 

in the aftermath of severe thunderstorms in 1996. 

Riparian Reserves are components of the landscape that are critically important to protection of 

aquatic resources, either because of their proximity to streams or their special sensitivity to 

disturbance. Riparian Reserves may be thought of as falling into two subtypes: “wet” Riparian 
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3-118 Chapter 3: Affected Environment and Environmental Consequences

Reserves are streams and other water bodies and their adjacent riparian zones; generally, “dry” 

Riparian Reserves are areas of past or present slope instability. Both types of Riparian Reserves are 

protected through application of Standards and Guidelines described in the Klamath National Forest 

LRMP and are managed to meet ACS objectives. 

Roads. Road density is considered “properly functioning” in a watershed if there are less than 

2 miles per square mile (mi/mi2

) of roads, with no valley bottom roads. Road density in the Eddy 

Gulch LSR varies. For example, lower North and South Russian creeks, North Fork Salmon River, 

North Russian Creek, Gould-East Fork South Fork Salmon, South Fork Salmon River, Taylor Creek, 

Upper North and South Russian Creek watersheds all have road densities that are rated as “properly 

functioning.” Mathews Creek, Shadow Creek, and Whites Gulch are rated as “at risk” for road 

density, and Eddy Gulch is rated as “not properly functioning” for road density (road density is 

4.44 mi/mi2

). Eddy Gulch and Mathews Creek both have main roads that parallel the stream for a 

considerable distance. 

Table 3-39 presents a summary of road development in Riparian Reserves by 7th-field 

watersheds. Ten of the 17 listed watersheds have road densities above 2.0 mi/mi2

. Fifteen of the 

17 listed watersheds have road densities in Riparian Reserves above 2.0 mi/mi2

; some are much 

higher. This is generally the result of historically built roads that parallel streams. Road density is 

greater in Riparian Reserves than in watersheds, in some instances, due to the greater proportion of 

roads in the relatively smaller area of Riparian Reserves. 

Table 3-39. Summary of past road development by 7th-field watershed.

7th-field Watershed 

Road Density 

in Riparian Reserve 

(mi/mi2) 

Road Density 

in Watershed 

(mi/mi2) 

Black Bear Creek 1.9 2.7 

Cody-Jennings 2.8 1.4 

Crawford Creek 2.9 3.1 

Eddy Gulch 5.2 4.5 

Gooey-Ketchum 4.0 1.9 

Gould-East Fork South Fork Salmon 2.5 2.0 

Indian Creek 2.4 3.2 

Lower North Russian 4.3 1.7 

Lower South Russian 6.4 3.6 

Matthews Creek 3.5 2.7 

Shadow Creek 1.8 2.7 

Sixmile Creek 2.2 1.7 

Tanner-Jessups 4.6 3.2 

Taylor Creek 2.3 1.7 

Timber-French 3.1 1.6 

Upper North Russian 3.8 2.6 

Whites Gulch 3.3 2.2 

Changes in sediment regimes were assessed using the CWE predictive models or estimates of 

stored sediment in stream channels. Both are employed in this report to describe existing sediment 

delivery regimes. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-119

Cumulative Watershed Effects Model. The Klamath National Forest's CWE model has two 

components that address sediment delivery potential. The USLE component uses a long-established 

predictive algorithm to estimate changes in rates of rill and gully erosion and its delivery to streams. 

The GEO component predicts sediment delivery from potential landslide events based on disturbance 

history and site geology and geomorphology. The CWE model's current condition assessment is 

described below. The model output reports risk ratios. Risk ratios are the result of dividing the 

parameter of interest (sediment yields from the USLE component is an example) by the threshold of 

concern (TOC) established by assessing watershed sensitivity. It is a type of normalizing such that the 

critical value of the risk ratio is 1.0. Watersheds are judged to be well below TOC when risk ratios are 

well under 1.0. 

The CWE model, USLE component, identifies two 7th-field watersheds as being near or over 

threshold for sediment delivery from surface runoff: Eddy Gulch (risk ratio = 1.05) and Shadow 

Creek (risk ratio = 0.94). All other 7th-field watersheds have risk ratios between 0.24–0.56, indicating 

that these watersheds meet desired condition. The GEO component identifies four 7th-field 

watersheds with potential concerns over landslide-related sediment delivery: Upper North Russian 

(risk ratio = 0.87), Indian Creek (risk ratio = 0.87), Eddy Gulch (risk ratio = 0.79), and Kanaka-Olsen 

(risk ratio = 1.53). The “Aquatic Resources Report for Water Quality and Fisheries” contains a 

considerable amount of detail about the CWE analysis conducted for the project and tables showing 

results of the CWE modeling. 

The Salmon River CWPP identifies the following 7th-field drainages as municipal watersheds 

based on their existing or potential use as sources of domestic water supply; Black Bear, Eddy Gulch, 

Callahan Gulch, Crawford Creek, Shadow Creek, Counts Gulch, and Music Creek. No evidence was 

found to indicate that current levels of sediment storage or transport adversely affect these uses. 

Flood Return Intervals. The amount of impervious area increases within a watershed when a 

higher proportion of precipitation and snow melt takes rapid, overland flow paths rather than 

infiltrating into the soil. If this runoff does not encounter infiltration opportunities along its flow path, 

it rapidly reaches the main channel. Under the right circumstances, and with sufficient impervious 

area, the magnitude of short return-interval flood peaks can increase, leading to channel scour. 

Limiting impervious area is the primary mitigation for this impact. It is exactly this condition that is 

indexed by the ERA component of the Klamath National Forest's CWE model (refer to the “Aquatic 

Resources Report for Water Quality and Fisheries” for this project). 

3.5.3.3 Large Woody Debris 

Large wood is one of the primary watershed products the Eddy Gulch LSR supplies and 

replenishes to downstream aquatic/anadromous salmonid habitat. The predominant mechanism for 

large wood recruitment in the LSR is streamside landsliding with some mass wasting. Thus, the level 

of recruitment depends on the availability of large conifers on inner gorges. Wood transport 

downstream occurs via debris torrents and large flood events, such as the 1997 flood, which resulted 

in numerous landslides. The primary functions of large wood include pool formation, cover, nutrient 

input, and sediment storage and metering. 

Field survey results rated Eddy Gulch, Mathews Creek, Crawford Creek, Black Bear Creek, and 

Whites Gulch as “at risk” based on low amounts of large wood documented in the bankfull channel. 
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3-120 Chapter 3: Affected Environment and Environmental Consequences

An abundance of small to mid-size diameter wood pieces was observed during field reviews of these 

streams, generally reflecting the size of trees in Riparian Reserves. Large woody debris (LWD) levels 

have been reduced by past disturbances, including the 1964 flood, which scoured and transported 

large wood out of these stream systems; and past fires and timber harvest, which reset vegetation in 

Riparian Reserves. Lower North Russian, Lower South Russian, Music Creek, North Russian Creek, 

Shadow Creek, Sixmile/Gould, Taylor Creek, and Upper North and South Russian creeks are all rated 

as “properly functioning” for LWD, which indicates they have more than 80 pieces of large wood 

(defined as dbh larger than 24 inches and longer than 50 feet) per mile. 

As discussed above, the condition of Riparian Reserves is a primary influence on water quality 

and fisheries habitat and is discussed in this section. Many of the streams in the Eddy Gulch LSR 

have narrow, deeply incised channels with a minor component of obligate riparian vegetation. Debris 

torrents and channel scour associated with flood events are common occurrences and periodically 

reset streamside vegetation that is immediately adjacent to streams. Willow, big leaf maple, and alder 

colonize these disturbed areas and are critical for recovery of riparian function and for input of 

nutrients. Conifers, and in many stream reaches, steep incised topography, provide the primary stream 

shade in Riparian Reserves in the LSR. In addition, conifers provide the bulk of large wood and root 

stability to streamside areas in the LSR. However, the LSR also has a number of acres that are on 

south- and west-facing slopes with shallow soils and hot, dry conditions, which are not conducive to 

dense coniferous stands. 

During field surveys of 7th-field watersheds, riparian vegetation was observed to be a mosaic of 

mostly mid-successional, with some late-successional characteristics. Large trees were usually 

present but not predominant. Road incursions, salvage logging, fire, floods, and old landslides are the 

agents that have produced earlier successional patterns in riparian stands. 

Even though all riparian stands may not be at full potential relative to late-successional 

characteristics, stream shade is abundant. Where past disturbance has removed conifer canopy, 

riparian hardwoods (alder, big leaf maple, dogwood, and willow) have rapidly filled the gap. With the 

exception of road crossings, shade canopy was observed to be over 80 percent and often near or 

above 90 percent. 

At higher elevations, some of the hardwood component disappears in favor of brush species with 

lower water demand. As such, the component of shade provided by non-coniferous vegetation 

declines, as does overall shade. At elevations above about 4,500 feet on intermittent channels, shade 

values were observed to be more commonly in the 60–70 percent range. 

Except where permanent roads are located in or near riparian zones, ground cover was observed 

to be almost always at or near 100 percent in Riparian Reserves. As a result, the sediment filtering 

capacity of most Riparian Reserves is very good. The specific areas where road incursions have 

impacted the sediment filtering capacity of Riparian Reserves include South Russian Creek (road 

40N54), Whites Gulch (40N61), Black Bear Creek (1E001), and lower Crawford Creek (39N23). 

3.5.3.4 Stream Temperature 

There are 8,624 acres of Riparian Reserves in the Eddy Gulch LSR. Prior to the 1995 Klamath 

LRMP, timber harvest occurred in areas now designated as Riparian Reserves, and as a result, 
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Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-121

approximately 4 percent of Riparian Reserves are in plantation status and lack desired vegetation 

characteristics, including structural diversity, which provides adequate thermal regulation and 

supplies coarse wood to streams. 

All of the 7th-field watersheds in the LSR have stream temperatures that are considered “properly 

functioning.” Water temperatures are considered “properly functioning” in lower order streams when 

temperatures are 69oF or less. In addition to previous data collected by the Klamath National Forest 

for all 7th-field streams, some streams were sampled in 2008: main stem reaches of Whites Gulch and 

Shadow Creek measured 59oF in mid-August. Temperatures sampled in mid-July 2008 were as 

follows: Mathews Creek–62.5oF, South Music–61oF, Taylor Creek–55.5oF, and Russian Creek–

55.5oF. During field reviews of the Assessment Area in mid-August 2008, water temperatures were 

measured in numerous seeps and springs that flowed into Whites Gulch, South Music, and Sixmile 

Creek, and temperatures ranged from 46.5oF–57oF. These small, low-flow perennial cold seeps and 

springs are common in the analysis area and collectively feed 7th-field drainages downstream, and are 

crucial for maintaining cool temperatures in summer and fall months. Cool water temperatures in 

tributaries in the LSR highlight the importance of these streams relative to providing cool water 

inflows to warmer habitat downstream of the LSR that are used by anadromous salmonids, including 

within the North Fork and South Fork Salmon River. 

3.5.4 Environmental Consequences 

3.5.4.1 Alternative A: No Action 

Actions with Potential to Affect Sediment Indicator under Alternative A 

Road construction—No new roads would be constructed under Alternative A. 

Skid trails, landings, and cable corridors associated with thinning units—There are no 

thinning treatments associated with Alternative A. Fireline construction would be expected under the 

anticipated wildfire scenario. Exact locations and types of firelines would depend on location of fire 

and its behavior. 

Mastication of fuels—No mastication would occur under Alternative A. 

Prescribed underburning—No prescribed underburning would occur under Alternative A. 

Water drafting—Water drafting would be a likely activity related to wildfire suppression. Water 

drafting under conditions of a wildfire may not occur with the same level of resource protection as 

would be expected under normal project conditions. 

Wildfire and suppression actions—Loss of cover exposes soil to raindrop impact and 

subsequent erosion. This, in turn, can lead to loss of soil productivity and delayed recovery through 

vegetative regrowth. Where fire severity is high adjacent to streams, erosion can lead to sediment 

delivery to those streams. The direct effect, in this instance, would be to stream segments directly 

impacted by moderate to high-intensity fire. The magnitude of the direct effect is dependent on the 

total length of channel experiencing high-intensity fire. In general, the indirect effect of accelerated 

sediment delivery is of greater concern because sediment moves downstream to affect an everincreasing amount of aquatic habitat. 
Final Environmental Impact Statement 

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3-122 Chapter 3: Affected Environment and Environmental Consequences

The modeled wildfire under the no-action alternative is 7,200 acres in average extent. 

Eleven percent, or approximately 780 acres, is predicted to experience stand-replacing fire intensity. 

This would generally include 50–100 acres of Riparian Reserves. While much canopy would be 

retained, most soil cover in the form of litter and duff would be consumed. 

Impervious surface can be created through soil disturbance and compaction and from the creation 

of hydrophobic soils. Under the no-action wildfire scenario, increases in impervious surface can result 

from the use of heavy equipment in fire suppression (disturbance/compaction) and high-intensity fire 

(hydrophobic soils). When sufficient impervious surface has been created within a watershed, a 

higher proportion of storm and snowmelt runoff is manifest as surface runoff. A smaller proportion 

infiltrates into the soil, taking slower paths to stream channels. This can result in higher peak flows 

for each unit of precipitation or snowmelt. When these conditions persist, it represents a shortening of 

flood return intervals. A fundamental shift in the frequency of channel-shaping flood events can 

produce an increased potential for channel scour. Where impervious surfaces are created in nearstream areas, these effects can be disproportionately higher. 

The indicators related to sediment are comprised of the risk ratios produced by the Klamath 

National Forest’s CWE model as described above in Section 3.5.2.2 each of the three risk ratios 

assesses a particular type of watershed disturbance process. The ERA risk ratio looks at creation of 

impervious surface relative to a threshold based on watershed sensitivity. The USLE risk ratios look 

at sheet and rill erosion potential from soil disturbance. The GEO component indexes the potential for 

landslide-generated sediment. Each component assesses actions with the potential to generate 

sediment. As such, the desired condition for this indicator is for all risk ratios in all 7th-field 

watersheds to be below 1.0. 

The CWE model requires spatially specific disturbance information as input. This information 

was supplied by output of the fire behavior model FLAMMAP. Fire and Fuels specialists on the 

Interdisciplinary (ID) team ran the model with three separate ignition points, each point representing a 

likely point of human-caused ignition. Each ignition produced wildfires of similar size and intensity 

but in different locations. For purposes of the CWE analysis, fire model output for the Shadow Creek 

Campground ignition point was used. The rationale for this selection includes these points: 

 The Shadow Creek ignition produces the greatest concentration of burned acres within a 

single 7th-field watershed (Shadow Creek). 

 Shadow Creek has a relatively large amount of past disturbance (existing roads and 

regeneration harvest units) when compared to other 7th-field watersheds in the 

analysis area. 

 Shadow Creek is a municipal watershed. 

The no-action alternative with the modeled wildfire just described was analyzed using the CWE 

model. Table 3-40 displays risk ratios produced by the CWE model for this alternative. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-123

Table 3-40. CWE model results for the no-action alternative with modeled wildfire scenario. 

USLE Component ERA Component GEO Component 

7th-field Watershed Pre-fire Post-fire Pre-fire Post-fire Pre-fire Post-fire 

Sixmile Creek 0.516 0.545 0.122 0.142 0.364 0.388 

Gould-East Fork South Fork Salmon 0.347 1.383 0.164 0.645 0.454 0.838 

Shadow Creek 0.934 2.854 0.181 1.002 0.408 1.067 

Gooey-Ketchum 0.259 0.413 0.118 0.176 0.497 0.538 

Crawford Creek 0.457 0.458 0.216 0.216 0.287 0.287 

Whites Gulch 0.283 0.299 0.128 0.134 0.186 0.188 

Major increases in the risk ratios for Shadow Creek and Gould-East Fork Salmon are evident. 

Especially high is the 2.85 USLE risk ratio for Shadow Creek, highlighting the potential of the 

wildfire to increase sediment yield. These results should be interpreted with caution. They are not a 

statement of the expected outcome of a specific action but an example of a reasonably possible 

outcome. Only watersheds affected by the modeled wildfire are shown in the table. Under the 

no-action alternative, all other 7th-field watersheds have risk ratios that reflect current conditions 

only. 

Because the CWE model produced the dramatic increase in the USLE risk ratio, a second 

approach was employed to corroborate the CWE model’s suggestion of a high potential to increase 

erosion and sedimentation. The WEPP soil erosion and sediment delivery model was used to estimate 

sediment delivery rates from a prototypical slope profile under natural vegetation and modeled 

wildfire. Model results suggest an approximately 50-fold increase in per-acre sediment yield in the 

first year following fire, declining to pre-fire conditions in 5–10 years. Using local climate data, the 

model also predicts a 90–100 percent chance of sediment delivery in the first year following the fire. 

These effects would be predicted to occur on the 7,200 acres that burn under the modeled wildfire 

scenario. 

Taken together, the results of the WEPP and CWE analyses suggest that the potential severity of 

increased sedimentation from wildfire is high. The potential to adversely affect domestic use of water 

from municipal watersheds under such a wildfire scenario is reasonably likely. Such an increase in 

sediment yield has a reasonable likelihood of resulting in measurable increases in stored in-channel 

sediment, thus adversely affecting aquatic habitat. The magnitude of this potential effect is judged to 

be moderate to major (depending on the spatial pattern an actual fire would produce) with an 

expected duration of a decade or less. 

Actions with Potential to Affect Flood Regime Change Indicator under Alternative A 

Road construction—No new roads would be constructed under Alternative A. 

Skid trails, landings, and cable corridors associated with thinning units—There are no 

thinning treatments associated with Alternative A. Fireline construction would be expected under the 

anticipated wildfire scenario, but the exact locations and types of firelines would depend on location 

of fire and its behavior. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-124 Chapter 3: Affected Environment and Environmental Consequences

Mastication of fuels—No mastication would occur under Alternative A. 

Prescribed underburning—No prescribed underburning would occur under Alternative A. 

Water drafting—Water drafting would be a likely activity related to wildfire suppression. 

Water drafting does not affect the flood regime indicator. 

 Wildfire and its suppression—The measurement indicator that gauges the potential for 

altered flood regimes due to the creation of impervious surface is the ERA component of the CWE 

model. The desired condition is a risk ratio less than 1.0 in each 7th-field watershed in the analysis 

area. That would indicate that the total amount of impervious surface (ERA) from all past, current, 

and reasonably foreseeable activities is below the threshold of concern. The reader is again referred to 

Table 3-6 above for the results of the CWE model. The wildfire scenario causes an estimated increase 

in the ERA risk ratio for Shadow Creek that pushes up to the 1.0 inference point. This is not an actual 

effect but serves to point out that a fire of this magnitude and spatial pattern has the potential to create 

adverse hydrologic conditions. The best way to categorize the situation relative to flood regime 

change in Shadow Creek is “at risk.” A risk ratio substantially over 1.0 would be necessary to arrive 

at a higher estimation of the magnitude of the effect. The Klamath CWE model uses fairly 

conservative ERA threshold of concern values so some factor of safety is built into these risk ratio 

estimates. 

Actions with Potential to Affect Stream Temperature Indicator under Alternative A 

Road construction—No new roads would be constructed under Alternative A. 

 Skid trails, landings, and cable corridors associated with thinning units—There is no 

timber harvest associated with Alternative A. Fireline construction would be expected under the 

anticipated wildfire scenario. Exact locations and types of firelines would depend on location of fire 

and its behavior. 

 Mastication of fuels—No mastication would occur under Alternative A. 

 Prescribed underburning—No prescribed underburning would occur under Alternative A. 

Water drafting—Water drafting would be a likely activity related to wildfire suppression. 

Water drafting under conditions of a wildfire may not occur with the same level of resource protection 

as would be expected under normal project conditions and could therefore affect stream temperatures 

if flows were substantially reduced (due to implementation of NMFS’ Water Drafting Guidelines this 

will not occur). 

 Wildfire and its suppression—Stream temperature is likely to be adversely affected due to 

the 50–100 acres of Riparian Reserve predicted to be consumed by high-intensity wildfire. This effect 

is dependent on the actual extent and location of stand-replacing fire in Riparian Reserves. For 

example, many small burned-out patches dispersed across the landscape would have less impact on 

these indicators than a few large contiguous blocks in a single watershed. Wildfire modeling does not 

provide conclusive evidence that stream temperature would be significantly affected. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-125

Actions with Potential to Affect Large Woody Debris Recruitment Indicator under 

Alternative A 

Road construction—No new roads would be constructed under Alternative A. 

 Skid trails, landings, and cable corridors associated with thinning units—There is no 

timber harvest associated with Alternative A. Fireline construction would be expected under the 

anticipated wildfire scenario. Exact locations and types of firelines would depend on location of fire 

and its behavior. 

Mastication of fuels—No mastication would occur under Alternative A. 

Prescribed underburning—No prescribed underburning would occur under Alternative A. 

Water drafting—Water drafting would be a likely activity related to wildfire suppression. 

Water drafting does not affect the LWD indicator. 

Wildfire and its suppression—A wildfire could reduce long-term LWD recruitment at the 

7th-field scale if Riparian Reserves were burned. Modeled wildfires average 6–7 percent of Riparian 

Reserves consumed by high-intensity fire within the fire perimeter. This would add cumulatively to 

existing low levels of LWD in 7th-field streams and in habitat downstream that receives large wood 

from the analysis area. Low levels of large wood in the subject 7th-field streams are partly due to the 

physical attributes of streams, which facilitate wood transport rather than storage. However, a wildfire 

would add cumulatively to existing low levels of LWD in the analysis area and would decrease longterm recruitment to downstream alluvial reaches and pools, where wood plays a vital role in habitat 

complexity for spawning and rearing salmonid. 

Hazard tree removal—Hazard trees may be removed along roads and could affect LWD in 

Riparian Reserves. However, the Klamath National Forest Hazard Tree Guidelines (USFS 2005) will 

be implemented and trees felled within Riparian Reserves would be left on site. Therefore, LWD 

levels in Riparian Reserves will not be affected by hazard tree removal. 

Actions with Potential to Affect the Road Density Indicator under Alternative A 

Road construction—No new roads would be constructed under Alternative A. 

Skid trails, landings, and cable corridors associated with thinning units—There is no 

timber harvest associated with Alternative A. Fireline construction would be expected under the 

anticipated wildfire scenario. Exact locations and types of firelines would depend on location of fire 

and its behavior. 

Mastication of fuels—No mastication would occur under Alternative A. 

Prescribed underburning—No prescribed underburning would occur under Alternative A. 

Water drafting—Water drafting would be a likely activity related to wildfire suppression. 

Water drafting does not affect the Road Density indicator. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-126 Chapter 3: Affected Environment and Environmental Consequences

Wildfire and its suppression—These actions would not change road density under 

Alternative A. 

Conclusion: Summary of Potential Effects on Aquatic Resources under Alternative A 

CWE model risk ratios serve as the metric for sediment-related indicators. Table 3-41, which is 

presented under the discussion of Alternative B, contains risk ratios for the current condition plus 

foreseeable future actions, along with those for the action alternatives. The following discussion 

makes reference to these risk ratios. In the interest of avoiding redundancy, Table 3-41 is not repeated 

in this discussion of Alternative A. Table 3-40 (presented previously) contains risk ratios relevant only 

to the modeled wildfire scenario, and thus, is only pertinent to Alternative A. 

Direct and Indirect Impacts on Fisheries Habitat under Alternative A (Beneficial Use 

“COLD”) 

Based on the modeled wildfire and the modest amount of Riparian Reserves that would be 

burned, it is unlikely that a wildfire would directly kill fish. The habitat effects of a wildfire would 

likely constitute an indirect effect on fish since they would occur later in time. Although a surface fire 

would consume litter, small woody debris, shrubs, and some large trees, Riparian Reserves have 

higher fuel moistures, resulting in low potential for direct effects on fish; that is, there is low potential 

for a severe fire to burn over streams and directly kill fish. Indirect effects on fisheries are evaluated 

in the bulleted items that follow. 

 Failing to implement fuels reduction treatments would increase the risk of stand-replacing 

wildfire and the accompanying loss of protective soil cover, leading to accelerated erosion 

and sedimentation. High USLE and ERA risk ratios resulting from CWE analysis of the 

modeled wildfire indicate that potential adverse sediment effects on fish habitat would be 

high under the no-action Supporting this conclusion is the WEPP model output showing a 

50-fold increase in first year erosion rates with a virtual certainty that a portion of this 

accelerated erosion will reach streams. 

 The magnitude of this impact is judged to be moderate to major depending on the 

dispersion of high-intensity fire across 7th-field watersheds. The duration of adverse effects 

is likely to be on the order of 5 to 10 years. 

 Failing to implement fuels reduction treatments would increase the risk of stand-replacing 

wildfire and the accompanying increase of impervious ground surface, leading to an 

increase in overland surface runoff. Based on conditions predicted by the modeled wildfire 

scenarios, sediment effects related to altered runoff regime are likely to be negligible to 

minor. This is due to the modest amounts of Riparian Reserves consumed by high-intensity 

fire and the high probability that suppression-related disturbance would likely be 

concentrated along ridgetops and existing roads. Additionally, the loam-clay loam soils 

characteristic of the analysis area are not the kind of noncohesive soils most prone to 

developing hydrophobic conditions following fire. The duration of effects is likely to be 

short term as regrowth of vegetation and other processes break up impervious surfaces and 

areas of hydrophobic soils. The intensity of this effect is negligible to minor. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-127

 Failing to implement fuels reduction treatments would increase the risk of stand-replacing 

wildfire and the accompanying loss of riparian shade canopy, leading to stream 

temperature increases. Where stand-replacing fire intensity occurs in streamside zones, 

shade canopy is lost, exposing streams to increased amounts of solar radiation. To 

experience a measurable increase in temperature, relatively large contiguous segments of 

stream must experience significant reduction in shade canopy. Spatial patterns of highintensity fire produced by the wildfire model do not exhibit this pattern. The model 

suggests that 6–7 percent of Riparian Reserves would experience stand-replacing fire in a 

patchy, noncontiguous spatial pattern. Most 7th-field tributaries are narrow, steep, and 

north-south trending, all of which suggests lower vulnerability to temperature increases. 

 Adverse effects on stream temperature under the no-action alternative are expected to be 

negligible to minor and of short duration because the regrowth of riparian shrubs is usually 

quite rapid following the removal of overstory, and physical conditions as described above 

may attenuate loss of stream shade. No significant effects are expected due to this process. 

 Failing to implement fuels reduction treatments would increase the risk of stand-replacing 

wildfire and the accompanying loss of snags and large trees near streams. The no-action 

alternative may cause indirect effects on fish and their habitat because fuel loadings are 

high in the LSR, and groups of trees could be killed in Riparian Reserves if a large wildfire 

were to occur. If overstory vegetation were damaged or lost, future large wood recruitment 

would be reduced. Post-fire (short- to mid-term) recruitment may increase due to the 

amount of dead trees. However, future long-term large wood recruitment in Riparian 

Reserves would likely be impacted (decreased). 

Indirect adverse effects on LWD recruitment are judged to be minor due to the relatively 

small area of Riparian Reserves predicted to be impacted by high-intensity fire. 

Cumulative Effects on Fisheries Habitat under Alternative A (Beneficial Use “COLD”). The 

no-action alternative would not add project-related incremental effects to the effects of past, 

present/ongoing, or future projects because no management activities are proposed. However, were a 

wildfire to occur that is similar to the modeled wildfire, cumulative adverse effects on fish habitat are 

likely. Aquatic habitat is recovering from past disturbances, and fish populations are at low levels. 

Past surveys indicate that LWD is present in less than desired levels. Thus, a severe wildfire, in 

combination with past, present/ongoing, and future actions, could result in cumulative effects on fish 

associated with increases in sediment supply, localized increases in water temperature, and reduced 

long-term LWD recruitment. The magnitude of effects is expected to be minor to moderate (sediment 

impacts could be major within one or two 7th-field watersheds), depending on the spatial pattern of 

high-intensity fire. Temperature and sediment effects would be expected to recover within 5 to 

10 years, while effects on large wood recruitment would persist for multiple decades. 

Foreseeable future actions are listed in Section 3.1.4 above. Two of the listed actions (North Fork 

Roads Stormproofing Project and construction of a fuelbreak system west of Black Bear Ranch) were 

also included in the input to the CWE model and are reflected in the model output. In all 7th-field 

watersheds affected by future projects, the net effect of those projects is a small but consistent 

decrease in risk ratios. The road project represents a major long-term improvement to watershed 

condition in the affected drainages. The details of the fuel break project are not yet fully developed. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-128 Chapter 3: Affected Environment and Environmental Consequences

Assuming it involves only underburning and mastication along ridgetops with no road development, 

it is highly unlikely to have detectable adverse effects and will provide improved wildfire suppression 

and protection to the Black Bear and Callahan municipal watersheds. 

Municipal/Domestic Uses of Water under Alternative A (Beneficial Use “MUN”) 

Direct and Indirect Effects—Direct effects to municipal/domestic uses of water are 

unlikely. Damage to impoundments or delivery infrastructure or introduction of pollutants at points of 

diversion are the most likely processes fitting the definition of “direct effect.” Under the no-action 

alternative, inadvertent actions related to wildfire suppression would be the most likely mechanism 

producing direct adverse effects on municipal/domestic use. These are not foreseeable consequences 

and are dismissed from further analysis or discussion. Indirect effects on municipal/domestic use are 

evaluated in the bulleted items that follow. 

 Failing to implement fuels reduction treatments would increase the risk of stand-replacing 

wildfire and the accompanying loss of protective soil cover, leading to accelerated 

sedimentation and high turbidity during major runoff events. Accelerated erosion and 

sedimentation can result in sediment deposition that damages diversion structures or 

renders them inoperative. High turbidity in water indicates the presence of particulates that 

can serve as substrates (and nutrients) for harmful microorganisms. CWE and WEPP 

model results suggest that a likely wildfire could be expected to have significant adverse 

effects on existing or potential municipal/domestic use of water, especially when standreplacing fire intensity is concentrated within a 7th-field watershed. 

 The magnitude of this effect is judged to be moderate, mostly because of the uncertainty 

associated with the location and spatial distribution of wildfire effects. 

 Failing to implement fuels reduction treatments would increase the risk of stand-replacing 

wildfire and the accompanying increase in impervious surface, leading to alteration of 

channel-shaping flood regime. Channel and bank scour that could potentially result from 

this process can increase sediment loads and damage water diversion infrastructure in ways 

similar to those already discussed. 

 The magnitude of this effect is judged to be negligible. This determination is based on the 

moderate increase in the Shadow Creek ERA risk ratio (Table 3-40) under the modeled 

wildfire scenario and the observation that most 7th-field channels are well-armored and 

highly confined transport channels with low potential for rapid incision or lateral 

migration. 

Cumulative Effects on Municipal/Domestic Uses of Water under Alternative A (Beneficial 

Use “MUN”). No evidence was found to indicate that existing sediment or turbidity levels cause 

impairment to municipal / domestic uses of water. Because the CWE model input includes 

information from past and foreseeable future projects, its output offers the best quantitative 

assessment of potential cumulative effects to municipal / domestic use in the form of accelerated 

sedimentation. Listed municipal watersheds include Eddy Gulch, Black Bear Creek, Shadow Creek, 

Callahan Gulch, Counts Gulch, Crawford Creek, and Music Creek. Of these, Eddy Gulch and Shadow 

Creek are the only drainages with CWE risk ratios that could be described as “at risk.” The CWE 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-129

model values shown in Table 3-41 include the values for the current condition (2008), including past 

actions. The Kanaka-Olsen and Indian Creek watersheds are over the threshold of concern, but the 

risk ratios are decreasing and would fall below the threshold of concern by the time the project is 

fully implemented in 2014. The same risk ratio for Shadow Creek is 0.93. No other risk ratios for 

municipal watersheds are in the “at risk” or higher range. 

It is reasonable to conclude that the effects of wildfire in these two drainages would be 

superimposed on an existing level of disturbance that would make it easy to exceed thresholds of 

concern. Table 3-40 above supports this conclusion by showing a USLE risk ratio change from 0.93 

to 2.85 for Shadow Creek based solely on the effects of the modeled wildfire. Based on this, it is 

reasonable to conclude that the potential adverse effects of wildfire on municipal watersheds is so 

great that the existing condition of the affected watershed may not matter, being wholly overwhelmed 

by fire effects. 

3.5.4.2 Alternative B: Proposed Action 

The primary concerns related to Aquatic Resources center on (1) the effects of temporary road 

construction and its potential for sediment delivery to streams; (2) the potential adverse effects of all 

project activities on municipal/domestic use of water; (3) the potential effects of modifying vegetation 

in Riparian Reserves to the detriment of sediment regime, stream temperature, and LWD recruitment; 

and (4) the potential adverse effects on fish and water quality from water drafting. 

Both action alternatives propose thinning, fuels reduction treatments, and underburning, and both 

alternatives are similar in scope, scale, and location. The difference between the action alternatives is 

that Alternative C does not propose construction of 1.03 miles of new temporary roads, 822 fewer 

acres would be underburned, and handlines would be constructed around some burn units. Thinning 

in M Units would be reduced by 99 acres, from 931 acres in Alternative B to 832 acres in 

Alternative C. The magnitude of differences between the two action alternatives relative to potential 

effects on fish and their habitat are very small because mechanical units and proposed temporary 

roads are not within Riparian Reserves and are located on or near ridgetops. The differences between 

alternatives with regard to underburn acreage and handline construction would not result in any 

differences in effects on fish or their habitat. The proposed temporary roads would not cross any 

streams or other Riparian Reserves and are dispersed in a number of short segments across several 

watershed areas. The temporary roads would be closed, ripped, and re-contoured after use. 

Design features applicable to both action alternatives include BMPs, Wet Weather Operating 

Standards (WWOS) (USFS 2002), forestwide soil cover standards, as well as Klamath LRMP 

Standards and Guidelines. Application of these measures would minimize the effects of each action 

alternative on aquatic resources considered herein. 
3-130 Chapter 3: Affected Environment and Environmental Consequences Table 3-41. CWE model results for Alternative B combined with the North Fork Roads Stormproofing Project. USLE ERA 

Current 

(2008) 

Current Plus 

Future Action 

(2009) 

Current, Future, and 

Sequenced Proposed 

Action 

2014 

Current, Future, and 

Sequenced Proposed 

Action 

2021 

Current 

(2008) 

Current/ Plus 

Future Action 

(2009) 

Current, Future, and 

Sequenced Proposed 

Action 

2014 

Current, Future, and 

Sequenced Proposed 

Action 

2021 

Current 

(2008) 

Current Plus 

Future Action 

(2009) 

7th-field WatershedsBlack Bear Creek 0.39 0.39 0.50 0.39 0.32 0.32 0.32 0.18 0.44 0.44 Cody-Jennings Creek 0.41 0.41 0.41 0.41 0.24 0.24 0.20 0.16 0.49 0.49 Crawford Creek 0.46 0.46 0.47 0.46 0.22 0.22 0.29 0.20 0.29 0.29 Eddy Gulch 1.05 0.90 0.91 0.90 0.39 0.32 0.35 0.33 0.79 0.62 Gooey-Ketchum Creek 0.26 0.26 0.26 0.26 0.12 0.12 0.12 0.11 0.50 0.50 Gould-East Fork South Fork Salmon River 0.35 0.35 0.35 0.40 0.16 0.16 0.17 0.21 0.45 0.45 Indian Creek 0.53 0.53 0.53 0.53 1.04 1.04 0.59 0.24 0.87 0.87 Kanaka-Olsen Creek 0.19 0.15 0.15 0.15 0.30 0.27 0.17 0.10 1.53 1.43 Lower North Russian Creek 0.24 0.21 0.22 0.21 0.17 0.15 0.16 0.15 0.47 0.41 Lower South Russian Creek 0.40 0.30 0.31 0.30 0.54 0.42 0.40 0.31 0.55 0.36 Matthews Creek 0.42 0.42 0.43 0.42 0.15 0.15 0.16 0.15 0.47 0.47 Robinson-Rattlesnake Creek 0.24 0.21 0.21 0.21 0.17 0.16 0.13 0.13 0.34 0.32 Shadow Creek 0.94 0.93 0.96 0.97 0.18 0.18 0.29 0.25 0.41 0.41 Sixmile Creek 0.52 0.52 0.52 0.52 0.12 0.12 0.12 0.13 0.36 0.36 Tanner-Jessups Creek 0.47 0.34 0.34 0.34 0.51 0.46 0.37 0.32 0.61 0.41 Taylor Creek 0.26 0.23 0.23 0.23 0.16 0.14 0.14 0.13 0.20 0.15 Timber-French Creek 0.24 0.24 0.24 0.24 0.14 0.14 0.12 0.10 0.31 0.31 Upper North Russian Creek 0.35 0.27 0.30 0.27 0.32 0.26 0.37 0.23 0.87 0.60 Whites Gulch 0.53 0.28 0.29 0.28 0.21 0.13 0.14 0.12 0.35 0.19 
Section 3.5 – Aquatic Resources 3-131 Table 3-41. CWE model results for Alternative B combined with the North Fork Roads Stormproofing Project (continued)

USLE ERA 

Current 

(2008) 

Current Plus 

Future Action 

(2009) 

Current, Future, and 

Sequenced Proposed 

Action 

2014 

Current, Future, and 

Sequenced Proposed 

Action 

2021 

Current 

(2008) 

Current/ Plus 

Future Action 

(2009) 

Current, Future, and 

Sequenced Proposed 

Action 

2014 

Current, Future, and 

Sequenced Proposed 

Action 

2021 

Current 

(2008) 

Current Plus 

Future Action 

(2009) 

6th-field WatershedsCecilville-Crawford Creek 0.37 0.37 0.35 0.34 0.20 0.20 0.20 0.15 0.36 0.36 Main East Fork South Fork Salmon River– 0.38 0.38 0.38 0.39 0.13 0.13 0.16 0.15 0.29 0.29 North Russian Creek 0.28 0.24 0.25 0.24 0.21 0.18 0.21 0.16 0.46 0.35 Plummer-Black Bear Creek 0.23 0.23 0.26 0.24 0.25 0.25 0.21 0.13 0.41 0.41 South Russian Creek 0.21 0.15 0.16 0.15 0.20 0.16 0.14 0.10 0.27 0.16 Whites-Jackass 0.55 0.39 0.39 0.39 0.26 0.21 0.19 0.18 0.49 0.35 5th-field WatershedsNorth Fork Salmon River 0.19 0.15 0.13 0.13 0.23 0.20 0.16 0.11 0.55 0.48 South Fork Salmon River 0.29 0.29 0.28 0.28 0.26 0.26 0.23 0.17 0.38 0.38 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-132 Chapter 3: Affected Environment and Environmental Consequences

The following discussion of Alternative B includes multiple references to risk ratios produced by 

the Klamath National Forest’s CWE model. Table 3-41 lists results of CWE analysis for watersheds in 

the analysis area under Alternatives B. The risk ratios reported under the column heading “2009” 

represent existing conditions plus foreseeable actions as listed in Section 3.1.4 above. The values 

reported for 2014 represent conditions at a point in time when all mechanical treatments (thinning 

units and FRZs) will be complete. The values reported for 2021 represent the point in time when all 

treatments have been implemented. A supplemental analysis of the effects of the 2008 and 2009 

wildfires in the Salmon River subbasin was done by Klamath National Forest hydrologist Gregg 

Bousfield (Eddy Gulch CWE addendum, September 23, 2009), and the conclusion was that the fires 

did not occur in any 7th-field watersheds in the affected environment and that no CWE values were 

pushed over threshold. Therefore, there is no significant change in the Proposed Action’s direct, 

indirect, or cumulative effects on water quality and aquatic resources as analyzed in the draft EIS: 

The wildfires did not cause any of the 7th- or 5th-field watersheds to significantly change model 

values, nor did these wildfires push model values over thresholds when combined with the Proposed 

Action. 

Actions with Potential to Affect Sediment Indicators under Alternative B 

Road construction. Seven segments (totaling 1.03 miles) would be constructed as new 

temporary roads. The longest new temporary road segment is 1,577 feet in length, and all temporary 

roads are on ridgetops or near-ridgetop locations. None are near Riparian Reserves, none require any 

stream crossing structures, none traverse unstable slopes, and none are proposed on granitic or 

similarly noncohesive soils. All of the temporary roads would be closed using normal erosion control 

measures (ripped and mulched, as needed). 

Four segments (totaling 0.98 mile) of former logging access routes currently closed to vehicle 

use, would be re-opened under Alternative B. The longest of these is a 2,154-foot segment of old 

fireline for accessing M Units 8 and 43. The former logging access routes are on ridgetops or nearridgetop locations and no cross streams or other Riparian Reserves. These routes would be waterbarred and closed immediately after thinning is completed. 

The temporary roads and former logging access routes are associated with thinning units (the 

M Units), and would be used primarily to provide yarder access to steeper ground that can only be 

thinned by cable yarding. These roads/routes, taken together, are distributed across three 7th-field 

watersheds as follows: Black Bear (0.25 mile), Crawford Creek (0.43 mile), and Shadow Creek 

(1.05 miles). 

Construction of new temporary roads has the potential to increase sediment delivery to streams. A 

substantial body of literature suggests that roads can be significant producers of sediment and can 

alter hydrologic patterns on a hillslope (Trombulak and Frissell 2000). Road segments that present the 

greatest risk for sediment delivery have a number of common traits, including (1) alignments parallel 

to stream, (2) numerous stream crossings, (3) alignments that traverse unstable slopes, (4) constructed 

in noncohesive soils, and (5) steep side slopes creating large cut and fill slopes. None of the 

temporary roads proposed under Alternative B exhibit these characteristics. 

The disturbance associated with temporary roads was incorporated into the input for the CWE 

model and is reflected in the resulting risk ratios that serve as the metrics for the sediment indicator. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-133

Model results do not segregate road impacts from other disturbances. However, when taken together, 

all project-related disturbances associated with Alternative B fail to result in any 7th-field watershed 

producing risk ratios over threshold. This is best assessed by comparing “2009” risk ratios with those 

for “2014” when all roads would have been constructed, and the thinning units they access would 

have been harvested. Increases are, without exception, minimal—measurable mostly at the second 

decimal. Some risk ratios actually decline due to the North Fork Roads Stormproofing Project and 

natural recovery over time. 

Skid trails, landings, and cable corridors associated with thinning units—Approximately 

73 existing landings (wide spots in roads or forest openings) would be used to support treatments in 

M Units. All of these are associated with tractor units. Cable yarding would use the road prism for 

"hot decking" of logs such that no additional landings are proposed for cable units. (Basically, hot 

decking occurs when the running surface of the road is not wide enough for both the cable yarder and 

the logs. The logs have to be moved out of the way so another load can be brought to the road, where 

trucks haul them away—this eliminates the need for landing construction because the road prism 

itself serves as the landing.) Total clearing for landings over the entire Assessment Area is estimated 

to cover 18 acres (the landings are shown on Maps A-6a and A-6b in this final environmental impact 

statement [EIS] report). None of the landings are in Riparian Reserves or other sensitive lands. All 

landings will receive post-project erosion control as described in the Klamath LRMP. 

Cable corridors would be located approximately 150 feet apart and oriented parallel to each other 

when possible. Several exceptions to the parallel alignment of corridors exist. Logs will have one-end 

suspension with the other end dragging on the slope. Heavy yarding volume in any one corridor can 

cause excessive soil disturbance. This is not expected to occur because harvest volumes per acre are 

generally light and because slash on the ground helps cushion and protect the soil from excessive 

disturbance. Resource protection measures (included in Alternative B) require erosion control 

measures in cable corridors where soil disturbance exceeds ground-cover retention guidelines. 

Mastication of fuels—Mastication of understory fuels is proposed in Fuel Reduction Zones 

(FRZs) where slopes are less than 45 percent. This usually involves the ridgeline itself and a short 

distance downslope on either side. Masticators are small, low ground pressure, tracked machines that 

minimize soil disturbance and compaction compared to much larger equipment such as log skidders. 

Mastication produces abundant ground cover in the form of small fragments of woody vegetation 

processed by the equipment. Effects on soil erosion and sedimentation processes from mastication 

would be minimal and are significantly outweighed by the benefits of breaking up fuel continuity and 

creating ample ground cover in the process. 

 Prescribed underburning—Prescribed fire is proposed on several thousand acres in the 

LSR. The prescribed burns will target consumption of understory fuels while retaining adequate soil 

and canopy cover. Due to the uneven distribution of fuels and fuel moistures, exact adherence to 

cover guidelines cannot be guaranteed on every acre subject to treatment. Limited but unforeseen 

flare-ups in fuel accumulations are likely to occur in some areas. The greatest potential for sediment 

generation would be related to flare-ups within Riparian Reserves. Adverse effects would be 

associated with the generation and subsequent movement of sediment in the critically important nearstream zone. Within this zone, adequate soil cover helps maintain an effective filter to buffer streams 

from sediment generated from upper slope positions. Loss of cover reduces the filtering function and 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-134 Chapter 3: Affected Environment and Environmental Consequences

can expose soil to erosive forces. Sediment generated within the near-stream zone has a much higher 

chance of reaching the stream due to the shorter flow path. Such events are expected to be few in 

number and limited in size by the fact that burn plans will consider retention of cover in these areas in 

conformance with Klamath LRMP guidance (Aquatic Conservation Strategy [ACS], Riparian Reserve 

Standards and Guidelines, Best Management Practice (BMPs), and related RPMs). 

Underburning will be consistent with guidelines in the Biological Assessment and Evaluation for

Pre-Commercial Thin and Release Actions and Fuel Reduction Actions on the Klamath National 

Forest (USFS 2001), which limits burn prescriptions and design within Riparian Reserves, and 

establishes a cap on the amount of acreage that can be burned in a given year to prevent adverse 

effects to aquatic habitat and fish. 

Water drafting—The only action that would occur in stream channels that would have the 

potential for direct effects on fish or their habitat is water drafting. Nineteen proposed water drafting 

sites have been identified. Nine sites are within (the following) fish-bearing streams: Lower North 

Russian Creek (3), Upper North Russian Creek, Robinson-Rattlesnake, Crawford Creek, Shadow 

Creek, Whites Gulch, and Cody-Jennings. Drafting sites have existing access but may be rocked to 

reduce surface erosion of dirt roads. Water drafting will be done according to the NMFS Water 

Drafting Specifications (NMFS 2001), which limits the amount and rate at which water can be 

withdrawn during pumping and requires pumps to be screened. By following these specifications and 

considering the instincts of fish to flee when a water truck approaches, potential effects of water 

drafting in fish-bearing reaches would be negligible. 

 Wildfire and suppression actions—The risk of stand-replacing wildfire and its associated 

increase in erosion and sedimentation would be reduced by project activities. Thinning and FRZ 

treatments on ridgetops, along with roadside fuel reductions, provide more and better options for 

wildfire control tactics. 

Actions with Potential to Affect Flood Regime Change Indicator under Alternative B 

 Road construction—Roads contribute to the total amount of impervious ground surface. Too 

many miles of road, especially roads located in near-stream areas, can result in large increases in 

surface runoff which can lead to larger volumes of stormflow reaching stream channels in a shorter 

period of time. Where roads are more distant from channels, surface runoff generated from the road 

prism has much more opportunity to infiltrate at points along its flow path. 

The ERA risk ratios in Table 3-41 above show no increases of concern. This includes the effect of 

proposed temporary roads as well as all other project activities. 

 Skid trails, landings, and cable corridors associated with thinning units—Under 

Alternative B, the use of existing landings and skid trails will be maximized. This renews disturbance 

on those sites but minimizes the creation of new impervious surfaces elsewhere. All skid trails and 

landings will receive full erosion control implementation upon project completion. 

Cable corridors do not produce important amounts of impervious surface and thus present no risk 

relative to flood regime change. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-135

Skid trails and landings are included in the CWE model input and reflected in its output. As 

previously stated, nothing in Alternative B would result in a significant increase in any risk ratio in 

any watershed. 

Mastication of fuels—No impervious surfaces will be created as a result of mastication. This 

is because the masticator is a small, low-ground-pressure machine, and the process of mastication 

increases ground cover and reduces the formation of erosion pavements. 

Prescribed underburning—No impervious surfaces will be created as a result of prescribed 

underburning. Some handline construction may occur but is unlikely to produce any measurable 

adverse effects. 

Water drafting—Water drafting does not create new impervious surface and does not 

contribute to flood regime change. Existing access roads will be used. 

Wildfire and its suppression—The reduced risk of wildfire would lower the potential to 

create impervious surfaces as a result of wildfire and suppression activities. The RS treatments along 

emergency access routes would provide greater opportunity for carrying out control strategies from 

existing roads, and fuelbreaks (the FRZs) would result in less need for fireline construction. 

Actions with Potential to Affect Stream Temperature Indicator under Alternative B 

Road construction—No roads are proposed in any Riparian Reserve. Proposed road 

construction or reconstruction would not affect stream temperature because no riparian or near-stream 

vegetation will be affected. 

Skid trails, landings, and cable corridors associated with thinning units—No skid trails 

or landings are proposed in Riparian Reserves. No near-stream vegetation will be affected by skid 

trails or landings. Because of this, no impact on stream temperature would result from the use of skid 

trails and landings. 

Some thinning units (M Units 15, 19, 21, 24, 40, 51, 61, and 76) have small portions of Riparian 

Reserves within or near their boundaries. In each instance, streamside management zones have been 

prescribed to ensure that canopy and ground cover guidelines are met. The small amount of area 

involved, along with Streamside Management Zone (SMZ) protections, ensures that no stream 

temperature impacts would result. 

Mastication of fuels—No mastication is anticipated in Riparian Reserves. In the rare event 

that mastication does occur in a Riparian Reserve, operation will be limited in order to meet ground 

cover and canopy cover retention guidelines. Effects on near-stream vegetation will be non-existent to 

extremely limited. 

Prescribed underburning—The greatest potential for adverse stream temperature effects 

would be related to flare-ups within Riparian Reserves. Flare-ups could remove canopy and create 

openings adjacent to streams. The magnitude of this potential effect is dependent on fuel continuity 

and fuel moisture within Riparian Reserves at the time of ignition. Burn prescriptions can and will 

exert control over this by specifying burn patterns, points of ignition, fuel moistures, and other factors 

that will limit it. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-136 Chapter 3: Affected Environment and Environmental Consequences

Such events are expected to be few in number and limited in size by the fact that burn plans will 

consider retention of cover in these areas in conformance with Klamath LRMP guidance (ACS, 

Riparian Reserve Standards and Guidelines, BMPs, and related RPMs). The magnitude of this effect 

is expected to be very similar between Alternatives B and C because only 99 acres less cable thinning 

and 822 acres less underburning would occur under Alternative C. 

Underburning will be implemented consistent with guidelines in the Biological Assessment and 

Evaluation for Pre-Commercial Thin and Release Actions and Fuel Reduction Actions on the Klamath 

National Forest (USFS 2001) which limits burn prescriptions and design within Riparian Reserves, 

and establishes a cap on the amount of acreage that can be burned in a given year, to prevent adverse 

effects on aquatic habitat and fish. 

Water drafting—Water drafting is unlikely to affect stream temperature because it does not 

result in modification of near-stream vegetation and NMFS (2001b) water drafting guidelines will be 

implemented to protect instream flows. 

Wildfire and its suppression—The reduced risk of wildfire would lower the potential for 

stand-replacing fire in Riparian Reserves. 

Actions with Potential to Affect Large Woody Debris Recruitment Indicator under 

Alternative B 

 Road construction—No roads are proposed in any Riparian Reserve. Proposed road 

construction or reconstruction is unlikely to affect LWD recruitment because no riparian or nearstream vegetation will be affected. 

 Skid trails, landings, and cable corridors associated with thinning units—No skid trails 

or landings are located in Riparian Reserves, and no near-stream vegetation would be affected by skid 

trails or landings; because of this, there would be no adverse effects on LWD recruitment. 

Some thinning units (M Units 15, 19, 21, 24, 40, 51, 61, and 76) have small portions of Riparian 

Reserves within or near their boundaries. In each instance, streamside management zones or Riparian 

Reserves have been prescribed to ensure that canopy and ground cover guidelines are met. There 

would be no effect on LWD or future LWD recruitment due to the small amount of acreage of 

Riparian Reserves near or within units, the fact that M Unit treatments will be outside of Riparian 

Reserves, the fact that Riparian Reserves are not on perennial streams, and because RPMs would be 

employed. 

 Mastication of fuels—No mastication is anticipated within Riparian Reserves. In the rare 

event that mastication does occur in a Riparian Reserve, operations will be limited to meet ground 

cover and canopy cover retention guidelines. Effects on near-stream vegetation will be non-existent to 

extremely limited. 

 Prescribed underburning—The greatest potential for adverse effects on LWD recruitment 

would be related to flare-ups within Riparian Reserves. Flare-ups could remove canopy and create 

pockets of standing dead trees adjacent to streams. Initially, there would likely be an increase in LWD 

as fire-killed trees decay and fall. This would be followed by a long period of no recruitment from 

these areas. The magnitude of this potential effect is dependent on fuel continuity and fuel moisture 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-137

within Riparian Reserves at the time of ignition. Burn prescriptions can exert control over this by 

specifying burn patterns, points of ignition, fuel moistures, and other factors that will limit the level of 

effects. Such events are expected to be few in number and limited in size by the fact that burn plans 

will consider retention of cover in these areas in conformance with Klamath LRMP guidance (ACS, 

Riparian Reserve Standards and Guidelines, BMPs, and related RPMs). 

Underburning will be implemented consistent with guidelines in the Biological Assessment and 

Evaluation for Pre-Commercial Thin and Release Actions and Fuel Reduction Actions on the Klamath 

National Forest (USFS 2001), which limits burn prescriptions and design within Riparian Reserves, 

and establishes a cap on the amount of acreage that can be burned in a given year to prevent adverse 

effects to aquatic habitat and fish. 

Water drafting—Water drafting will have no effect on LWD or LWD recruitment because 

there would be no modification of near-stream vegetation, and only existing access roads will be 

used. 

Wildfire and its suppression—The reduced risk of wildfire would lower the potential for 

stand-replacing fire in Riparian Reserves and loss of LWD. 

Hazard tree removal—Hazard trees may be removed along roads and could affect LWD in 

Riparian Reserves. However, the Klamath National Forest Hazard Tree Guidelines (USFS 2005) will 

be implemented, and trees felled within Riparian Reserves would be left on site; therefore, LWD 

levels in Riparian Reserves would not be affected by hazard tree removal. 

Actions with Potential to Affect the Road Density Indicator under Alternative B 

Road construction—Alternative B proposes 1.03 miles of new temporary road construction 

and 0.98 mile of re-opening former logging access routes. All 2.01 miles of temporary roads/routes 

occur in three 7th-field watersheds: Black Bear (0.25 mile), Crawford Creek (0.43 mile), and Shadow 

Creek (1.05 miles). These are the only drainages in which road density would be affected. Shown 

below are the changes in road density that would result from implementation of Alternative B. 

Pre-project 

(mi/mi2) 

Post-project 

(mi/mi2) 

Black Bear Creek 2.67 2.69 

Crawford Creek 3.09 3.12 

Shadow Creek 2.73 2.85 

Although all reported road densities in these drainages exceed the desired threshold of 2.0 mi/mi2

, 

the magnitude of the increase is very small. Closing these roads immediately after use will hasten 

vegetative regrowth such that these increases to the threshold will be recovered to pre-project levels 

within a decade. There will be no changes to road density in Riparian Reserves because no 

construction of temporary roads or re-opening of former logging access routes would occur in those 

areas. 

Skid trails, landings, and cable corridors associated with thinning units—These actions 

would have no effect on road density. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-138 Chapter 3: Affected Environment and Environmental Consequences

Mastication of fuels—This action would not affect road density. 

Prescribed underburning—This action would not affect road density. 

Water drafting—This action would not affect road density because only existing access 

roads will be used. 

Wildfire and its suppression—These actions would not affect road density. 

Direct and Indirect Impacts on Fisheries Habitat under Alternative B 

(Beneficial Use “COLD”) 

 Water drafting from streams has the potential to adversely affect fish by temporarily 

dewatering channels and entraining young fish into pump intakes—Existing water drafting sites 

will be used. The incorporation of NMFS (2001b) Water Drafting Specifications as RPMs will 

prevent these potential impacts. Erosion control and drainage will prevent sedimentation and turbidity 

increases. 

 Construction of new temporary roads and re-opening of former logging access routes 

have the potential to increase sedimentation in streams and degrade fish habitat—The proposed 

1.03 miles of temporary road construction and re-opening of 0.98 mile of former logging access 

routes are minor in extent, totaling only 2.01 miles for the entire project. Their locations are well 

away from streams or unstable slopes. The extent of proposed road construction produced a minute 

increase in CWE risk ratios and road density values. Closure following thinning will hasten recovery 

of road sites through erosion control and vegetative regrowth. The adverse effects of road 

construction would be negligible to minor, and the duration of the negligible or minor effects would 

not exceed one decade. 

 Mechanical treatments, mastication, and use of skid trails and landings could 

potentially increase the amount of soil disturbance, erosion, and sediment delivery to streams—

Most mechanical units are on ridgetops or upper slope locations, with minimal overlap with seasonal 

(nonperennial) stream Riparian Reserves. Where those overlaps occur, SMZs and other RPMs 

(including quantitative ground cover requirements) are in place to ensure that near-stream areas do 

not become sediment sources and that their sediment filtering capacity is maintained. Tractor yarding 

is limited to slopes below 35 percent. All mechanical units have been designed with RPMs that 

conform to Klamath LRMP guidance in meeting the ACS and Riparian Reserve Standards and 

Guidelines, thus ensuring retention and, where needed, rapid re-establishment of soil cover. 

CWE risk ratios (sediment indicators) indicate that mechanical treatments will not result in any 

“properly functioning” watershed degrading in status to “at risk” or worse. Potential adverse effects 

from these treatments would be negligible to minor, with full recovery to pre-project conditions 

within a decade. 

 The prescribed underburning could potentially result in localized loss of soil and canopy 

cover, which would be of special concern in Riparian Reserves—Potential effects are increased 

sediment delivery to streams, increased stream temperature, and altered rates and patterns of LWD 

recruitment. All such effects would be detrimental to fish habitat. Such events are expected to be few 

in number and limited in size by the fact that burn plans will incorporate retention of cover in 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-139

conformance with Klamath LRMP guidance (ACS, Riparian Reserve Standards and Guidelines, 

BMPs, and related resource protection measures). This potential effect is expected to be negligible. 

Should such effects occur, they would be short term because regrowth and adjacent unburned stands 

would contribute to the rapid re-establishment of soil cover. The magnitude of this effect is virtually 

identical between Alternatives B and C because the locations and amounts of underburn treatments 

are nearly identical. 

Underburning will be implemented consistent with guidelines in the Biological Assessment and 

Evaluation for Pre-Commercial Thin and Release Actions and Fuel Reduction Actions on the Klamath 

National Forest (USFS 2001), which limits burn prescriptions and design within Riparian Reserves, 

and establishes a cap on the amount of acreage that can be burned in a given year, to prevent adverse 

effects on aquatic habitat and fish. 

Cumulative Effects on Fisheries Habitat under Alternative B (Beneficial Use “COLD”) 

Cumulative effects on fish are those effects of the project combined with other effects in the 

subject watersheds, including past natural disturbances and anthropogenic-induced effects and effects 

from reasonably foreseeable future actions (the foreseeable future actions are listed in Section 3.1.4

above. These projects are expected to have either no effect (fiber optic project) or to result in net 

improvement (North Fork Roads Stormproofing Project and fuelbreak system west of Black Bear 

Ranch) to watershed conditions and aquatic resources. Private land activities in proximity to the LSR 

include mining, domestic use, and fuel reduction activities. The other activities (private land 

activities, recreation, mining, and watershed restoration) do not typically occur on the same land at 

the same time as the proposed actions. The physical and temporal separation between activities, low 

probability of sediment moving off site and into streams from proposed treatments, and the protective 

measures that will be implemented all serve to minimize the risk of adverse cumulative effects on 

water quality, anadromous fish, and their habitat. Cumulative effects, including the proposed 

treatments, are considered to be minor. 

Cumulative effects are also discussed in the fish BA/BE for the Eddy Gulch LSR Project (this 

document is contained in the Eddy Gulch LSR Project Record). There are approximately 178 miles of 

streams in the Eddy Gulch LSR that provide habitat for steelhead and resident trout, and 7.8 miles of 

streams on private lands that provide habitat for steelhead and resident trout. The Eddy Gulch LSR 

includes 60,331 acres of Klamath National Forest lands and 2,323 acres of private lands. The 

reasonably foreseeable future actions on these private lands have the potential to increase 

sedimentation into these streams, possibly impacting habitat for these species. However, activities 

would occur under the State Forest Practice Rules, which include measures to protect riparian and 

stream habitat. Thus, effects on salmonids and their habitat would be less than significant. 

The actions proposed in Alternative B are consistent with guidelines in the Biological Assessment 

and Evaluation for Pre-Commercial Thin and Release Actions and Fuel Reduction Actions on the 

Klamath National Forest (USFS 2001), and they also comply with Standards and Guidelines in the 

Klamath LRMP (USFS 1995). These guidelines include measures to protect aquatic habitat and place 

a cap on the amount of underburning that occurs in a given year within a given watershed. The 

proposed treatments are not expected to cause adverse effects on anadromous fish, resident fish, or 

their habitat. This is based on previous consultation with NMFS, on the ground monitoring of the 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-140 Chapter 3: Affected Environment and Environmental Consequences

types of actions proposed, and field reviews of proposed treatment units (refer to the BA/BE prepared 

for the proposed action). 

There would be no risk to viability for the anadromous fish described in this document because 

the needs of species influenced by federal land management activities will continue to be met through 

compliance with Klamath LRMP Standards and Guidelines. Additionally, it is expected that 

compliance the Standards and Guidelines will provide an amount and distribution of habitat adequate 

to support the continued persistence of vertebrate and nonvertebrate species in the analysis area. 

Direct and Indirect Effects on Municipal/Domestic Uses of Water 

under Alternative B (Beneficial Use “MUN”) 

Direct effects on municipal/domestic uses of water are unlikely. The processes that most likely fit 

the definition of “direct effects” include damage to impoundments or delivery infrastructure or 

introduction of pollutants at points of diversion. Under Alternative B, no activities are proposed near 

known points of diversion or use that could produce such direct effects. Indirect effects would most 

likely be associated with accelerated sediment delivery to streams. Accelerated erosion and 

sedimentation can result in sediment deposition that damages diversion structures or renders them 

inoperative. High turbidity in water indicates the presence of particulates that can serve as substrates 

(and nutrients) for harmful microorganisms. Indirect effects on municipal/domestic use are evaluated 

in the bulleted items that follow. 

 Construction of new temporary roads and re-opening of former logging access routes have 

the potential to increase sedimentation in streams, resulting in damage to water delivery 

systems or rendering water unfit for consumption. As previously discussed, the minor 

extent of road construction and their location away from streams and unstable slopes makes 

this effect highly unlikely. Points of diversion are typically located near residences in the 

lower portion of watersheds, which creates the maximum possible distance between 

disturbances and points of domestic use. This creates abundant opportunities for runoff 

infiltration and sediment deposition where it will not affect this beneficial use. 

 Additionally, CWE model risk ratios suggest no significant increase in sediment delivery 

potential from all project activities, including road construction. The potential adverse 

effect of road construction on municipal / domestic uses of water would be negligible to 

minor, and the duration of effects would not exceed one decade. 

 Mechanical treatments, mastication, and use of skid trails and landings could potentially 

increase the amount of soil disturbance, erosion, and sediment delivery to streams. 

Sediment indicators do not show significant increases for project activities, including 

mechanical treatments. The same rationale presented under Fish Habitat effects (discussed 

above) applies here (also refer to “Section 3.5.4.4 Summary of Effects to Special Status 

Species and Their Habitat”). Low disturbance treatments, such as thinning and mastication, 

ridgetop and upper slope location, minimal overlap with Riparian Reserves, full 

implementation of RPMs, and extremely small increases in CWE risk ratios all support the 

conclusion of minimal impact on municipal / domestic use from project-related accelerated 

sedimentation. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-141

The proposed action complies with the Clean Water Act through implementation of BMP’s, 

meeting water quality objectives (suspended sediment, turbidity, and temperature), and protecting 

beneficial uses (USDA Forest Service 2007a). These actions ensure compliance with the Clean Water 

Act and North Coast Regional Water Quality Board Basin Plan. Further, projects must comply with 

the California Regional Water Board’s Categorical Waiver for Discharges Related to Timber Harvest 

Activities on Federal Lands Managed by the United States Department of Agriculture, Forest Service 

in the North Coast Region, Order No. R1-2004-0015 (Waiver). The Eddy Gulch LSR Project meets 

all conditions and eligibility requirements of the Categorical Waiver. 

Potential adverse effects on municipal/domestic uses of water from these treatments would be 

negligible to minor, with full recovery to pre-project conditions within a decade. 

 The prescribed underburning could potentially result in localized loss of soil and canopy 

cover, which would be of special concern in Riparian Reserves—Such events are expected to be 

few in number and limited in size by the fact that burn plans will meet cover retention requirements in 

conformance with Klamath LRMP guidelines (ACS, Riparian Reserve Standards and Guidelines, 

BMPs, and related RPMs). This potential effect is expected to be negligible. Should such effects 

occur, they would be short term because regrowth and adjacent unburned stands would contribute to 

the rapid re-establishment of soil cover. The magnitude of this effect is virtually identical between 

Alternatives B and C because the locations and amounts of underburn treatments are nearly identical. 

Cumulative Effects on Municipal / Domestic Uses of Water under Alternative B (Beneficial 

Use “MUN”). No evidence was found to indicate that existing sediment or turbidity levels cause 

impairment to municipal / domestic uses of water. Because the CWE model input includes 

information from past and foreseeable future projects, its output offers the best quantitative 

assessment of potential cumulative effects on municipal / domestic use in the form of accelerated 

sedimentation. Listed municipal watersheds include Eddy Gulch, Black Bear Creek, Shadow Creek, 

Callahan Gulch, Counts Gulch, Crawford Creek, and Music Creek. Of these, Eddy Gulch and Shadow 

Creek are the only drainages with CWE risk ratios that could be described as “at risk.” Table 7 shows 

Eddy Gulch with a USLE risk ratio of 0.90, which represents existing condition plus effects of 

foreseeable future projects. This increases very slightly to 0.91 in 2014 when all road construction 

and mechanical treatments are complete. The same risk ratio for Shadow Creek is 0.93, increasing to 

0.96 in 2014. These increases are extremely small and likely not significant. No other risk ratios for 

municipal watersheds are in the “at risk” or higher range. 

Cumulative adverse effects from project activities, when superimposed on past and foreseeable 

future actions, are expected to be negligible to minor. Full recovery to pre-project conditions, as 

judged from CWE risk ratios, is likely upon project completion in 2021. 

3.5.4.3 Alternative C: No New Temporary Roads Constructed 

As mentioned in the discussion of Alternative B, the differences between the two action 

alternatives are very small. The 1.03 miles of new temporary roads would not be constructed under 

Alternative C, and as a result, 99 acres in M Units and 822 acres in Rx Units would not be treated. 

This reduction in thinning acres would affect M Units 15, 17, 21, 24, 36, 37, and 75. The magnitude 

of differences between the two action alternatives relative to potential effects on fish and their habitat 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-142 Chapter 3: Affected Environment and Environmental Consequences

are very small because mechanical units and the proposed temporary roads would be located on or 

near ridgetops and not in Riparian Reserves. 

Because the differences between the action alternatives are so small, most of the discussions of 

potential effects presented under Alternative B are applicable to Alternative C. Rather than repeat 

those sections, the discussion that follows only focuses on the differences in effects on aquatic 

resources. 

The design features applicable to both action alternatives include BMPs, WWOS, forestwide soil 

cover standards, as well as Klamath LRMP Standards and Guidelines. Application of these measures 

would minimize the effects of proposed treatments equally under both alternatives. 

Actions with Potential to Affect Sediment Indicators under Alternative C 

Road construction—There would be no construction of the 1.03 miles of new temporary 

roads, but the former logging access routes (0.98 mile) would still be re-opened (vegetation removed 

and bladed) to access all or portions of five M Units for yarder access and skidding of logs. Other 

than this change, this discussion under this heading for Alternative B is equally applicable to 

Alternative C. 

Skid trails, landings, and cable corridors associated with thinning units—All of the 

99 acres of thinning that are eliminated under Alternative C were proposed for cable yarding because 

of slope steepness. This will produce a slight decrease in the potential for soil disturbance. The 

landings (and associated skid trails) proposed for tractor yarding in the thinning units will remain part 

of Alternative C. The rest of the discussion under this heading for Alternative B is equally applicable 

to Alternative C. 

Mastication of fuels—See discussion under Alternative B (no change). 

Prescribed underburning—Approximately 822 acres in Rx Units have been eliminated 

from Alternative C. This change, when taking into consideration the overall amount of proposed 

underburning, would result in a negligible difference between the effects of Alternatives B and C; 

therefore, the rest of the discussion under this heading for Alternative B is equally applicable to 

Alternative C.

Water drafting—See discussion under Alternative B (no change). 

Wildfire and its suppression—Not thinning the 99 acres within ridgetop FRZs and not 

treating 822 acres in Rx Units may slightly reduce the effectiveness of treatments relative to the risk 

of stand-replacing wildfire and its associated increase in erosion and sedimentation. The rest of the 

discussion under this heading for Alternative B is equally applicable to Alternative C.

Actions with Potential to Affect Flood Regime Change Indicator under Alternative C 

Road construction—The slight reduction in road construction is too small to have any 

measurable effect on the potential for flood regime change. No effect is expected from Alternative B, 

so none would be expected from Alternative C. The rest of the discussion under this heading for 

Alternative B is equally applicable to Alternative C.
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-143

Skid trails, landings, and cable corridors associated with thinning units—No adverse 

effect on flood regime change is expected from Alternative B so none would be expected from 

Alternative C in which overall soil disturbance is slightly less. The rest of the discussion under this 

heading for Alternative B is equally applicable to Alternative C. 

Mastication of fuels—See discussion under Alternative B (no change). 

Prescribed underburning—Since underburning does not create impervious surface, the 

99 acre increase is unlikely to produce an adverse effect. The rest of the discussion under this heading 

for Alternative B is equally applicable to Alternative C. 

Water drafting—See discussion under Alternative B (no change). 

Wildfire and its suppression—Not thinning on 99 acres within ridgetop FRZs and not 

treating 822 acres in Rx Units may slightly reduce the effectiveness of treatments relative to the risk 

of stand-replacing wildfire and its associated potential to increase the amount of impervious surface. 

The rest of the discussion under this heading for Alternative B is equally applicable to Alternative C. 

Actions with Potential to Affect Stream Temperature Indicator under Alternative C 

 Road construction—See discussion under Alternative B (no change). 

 Skid trails, landings, and cable corridors associated with thinning units—Under 

Alternative B, eight thinning units required SMZs because of overlap or adjacency with seasonal 

stream (nonperennial streams) Riparian Reserves. Three of those units (M15, M21, and M24—all in 

Shadow Creek) would have thinning acres reduced from 144 to 62 acres, with a minimal difference in 

effects. The rest of the discussion under this heading for Alternative B is equally applicable to 

Alternative C. 

 Mastication of fuels—See discussion under Alternative B (no change). 

 Prescribed underburning—See discussion under “Skid trails, landings, and cable corridors 

associated with thinning units.” 

 Water drafting—See discussion under Alternative B (no change). 

 Wildfire and its suppression—Not thinning on 99 acres within ridgetop FRZs may slightly 

reduce the effectiveness of treatments relative to the risk of stand-replacing wildfire and its associated 

potential to consume portions of Riparian Reserves. The rest of the discussion under this heading for 

Alternative B is equally applicable to Alternative C.

Actions with Potential to Affect Large Woody Debris Recruitment Indicator under 

Alternative C 

Road construction—See discussion under Alternative B (no change). 

Skid trails, landings, and cable corridors associated with thinning units—Under 

Alternative B, eight thinning units required SMZs because of overlap or adjacency with seasonal 

stream (nonperennial streams) Riparian Reserves. Three of those units (M15, M21, and M24—all in 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-144 Chapter 3: Affected Environment and Environmental Consequences

Shadow Creek) would have thinning acres reduced from 144 to 62 acres, with a minimal difference in 

effects. The rest of the discussion under this heading for Alternative B is equally applicable to 

Alternative C. 

Mastication of fuels—See discussion under Alternative B (no change). 

Prescribed underburning—See discussion under “Skid trails, landings, and cable corridors 

associated with thinning units.” 

Water drafting—See discussion under Alternative B (no change). 

Wildfire and its suppression—Not thinning on 99 acres within ridgetop FRZs and the 

reduction of 822 acres in Rx Units may slightly reduce the effectiveness of treatments relative to the 

risk of stand-replacing wildfire and its associated potential to consume portions of Riparian Reserves. 

The rest of the discussion under this heading for Alternative B is equally applicable to Alternative C. 

Hazard tree removal—The removal of hazard trees along roads could potentially affect 

LWD in Riparian Reserves under both action alternatives. However, the Klamath National Forest 

Hazard Tree Guidelines will be implemented and trees felled within Riparian Reserves would be left 

on site, so the LWD levels in Riparian Reserves would not be affected by hazard tree removal. 

Actions with Potential to Affect the Road Density Indicator under Alternative C 

Road construction—The discussion under Alternative B highlighted the extremely small 

increases in road density associated with 1.03 miles of new temporary road construction. The deletion 

of 1.03 miles of proposed temporary road segments under Alternative C results in pre-project road 

density, as shown below. 

Pre-project 

(mi/mi2) 

Alternative B 

Post-project 

(mi/mi2) 

Alternative C 

Post-project 

(mi/mi2) 

Black Bear Creek 2.67 2.69 2.67 

Crawford Creek 3.09 3.12 3.09 

Shadow Creek 2.73 2.85 2.73 

The rest of the discussion under this heading for Alternative B is equally applicable to 

Alternative C.

 Skid trails, landings, and cable corridors associated with thinning units—These actions 

would not affect road density. 

Mastication of fuels—This action would not affect road density. 

Prescribed underburning—This action would not affect road density. 

Water drafting—This action would not affect road density. Existing access roads would 

be used. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-145

Wildfire and its suppression—These actions would not affect road density. 

Direct and Indirect Effects on Fisheries Habitat under Alternative C 

(Beneficial Use “COLD”) 

 Water drafting from streams has the potential to adversely affect fish by temporarily 

dewatering channels and entraining young fish into pump intakes—Existing water drafting sites 

will be used. The incorporation of NMFS (2001b) Water Drafting Specifications as RPMs will 

prevent these impacts. Erosion control and drainage will prevent sedimentation and turbidity 

increases. This impact assessment is identical between Alternatives B and C. 

 Construction of new temporary roads and re-opening of former logging access routes 

have the potential to increase sedimentation in streams and degrade fish habitat—Under 

Alternative B, this potential for this impact was evaluated as negligible to minor. Because Alternative 

C eliminates 1.03 miles of new temporary road construction, but retains use of the 0.98 mile of 

former logging access routes, the impact would be slightly less under Alternative C and still 

negligible to minor. The duration of effects would not exceed one decade. 

 Mechanical treatments, mastication, and use of skid trails and landings could 

potentially increase the amount of soil disturbance, erosion, and sediment delivery to streams—

Alternative C contains 99 fewer acres of thinning, thus slightly reducing the magnitude of this impact. 

However, the magnitude of adverse effects under Alternative B was determined to be negligible, thus 

the reduction would be discountable. The rest of the discussion under this heading for Alternative B is 

equally applicable to Alternative C. Handlines that will be constructed around prescribed burn areas 

will be mitigated (water-barred and covered with organic material) immediately following prescribed 

burning, when safe to do so, to restore soil cover and minimize the potential for erosion. 

The potential adverse effect under Alternative B was judged to be negligible to minor, and with 

even fewer acres receiving mechanical treatment under Alternative C, potential effects on fish habitat 

from these treatments would be negligible to minor, with full recovery to pre-project conditions 

within a decade. 

 The prescribed underburning could potentially result in localized loss of soil and canopy 

cover, which would be of special concern in Riparian Reserves—Approximately 822 acres of 

Rx Units have been eliminated from Alternative C. This change, when taking into consideration the 

overall amount of proposed underburning, would result in a negligible difference between the effects 

of Alternatives B and C; therefore, the rest of the discussion under this heading for Alternative B is 

equally applicable to Alternative C. The duration of effects is expected to be 5–10 years due to rapid 

re-establishment of ground cover from adjacent stands. 

Cumulative Effects on Fisheries Habitat under Alternative C (Beneficial use “COLD”)

See discussion under Alternative B because it is equally applicable to Alternative C. The 

differences in cumulative effects on fish between the action alternatives are discountable. Based on 

the same rationale presented for Alternative B, cumulative effects, including the proposed treatments, 

are considered to be minor. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-146 Chapter 3: Affected Environment and Environmental Consequences

Direct and Indirect Effects on Municipal / Domestic Uses of Water under Alternative C 

(Beneficial Use “MUN”) 

Direct effects on municipal/domestic uses of water are unlikely. Damage to impoundments or 

delivery infrastructure or introduction of pollutants at points of diversion are the most likely processes 

fitting the definition of “direct effect.” Under Alternative C, no activities are proposed near known 

points of diversion or use that could produce such direct effects. Indirect effects would most likely be 

associated with accelerated sediment delivery to streams. Accelerated erosion and sedimentation can 

result in sediment deposition that damages diversion structures or renders them inoperative. High 

turbidity in water indicates the presence of particulates that can serve as substrates (and nutrients) for 

harmful microorganisms. Indirect effects on municipal/domestic use are evaluated in the bulleted 

items that follow:

 Construction of new temporary roads and re-opening of former logging access routes have 

the potential to increase sedimentation in streams resulting in damage to water delivery 

systems or rendering water unfit for consumption. Alternative C does not propose 

construction of the 1.03 miles of temporary roads, but the 0.98 mile of former logging 

access routes would still be re-opened. Based on the same rationale presented for 

Alternative B, it is concluded that the potential adverse effects on municipal use from roadgenerated sediment would be negligible to minor. The duration of effects would not exceed 

one decade. 

 Mechanical treatments, mastication, and use of skid trails and landings could potentially 

increase the amount of soil disturbance, erosion, and sediment delivery to streams. 

Alternative C contains 99 fewer acres of thinning, thus slightly reducing the magnitude of 

this impact. The rest of the discussion under this heading for Alternative B is equally 

applicable to Alternative C. 

This potential adverse effect that would result from implementation of Alternative C was judged 

to be negligible to minor. With even fewer acres receiving mechanical treatment under Alternative C, 

it is concluded that potential adverse effects on municipal/domestic use from these treatments would 

be negligible to minor, with full recovery to pre-project conditions within a decade. 

 The prescribed underburning could potentially result in localized loss of soil and canopy 

cover, which would be of special concern in Riparian Reserves—Approximately 822 acres of 

Rx Units have been eliminated from Alternative C. This change, when taking into consideration the 

overall amount of proposed underburning, would result in a negligible difference between the effects 

of Alternatives B and C, as is the conclusion that the magnitude of effects would be negligible to 

minor; therefore, the rest of the discussion under this heading for Alternative B is equally applicable 

to Alternative C. The duration of effects is expected to be 5–10 years due to rapid re-establishment of 

ground cover from adjacent stands. 

Cumulative Effects on Municipal/Domestic Uses of Water under Alternative C (Beneficial Use 

“MUN”) 

See discussion under Alternative B as it is equally applicable to Alternative C. The differences in 

cumulative effects to municipal/domestic uses between the action alternatives are discountable. Based 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.5 – Aquatic Resources 3-147

on the same rationale presented for Alternative B, cumulative effects including the proposed actions 

are considered to be minor. 

3.5.4.4 Summary of Effects on Special-Status Fish Species and Their Habitat 

The BA/BE (Berg 2009) prepared for the Eddy Gulch LSR Project Proposed Action contains a 

detailed analysis of effects on the following ESA-listed species, critical habitat, Essential Fish 

Habitat, and Sensitive Species: 

Endangered: None 

Threatened: Southern Oregon / Northern California Coast (SONCC) Evolutionary 

Significant Unit coho salmon (Oncorhynchus kisutch) and their 

designated critical habitat 

Proposed: None 

Sensitive: Upper Klamath-Trinity Rivers Chinook salmon (O. tshawytscha) 

Klamath Mountains Province steelhead trout (O. mykiss) 

Essential Fish 

Habitat: 

Coho salmon and Chinook salmon (specifically SONCC coho salmon 

and Upper Klamath-Trinity Chinook salmon for this project) 

ESA-listed Fish Species 

The fish BA/BE for this project (Berg 2009) determined that, in summary, all the actions, when 

considered collectively and individually, would have either no effect (as described in the efficiency 

measures section of the BA/BE) or are not likely to adversely affect coho salmon and their critical 

habitat. The project has indirect beneficial effects that would result in increased protection from 

wildfire. The one activity that was determined “May Affect, Not Likely to Adversely Affect” is water 

drafting. Thus, the final ESA determination for the Eddy Gulch LSR Project’s insignificantly negative 

effects of water drafting on peak/base flows and coho salmon that may be in the vicinity of water 

drafting sites was “May Affect, but is Not Likely to Adversely Affect” SONCC coho salmon. The 

BA/BE also determined that the Eddy Gulch LSR Project “May Affect, but is Not Likely to Adversely 

Affect” SONCC coho salmon critical habitat. 

Forest Service Sensitive Fish Species 

The BA/BE (ibid.) determined that the Eddy Gulch LSR Project would likely not result in a trend 

towards listing or loss of viability of steelhead or Chinook salmon and may have beneficial effects on 

watershed conditions that support these species. 

A trend toward listing under the ESA is not anticipated and viability is not at risk because the 

Eddy Gulch LSR Project meets Klamath LRMP Standards and Guidelines, does not adversely modify 

its habitat in the long term, and individual Chinook salmon and steelhead trout are not expected to be 

adversely impacted by project activities, and there are beneficial effects on habitat in the long term, as 

analyzed in the fish BA/BE. Biodiversity of aquatic species is maintained through the use of 

Standards and Guidelines in the Klamath LRMP, including development of resource protection 

measures, compliance with the ACS objectives, use of Riparian Reserve buffers, and evaluation at the 

5th-field watershed scale. Effects on 7th-field watersheds were also considered. 
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3-148 Chapter 3: Affected Environment and Environmental Consequences

Essential Fish Habitat Assessment 

The BA/BE (ibid.) used the Klamath National Forest fish distribution GIS map, as well as other 

surveys and field observations to analyze effects on salmonid habitat and to identify Essential Fish 

Habitat for Chinook and coho salmon within the Eddy Gulch LSR. The Klamath National Forest fish 

distribution map includes all streams that are used by steelhead, coho salmon, and Chinook salmon. 

The Klamath National Forest and fish BA/BE analysis for the Eddy Gulch LSR Project used the fish 

distribution map to identify critical habitat for SONCC coho salmon and Chinook and coho salmon 

Essential Fish Habitat since it is the most complete and conservative information relative to 

estimating the extent of anadromous habitat. However, because coho salmon and Chinook salmon do 

not typically migrate or rear as high up in stream systems as steelhead, the fish distribution map used 

for this analysis overestimates the extent of SONCC coho salmon critical habitat and Chinook and 

coho salmon Essential Fish Habitat because it is based on steelhead and resident trout distribution. 

Thus, steelhead may occupy some reaches not accessible to coho and Chinook salmon. However, 

effects were considered for all anadromous species, and habitat for all anadromous species was 

assumed to occur where steelhead and rainbow trout occur. The effects analysis in the fish BA/BE 

(ibid.) considers effects on Pacific salmonid habitat in general, and since habitat requirements and 

effects mechanisms for coho and Chinook salmon are similar, the effects of the project analyzed 

previously are identical for Essential Fish Habitat. The BA/BE (ibid.) determined that the Eddy Gulch 

LSR Project will not adversely affect, and may have long-term positive effects on coho salmon and 

Chinook salmon Essential Fish Habitat. Beneficial effects would include increased watershed 

resiliency to future wildfires and promotion of late-successional vegetation, which would increase 

large woody debris in forests and streams. 

Management Indicator Species 

The MIS Report determined that the no-action alternative would not result in direct effects on 

resident trout or steelhead or their habitat. Watershed and aquatic habitat conditions will continue to 

respond to climatic and other environmental changes and will continue to recover from past flood and 

fire events until reset by a future natural event such as wildfire. The no-action alternative would not 

directly affect stream shade, water temperature, sedimentation rates, or large woody debris. 

The MIS Report determined that the proposed actions, when considered collectively and 

individually, would either have no effect or negligible effects (as described in the efficiency measures 

section of the project fish BA/BE). Water drafting is the one Project Element that could directly affect 

steelhead and rainbow trout and their habitat. However, potential adverse effects of water drafting 

will be minimized through implementation of NMFS (2001) Water Drafting Guidelines that maintain 

instream flows and require screening of pumps. The project will have indirect beneficial effects that 

would result in increased protection from wildfire. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.6 – Soils and Geology 3-149

3.6 Soils and Geology ____________________________________ 

3.6.1 Introduction 

The role of the soil scientist for the Eddy Gulch Late-Successional Reserve (LSR) Project is to 

ensure that the methods used to achieve project objectives would maintain the productive capacity of 

the soil resource, as defined in the Klamath National Forest Land and Resource Management Plan 

(Klamath LRMP) and regional Soil Quality Analysis Standards (SQAS). Maintaining the long-term 

soil productivity in the Assessment Area will be accomplished through project design features and the 

Resource Protection Measures (RPMs) that ensure the project will meet the Klamath LRMP’s soil 

resource Standards and Guidelines (USFS 1995a) and the regional SQAS (USFS 1995b). 

The role of the geologist is to evaluate potential risks to geologic resources from project activities 

and to recommend RPMs to eliminate or minimize those risks. Of special interest are Riparian 

Reserve lands, particularly those that might pose elevated landslide risk. It is of the utmost 

importance that project activities do not significantly increase landslide-related sediment. By meeting 

this requirement, project implementation will fully protect all Riparian Reserves and prevent 

impairment of beneficial uses of water in streams and other water bodies. 

3.6.2 Methodology: Soils 

A unit selection strategy was used to determine which units should have site-specific data 

collected. Selection was based on soil sensitivity and type of management activities planned. Units 

that had the potential to be treated with ground-based yarding systems were a priority for field review. 

All proposed ground-based yarding units, 50 percent of the cable units, and most of those units 

proposed for mastication or roadside hazard tree removal were field reviewed. Field observations 

were done by making one to three traverses across each treatment unit, depending on the unit’s shape 

and size. Site and soil data were collected from plots along these traverses. The following types of 

existing site disturbances were identified in the field during the traverses: landings, skid trails, fullbench skid trails, skid trail displacement, old roads, and skid roads. The level of detrimental soil 

disturbance was estimated for each soil disturbance type. This data was used to develop the existing 

condition, as well as the cumulative effects of the Proposed Action. Soil data noted during the field 

assessment included shallow soil areas, rock outcrops, and areas of surface rock, rock lithology, 

general soil depth, and taxonomic features. Existing soil survey information was used unless field 

observations revealed significant differences between mapped soils and the actual site-specific soils. 

Also included with each transect or ocular estimate was a general discussion of the treatment unit 

that addressed issues such as potential mass instability areas, sensitive riparian locations, or the 

feasibility of the treatment method proposed. These observations helped develop specific 

management recommendations for the assessed treatment unit. 

3.6.2.1 Analysis Methods and Assumptions 

Numerous data sources were provided by Klamath National Forest staff and incorporated into this 

analysis; some of the more relevant information specific to the soil resource included the following: 

 Klamath National Forest Area Soil Survey (Foster and Lang 1994),
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3-150 Chapter 3: Affected Environment and Environmental Consequences

 Soil profile descriptions developed during the active soil survey located within the 

Assessment Area,

 Klamath LRMP Standards and Guidelines pertaining to the soil resource, and

 Estimates of basic erosion rates based on the Universal Soil Loss Equation (USLE) 

(Laurent 2001).

Computer-based Geographical Information Systems (GIS) technology was used to organize and 

synthesize digital data provided by both the Klamath National Forest and the contractor’s GIS 

specialist. By incorporating numerous digital databases (such as soils, geology, slope and aspect, 

existing land instability, the preliminary treatment units, and 1-meter resolution digital aerial 

imagery), the existing condition began to emerge. Although not a substitute for field-level 

assessments, this approach provided baseline information that defined the level and extent of analysis 

necessary to define the environmental consequences of the Proposed Action. 

Once generated, digital background images of the Assessment Area were incorporated into a 

Global Positioning System field data logger prior to field work. This technology was especially vital 

in the location of treatment units, roads and skid trails, and other areas of concern such as unstable 

landforms and riparian complexes. 

3.6.2.2 Scope of the Analysis 

Analysis Area. The soil resource analysis area is very site specific. Unlike a broader watershed 

approach, individual treatment units were evaluated and the data correlated. At the time of field data 

collection (June and July of 2008), the soil resource analysis area was approximately 30,000 acres. 

Appendix A of the Soil Resource Report graphically portrays this analysis area. 

Analysis Period. The timeframe for the effects analysis is less than 10 years for short-term 

effects and up to 75 or more years for long-term effects on soil productivity. 

3.6.2.3 Intensity of Effects 

“Intensity” refers to the severity of effects or the degree to which the action may adversely or 

beneficially affect a resource. The intensity definitions used throughout this effects analysis are 

described below. 

Negligible. Soils would not be affected, or the effects on soils would be below or at levels of 

detection. There would be no discernable effect on the rate of soil erosion and/or the ability of the soil 

to support native vegetation. 

Minor. The effects on soils would be detectable, but effects on soil productivity or fertility would 

be small. There would be localized, detectable effects on the rate of soil erosion and/or the ability of 

the soil to support native vegetation. 

Moderate. The effect on soil productivity or fertility would be highly variable due to differences 

in soil type, topography, and site-specific treatments. The rate of soil erosion and/or the ability of the 

soil to support native vegetation would be measurably changed, especially within the main skid trail 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.6 – Soils and Geology 3-151

corridors and landings. Detrimental disturbance in the form of soil compaction (greater than 

10 percent decrease in soil porosity) and displacement (greater than 15 percent loss of soil organic 

matter in upper 12 inches of soil) are approaching threshold values. 

Major. The effect on soil productivity or fertility would be highly variable due to differences in 

soil type, topography, and site-specific treatments, but readily apparent and would substantially 

change the character of the soils over a large area within the treatment unit. The actions would have 

substantial, highly noticeable influence on the rate of soil erosion and/or the ability of the soil to 

support native vegetation. The impacts would be most noticeable within main skid trails, landings and 

cable corridors. Detrimental disturbance in the form of soil compaction (greater than 10 percent 

decrease in soil porosity) and displacement (greater than 15 percent loss of soil organic matter in 

upper 12 inches of soil) would exceed threshold values, and most likely require on-site mitigation. 

3.6.3 Methodology: Geology 

The geologic assessment followed guidance for project-level investigations given in Methods for 

Mapping Unstable Lands. This is an internal guidance document prepared by Klamath National 

Forest geologists. 

3.6.3.1 Analysis Methods and Assumptions 

The primary steps for this geologic analysis involved 

1. reviewing existing data, including the Geo13 map layer that exists on the Klamath National 

Forest’s GIS; 

2. reviewing the geology sections in the three watershed analyses (USFS 1994b; 

USFS 1995b; USFS 1997) that cover the Assessment Area; 

3. reviewing published geologic maps to understand the distribution of rock types; 

4. examining air photo coverage for potential landslides or unstable features not already 

mapped; and 

5. conducting field reviews of proposed treatment units with the purpose of identifying site 

features that might indicate instability. 

The site features include hummocky or broken slope topography (scarp-bench-toe sequences), 

mid-slope or near-channel deposits of colluvium, area-wide patterns of springs and seeps, jackstrawed trees, and currently active scarps or ground fracture. Debris slide and debris torrent events 

will often be marked by drainages scoured to widths far greater than the active channel, with clear 

and abrupt changes in type or age class of vegetation. Field assessment also requires an understanding 

of the structural properties of various rock types and their relative potentials for producing unstable 

slopes. 

Where confirmed or suspected unstable slopes were encountered but not already mapped on 

Geo13, their locations were noted, the feature was reviewed on air photos, and its estimated 

boundaries drawn on a field map. 
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3-152 Chapter 3: Affected Environment and Environmental Consequences

Information on bedrock and geomorphic features is taken from the Klamath National Forest GIS 

coverages. Landslide sediment model coefficients were taken from studies in the Salmon River 

watershed (USFS 1994b). 

This investigation focused on slope stability issues related to project activities. The geologic 

assessment involved the geologist spending 20 days conducting field reviews and 15 office days. 

With only a few exceptions, the project geologist, hydrologist, and soil scientist conducted field 

reviews and evaluated all proposed thinning units, new temporary road locations, former logging 

access routes, and existing landings. Findings from the field reviews are documented in the project 

geology notes and unit descriptions (contained in the project record) and in Section 3.5 or the Aquatic 

Resources Report. The unit descriptions include recommendations for changes to Riparian Reserve 

boundaries and any slope instability features that were not previously mapped. The Klamath National 

Forest geomorphology and bedrock layers were updated as part of this project. 

The geologic evaluation included modeling of wildfire effects on geologic resources under the 

no-action alternative. The Klamath National Forest’s cumulative watershed effects (CWE) model was 

used to evaluate the effect of modeled wildfires on the potential for landslide-related sediment 

production. 

3.6.3.2 Scope of the Analysis 

Analysis Area. The analysis area was defined by the project’s Assessment Area boundary, 

although areas outside the boundary were examined on air photos to better understand patterns in the 

occurrence of unstable slopes in the area. Field review was confined to the immediate vicinity of 

project treatment units. 

Analysis Period. The timeframe for the effects analysis is 0–3 years for short-term effects and up 

to 10 years for long-term effects on geology. 

3.6.3.3 Intensity of Effects 

Negligible. Slope stability and landslide risk would not be affected. There would be no 

discernable effect on landslide-related sediment or other effects on beneficial uses of water or other 

aquatic resources. 

Minor. There could be a very small and short-term increase in landslide risk. The duration of 

increased risk is so short that triggering climatic or seismic events would have a very low probability 

of occurrence. There would be low probability of landslide-related sediment delivery to streams or 

other effects on beneficial uses of water. 

Moderate. Increased landslide risk is more extensive across the Assessment Area. The duration of 

effects lengthens, allowing a high probability of triggering climatic or seismic events. Project-related 

landslide sediment would be detectable at the 7th-field watershed scale but not at 6th-field or larger 

scales. Effects on beneficial uses or other aquatic resources would be localized and short duration. 

Major. Significantly increased landslide risk is common throughout the Assessment Area. 

Landslide-related sediment would be a significant concern at the 5th-field watershed scale. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.6 – Soils and Geology 3-153

3.6.4 Affected Environment (Existing Conditions): Soils 

Soils in the Eddy Gulch LSR Project Assessment Area were dominantly developed from 

metasedimentary or metaschist parent materials, with inclusions of serpentinized peridotite 

(ultramafics) and metavolcanics. The Assessment Area is characterized by gently to very steeply 

sloping topography, including stabilized landslide benches and scarps. The major soils formed from 

the metasedimentary materials ranged from the shallow Woodseye family to the moderately deep 

Jayar and deep Clallam families. Of lesser extent are the Inville and Wintoner families that developed 

in the metavolcanics, and the Lithic Mollic Haploxeralfs-Dubakella families’ complex that developed 

from the ultramafics. Soil textures in the Assessment Area were dominated by gravelly to very 

gravelly loams, sandy loams, or sandy clay loams. 

Calculated from approximately 1,200 data plots (which are detailed in Table B-1, Appendix B of 

the Soils Resource Report), 28.7 percent of the Assessment Area has been disturbed from past 

activities, excluding system roads. Approximately 2.6 percent of this disturbance exceeds the Forest’s 

soil quality thresholds for detrimental disturbance. The majority of the disturbance was in main or 

constructed skid trails and landings. Percent soil cover range was 10–100 percent (Klamath LRMP 

Standards and Guidelines for effective soil cover ranges between 70 and 80 percent), with an overall 

average of 72 percent in the proposed treatment units. There was a variation in soil cover between 

transects sampled, but when averaged with other transects, the forest standard was met in most cases. 

The following M Units averaged well below the 70 percent ground cover minimum: 19 (cable), 

21 (cable and tractor), 24 (cable), 35, and 36. Slope range was 2–80 percent, with an average percent 

slope of 42 percent. Using calculated soil erosion rates for average soil cover and slope developed for 

the Klamath National Forest (Laurent 2001), the estimated soil erosion rates ranged 0.4–0.8 ton per 

acre per year. Based on the small percentage of sheet and rill erosion observed during the field 

assessment, the actual range would be closer to 0.15–0.25 tons per acre per year. 

The current detrimental disturbance threshold (in existing landings, skid trails, and new 

temporary roads) is 15 percent. If skid trails and landings occupy greater than 15 percent of a unit, 

then the unit exceeds the detrimental disturbance threshold. Presently, M Unit 21 and M Unit 24 (both 

tractor units) exceed the detrimental disturbance standards. 

In virtually all of the treatment units assessed, coarse woody material was lacking spatially and in 

the range of decomposition classes. 

3.6.5 Environmental Consequences: Soils 

This section describes the anticipated effects on the environmental indicators. There are three 

measures (or indicators) that were used to assess current soil conditions in the Assessment Area. The 

same indicators were used to assess effects of taking no action and effects that could result from 

implementation of either Alternative B or Alternative C. 

 Soil cover, 

 Detrimental disturbance (detrimental compaction and detrimental soil displacement), and 

 Organic matter (includes fine organic matter and CWD). 
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3-154 Chapter 3: Affected Environment and Environmental Consequences

3.6.5.1 Alternative A: No Action 

Soil Cover 

Direct and Indirect Effects—A wildfire would result in loss of soil cover, which would 

adversely affect soil productivity and water quality. The continued accumulation of organic matter on 

the forest floor would contribute to increased ground fuel loads. No mechanical treatment or 

prescribed fire would occur, leading to increased fire severity and intensity during a fire event. Fire 

simulation models predict that under 90th percentile weather conditions, approximately 7,200 acres 

could potentially be affected by various burn intensities. As a result of decreased soil cover following 

a fire, the risk of soil erosion would increase on forested hill slopes. Soil erosion would contribute to 

a loss of soil nutrients and favorable growth medium on site and increased sediment delivery to 

stream channels. 

 Conclusion—There would be a higher risk of wildfire occurrence because no treatments 

would be implemented to reduce fuel loading. A wildfire would create short-term adverse effects on 

soil productivity and water quality due to the immediate loss of soil cover, causing a measurable 

increase in surface erosion and delivered sediment. 

 Cumulative Effects—A loss of soil cover would adversely affect long-term soil productivity. 

Soil cover can be expected to increase as organic materials accumulate on the soil surface. However, 

a future high-severity wildfire would likely consume organic materials on the forest floor and reduce 

soil cover below the Klamath LRMP Standard in the affected area. If soil cover is reduced to bare soil 

following a wildfire, the soil would be more susceptible to erosion. In addition, fire can volatilize 

organic compounds in the soil, some of which migrate down a temperature gradient and condense on 

soil particles below the surface. As a result, a non-wettable layer can develop below the surface. 

Creation of a water repellant layer has been described as a “tin roof” effect because infiltration rates 

are greatly reduced at the water repellant layer. During a precipitation event, soil above the nonwettable layer can become saturated and erode downslope due to rill formation and raindrop splash. 

Factors such as soil texture, slope, and post-burn precipitation intensity can affect the degree and type 

of post-fire erosion. Dry, coarse-grained soils are particularly susceptible to this type of fire-induced 

hydrophobic condition (not absorbing or mixing easily with water) (USFS 2005). 

 Conclusion. There would be a higher risk of wildland fire occurrence because no treatments 

would be implemented to reduce fuel loading. Taking no action would lead to long-term adverse 

effects on soil productivity in the uncontrolled fire-affected areas. Recovery from measurable surface 

erosion and subsequent delivered sediment would take approximately 5–6 years (USFS 1981). Full 

recovery of the organic fraction of ground cover would take decades. 

Detrimental Disturbance (Detrimental Compaction and Detrimental Soil Displacement) 

Direct and Indirect Effects—The extent and degree of detrimental disturbance (especially 

detrimental compaction) are expected to decline slowly over time. This process may take several 

decades in forested environments (USFS 2002). Root penetration, extension, and decay, along with 

the burrowing action of soil-dwelling animals, would contribute to the increase in soil porosity and 

decrease in compaction. In addition, incorporation of organic matter into the soil by biological 

processes (such as invertebrate and vertebrate soil mixing and decomposition) would help reduce soil 

bulk density and the degree of compaction in affected areas over time. As the degree and extent of 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.6 – Soils and Geology 3-155

soil compaction is reduced slowly, soil productivity would increase. Soil infiltration would be 

enhanced as porosity is increased. Increased infiltration may reduce surface runoff and subsequent 

erosion and sedimentation. 

 Conclusion. There would be a higher risk of wildland fire occurrence because no treatments 

would be implemented to reduce fuel loading. The effects of soil compaction would remain short 

term, localized, and negligible, mostly related to minor activities outside those areas identified under 

the existing condition. In the event of a future wildfire of moderate severity (up to 40 percent of an 

area where surface litter and humus have been consumed and surface soil horizons subjected to 

intensive heating), severe soil heating would cause physical changes in soils, including a reduction in 

soil porosity, mirroring the effects of soil compaction (Debano et al. 2005). This affect would occur 

primarily in locations where 1,000-hour fuels exceed 5–10 tons per acre (the current condition for the 

Eddy Gulch LSR Project Assessment Area is 5–30 tons per acre). This would lead to short-term 

adverse effects on soil productivity and water quality due to the immediate loss of infiltration 

capacity, causing a measurable increase in surface erosion and delivered sediment. 

Cumulative Effects—The extent and degree of detrimental disturbance are expected to 

continue to decline in the absence of future timber harvests, road construction, or other ground 

disturbing activities. 

 Conclusion. Recovery from detrimental disturbance, especially soil compaction would 

continue in areas previously affected, with short-term localized negligible compaction occurring due 

to activities such as roadside hazard tree removal. There would be a higher risk of wildfire occurrence 

because no treatments would be implemented to reduce fuel loading, leading to long-term adverse 

effects on soil productivity and water quality due to the loss of infiltration capacity and causing a 

measurable increase in surface erosion and delivered sediment. Recovery from measurable surface 

erosion and subsequent delivered sediment would take approximately 5–6 years (USFS 1981). 

Organic Matter (Fine Organic Matter and CWD) 

Direct and Indirect Effects—A wildfire would result in loss of organic matter, which would 

adversely affect soil productivity and water quality. Surface organic matter, including fine organic 

matter and coarse woody debris (CWD), can be expected to increase as organic materials accumulate 

on the soil surface. 

 Conclusion—The continued accumulation of organic matter on the forest floor would 

contribute to increased ground fuel loads, leading to increased fire severity and intensity during a fire 

event. Based on fire return intervals stated earlier, the loss of surface organic matter and CWD would 

have short-term adverse effects on both soil productivity and water quality because organic matter 

and CWD are essential elements for both soil fertility and ground cover. 

Cumulative Effects—A loss of organic matter would adversely affect long-term soil 

productivity. Surface organic matter can be expected to increase as organic materials accumulate on 

the soil surface. Referring to the earlier discussion of direct and indirect effects for detrimental 

disturbance, areas within a wildfire that are subjected to moderate fire intensity would have at least 

40 percent of the affected area where all surface litter and humus would be consumed and would 

likely fall below the 50 percent desired condition for fine organic matter (USFS 1981). Under the 
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3-156 Chapter 3: Affected Environment and Environmental Consequences

moderate intensity scenario, it can be expected that some passive crown fire would also occur, leaving 

pockets of scorched trees and shrubs. Within several months, a thin layer of needle cast and leaf fall 

from scorched trees would begin to increase the percent of organic matter in the affected areas 

(Pannkuk and Robichaud 2003). Fires short-circuit the decomposition pathway, rapidly oxidizing 

organic matter and releasing available nutrients to plants and soil organisms. When organic matter 

burns, essential nutrients can be transferred to the atmosphere through volatilization and ash 

convection (Raison et al. 1985). 

Nutrients may also be lost following fire due to leaching (Miller et al. 2006). Some nutrients are 

returned relatively quickly by terrestrial cycling pathways. Compared to the pre-burn condition, a 

large reduction in the organic matter covering the soil would reduce the insulating effect this layer has 

on soil temperature. Under a reduced organic layer, soils experience greater temperature extremes. 

Soil temperatures may be elevated for months or years, depending on the degree of organic matter 

consumed by a wildfire (Debano et al. 2005). Such changes in the soil temperature regime would 

affect rates of biological activity in the soil, resulting in altered nutrient cycling regimes. 

 Conclusion. There would be a higher risk of wildland fire occurrence because no treatments 

would be implemented to reduce fuel loading, leading to long-term adverse effects on soil 

productivity in the areas affected by uncontrolled wildfire. Recovery from measurable surface erosion 

and subsequent delivered sediment would take approximately 5–6 years (USFS 1981), but full 

recovery of the organic fraction of ground cover would take decades. The amount of CWD, as a result 

of fire, would begin to increase due to snag fall and would further increase total fuel loads. 

3.6.5.2 Alternative B: Proposed Action 

By following the Standards and Guidelines contained in the Klamath LRMP, and staying at or 

below the disturbance thresholds (described in Section 1.5.6 of the Soils Resource Report), there 

would be a low risk that soil productivity would be impaired. Alternative B proposes a moderate 

amount of mechanical treatments, so there would be a measurable amount of ground disturbance from 

equipment, skid trails, and landings. A combination of soil protection measures, normal erosion 

control, and conduct of logging timber sale contract provisions, are expected to provide adequate soil 

protection so that productivity is maintained. 

Soil Cover 

Direct and Indirect Effects—It is difficult to accurately predict treatment effects on 

effective ground cover and is reliant on professional experience of the observer, and available postthinning monitoring in similar settings. Thinning operations would likely increase activity fuels and 

effective ground cover, while pile burning and underburning have the greatest potential to reduce soil 

cover. Mastication would increase soil cover as materials are broadcast away from the equipment. 

Post-activity monitoring (from 1998 to 2004) on various treatments (prescribed fire, mastication, and 

handpiling with pile burning on the Klamath National Forest had an average percent ground cover 

ranging between 45 and 96 percent, with an overall average of 79 percent (Laurent 2007). Present 

percent soil cover average for all treatment units evaluated in the Eddy Gulch LSR Project 

Assessment Area is 72 percent. Comparing this value to the 79 percent average for previously 

monitored areas on the Klamath National Forest, one could reasonably expect soil cover to remain 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.6 – Soils and Geology 3-157

static or slightly increase (due to needle cast and leaf fall) for the mechanically treated units that will 

also be underburned. 

Presently, M Units 19 (cable), 21 (cable and tractor), 24 (cable), 35, and 36 fall well below the 

70 percent desired ground cover standard and would likely see further reductions. Additionally, 

M Units 3, 4 (cable and tractor), 15 (cable and tractor), 17 (cable), 23, 38 (cable), 52, 54, and 65 are 

border-line and would likely fall below the 70–80 percent standard after treatment. For the FRZs, 

especially those areas that are to be masticated, percent ground cover would likely increase. A 2001 

masticated plantation in the Shadow Creek area averaged 88 percent ground cover after completion 

(Laurent 2007). Because of the size and landscape diversity of the underburn-only treatment units (the 

prescribed burn units [Rx Units]), the introduction of low-intensity prescribed fire would create a 

burn mosaic of variable ground cover percentages. Overall, the entire Assessment Area would meet or 

exceed ground cover standards. Ground cover in all treatment units would recover quickly as leaf fall 

and needle cast contribute to the litter layer. A reduction in effective ground cover would increase the 

risk of erosion in affected areas. The amount and type of erosion depends on the character of the area. 

For example, patches of ground cover across a large area would be more effective at intercepting 

surface water than large areas devoid of cover. 

 Conclusion. Treatment activities would result in short-term localized negligible adverse 

effects on soil cover because the Proposed Action is designed to limit or restrict ground disturbance. 

This is particularly true with the use of prescribed fire because it is used under a more controlled 

environment, lessening the probability of higher intensity burns. The effects of wildland fire, on the 

other hand, would create long-term adverse effects on soil productivity and water quality due to the 

immediate and substantial loss of soil cover, causing a measurable increase in surface erosion and 

delivered sediment. 

Cumulative Effects—A reduction in ground cover, as a result of the proposed treatments, 

would likely be short-lived because nearby overstory trees will remain intact. Over time, litter from 

trees and shrubs would contribute to the development of effective ground cover in bare areas. A 

wildfire entering a treated area would result in a greater reduction in ground cover than the proposed 

treatments alone. See the soil cover discussion under Alternative A above. 

 Conclusion. Effects on soil cover related to the Proposed Action would be significantly 

reduced in less than 5 years, with the exception of some of the treatment units mentioned in the earlier 

narrative, where the effects would be long term but localized and negligible. 

Detrimental Disturbance (Detrimental Compaction and Detrimental Soil Displacement) 

Direct and Indirect Effects—

 Implementation of the Proposed Action would not significantly increase detrimental 

disturbance—The Eddy Gulch LSR Project includes project design criteria and other soil protection 

measures to minimize detrimental soil compaction and detrimental displacement. However, the use of 

heavy ground-based equipment and frequent stand entries would increase the potential for soil 

compaction (Powers 2002). Compacted and heavily disturbed ground can cause soil productivity to 

decline over time (Grigal 2000). Recent research suggests however, that compaction does not 

necessarily lead to productivity declines (Gomez et al. 2002; Powers et al. 2005). These studies show 

that in California’s Mediterranean climate, the effects of compaction are dependent on soil texture. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-158 Chapter 3: Affected Environment and Environmental Consequences

The studies show that compaction of sandy loam and coarser textured soils can actually increase 

productivity because compaction increases available water holding capacity. Compaction in loamy 

soils can have a neutral or insignificant effect, but in clayey soils, compaction has a detrimental 

effect. Since the project soils are mostly gravelly sandy loams to clay loams, the applicable standard 

limiting main skid trails and landings to 15 percent of an area are relatively conservative in protecting 

the soils from productivity loss due to compaction. 

For any mechanical harvest, the extent and degree of detrimental soil disturbance (especially 

compaction) depends on site-specific soil conditions such as texture and stoniness, moisture content 

at the time of operations, and harvest equipment features. For the Eddy Gulch LSR Project, the 

detrimental disturbance threshold is 15 percent. If main skid trails and landings occupy greater than 

15 percent of a treatment unit, then the unit exceeds the detrimental disturbance threshold. As part of 

the project design, units that are predicted to exceed 15 percent would be reevaluated after treatment. 

Currently, the following M Units are at or exceed the 15 percent threshold standard: 15, 17, 21, 22, 

30, and 80. Some compaction (reduced soil porosity) would occur in other areas where equipment 

makes one or two passes, but this increased compaction would not exceed threshold values (Powers 

2002). Subsoiling has been shown to be an effective method of reducing compaction and restoring 

porosity to the soil (Andrus and Froehlich 1983; Kolka and Smidt 2004). If post-project monitoring 

shows that these units exceed the detrimental disturbance threshold due to compaction, then 

subsoiling of their main skid trails would be done. Mechanical ground disturbance in the remaining 

treatment units has a high probability of not significantly impairing soil productivity because only 

those areas with slopes generally less than 35 percent would be treated using ground-based 

equipment. 

 Conclusion. Mechanical treatments would result in short-term site-specific adverse 

negligible effects on the soil resource as a result of heavy equipment operations outside of existing 

skid trails and landings. This action alternative will protect long-term soil productivity by measurably 

reducing fire severity through the reduction of existing fuel loading. 

 Cumulative Effects—Long-term soil productivity would be maintained with implementation 

of the Proposed Action. With the implementation of project design criteria, especially the use of 

existing skid trails and landings, all treatment units are expected to remain at existing levels. 

Conclusion. Through the use of existing skid trails and landings (especially when landings 

are existing road surfaces), total affected area would remain at background levels, and overall adverse 

effects would be long term but localized and negligible.

Organic Matter (Fine Organic Matter and CWD) 

Direct and Indirect Effects—It can be difficult to accurately predict treatment effects on 

surface fine organic matter or CWD, and is reliant on the experience of the observer, and available 

post-harvest evaluations in similar settings. Mastication treatments are expected to increase cover of 

organic matter as masticated debris is broadcast away from the equipment. Past soil cover monitoring 

on the Forest (Laurent 2007) showed that mastication resulted in 79 to 99 percent total organic soil 

cover and averaged 94 percent. Underburn treatments may reduce organic matter, but burning is 

expected to occur under prescribed conditions that would not result in complete combustion of the 

duff and litter layers, or measurable reduction in existing CWD. Past soil cover monitoring of 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.6 – Soils and Geology 3-159

underburning (Laurent 2007) under forested stands showed that underburning resulted in 56 to 

98 percent total organic soil cover and averaged 84 percent. Within underburned areas not all of the 

surface materials are burned. In some monitored stands 31 to 65 percent of the area within the burned 

boundaries remained unburned. Pile burning would decrease surface fine organic matter locally, but 

over time, adjacent trees and shrubs would provide litter to cover the burned area. Handpiling and 

subsequent burning of the piles retained on average 86 percent soil cover (Laurent 2007). In some 

cases 44 percent soil cover was retained within the burned pile areas due to incomplete consumption 

of the larger material within the piles. Fire line construction around prescribed burn areas and hand 

piles would create bare soil conditions. Cover of fine organic matter is expected to remain within 

acceptable threshold values. Local reductions in surface fine organic matter would have local minor, 

short term effects on soil temperature. Large reductions in organic matter would result in greater 

temperature extremes in the soil, as previously discussed earlier. Removal of canopy cover may result 

in increased temperatures at the forest floor, as well as reduced moisture content of surface fine 

organic matter (Erickson et al. 1985). 

 Conclusion. Implementation of the Proposed Action would result in short-term negligible 

adverse effects on the soil resource due to localized removal of organic matter by heavy equipment 

and prescribed fire. Without implementation, continued accumulation of organic matter on the forest 

floor would contribute to increased ground fuel loads, which may lead to increased fire severity 

during a fire event. Based on the fire return intervals stated earlier, the loss of surface organic matter 

and CWD would have short-term adverse effects on both soil productivity and water quality because 

organic matter and CWD are essential for both soil fertility and ground cover. 

Cumulative Effects—Loss of organic matter would adversely affect long-term soil 

productivity. Following implementation of the proposed treatments, organic matter on the soil surface 

would decrease in some areas due to mechanical displacement or consumption by fire, while organic 

matter would increase in other areas due to additions of masticated material, needle and leaf cast, and 

some increase in CWD due to the collapse of standing dead or dying trees. This may result in greater 

heterogeneity (diversity) of the forest floor. Patches of organic matter would provide habitat for soil 

invertebrates and microorganisms, and patches of bare areas would be susceptible to local erosion. 

Increases in woody materials on the forest floor due to mastication may cause short-term changes in 

decomposition, carbon, and nutrient dynamics in affected areas. Microorganisms that decompose 

wood would immobilize nitrogen and other nutrients while decaying the woody material. As the wood 

decomposes, those nutrients would be released and made available to plants and other organisms 

(Swift 1977). Microclimate changes at the forest floor (due to reduced canopy cover) can alter rates of 

decomposition and nutrient turnover in the surface fine organic matter of harvested stands (Erickson 

et al. 1985). 

 Conclusion. The effects of mechanical treatment and prescribed fire on the organic matter 

component would have localized minor to negligible, adverse effects on the soil resource due to the 

continuous recruitment of organic matter from needle cast, leaf fall, and snags falling to the ground. 

This action alternative will protect long-term soil productivity by measurably reducing fire severity 

through the reduction of existing fuel loading. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-160 Chapter 3: Affected Environment and Environmental Consequences

3.6.5.3 Alternative C: No New Temporary Roads Constructed 

Alternative C would have a moderate amount of mechanical treatments, so there would be a 

measurable amount of ground disturbance from equipment, skid trails, and landings. A combination 

of soil protection measures in the project design criteria and normal erosion control measures are 

expected to provide adequate soil protection so that productivity is maintained. By following the 

standards contained in the Klamath LRMP, and staying at or below the disturbance thresholds, there 

would be a low risk that soil productivity would be impaired. 

Soil Cover 

Direct and Indirect Effects—Implementation of this alternative would treat slightly less 

acres than Alternative B by mechanical methods, but the overall fuel reduction would be similar. 

 Conclusion. Treatment activities would have localized short-term negligible effects on soil 

cover because, as with Alternative B, Alternative C is designed to limit or restrict ground disturbance. 

This is particularly true with the use of prescribed fire because it is used under a more controlled 

environment, lessening the probability of higher intensity burns. The effects of wildfire, on the other 

hand, would create long-term adverse effects on soil productivity and water quality due to the 

immediate and substantial loss of soil cover, causing a measurable increase in surface erosion and 

delivered sediment. 

Cumulative Effects—A reduction in ground cover as a result of the proposed treatments is 

likely to be short-lived because nearby overstory trees would remain intact. Over time, litter from 

trees and shrubs would contribute to the development of effective ground cover in bare areas. A 

wildfire entering a treated area would result in a greater reduction in ground cover than the proposed 

treatments alone (see the soil cover discussion under Alternative A). 

 Conclusion. Effects on soil cover related to the Alternative C would be significantly reduced 

in less than five years, with the exception of some of the treatment units mentioned in the earlier 

discussion in Alternative B, where the effects would be long term but localized and negligible.

Detrimental Disturbance (Detrimental Compaction and Detrimental Soil Displacement) 

Direct and Indirect Effects—Implementation of Alternative C would not significantly 

increase detrimental disturbance. This alternative would treat fewer acres by cable yarding because 

new temporary roads would not be constructed, resulting in less potential for disturbance in the form 

of soil compaction and measurable soil displacement. The same number of tractor yarding acres 

would occur. The post-project soil compaction monitoring and potential subsoiling of units estimated 

to exceed the detrimental disturbance threshold would occur as described under Alternative B. 

 Conclusion. Mechanical treatments would result in site-specific short-term negligible 

adverse effects on the soil resource as a result of heavy equipment operations outside of existing skid 

trails and landings. Detrimental disturbance is estimated to be approximately 5–8 percent less than 

under Alternative B. 

Cumulative Effects—Long-term soil productivity would be maintained with implementation 

of Alternative C. With the implementation of project design criteria, especially the use of existing 

skid trails and landings, all treatment units are expected to remain at existing levels. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.6 – Soils and Geology 3-161

 Conclusion. Through the use of existing skid trails and landings (especially when landings 

are existing road surfaces), total affected area would remain at background levels, and overall adverse 

effects would be long term but localized and negligible.

Organic Matter 

Direct and Indirect—Implementation of this alternative would have similar effects on soil 

productivity and water quality as discussed under Alternative B. 

 Conclusion. Implementation of Alternative C would result in short-term negligible adverse 

effects on the soil resource due to localized removal of organic matter by heavy equipment and 

prescribed fire. Without implementation, continued accumulation of organic matter on the forest floor 

would contribute to increased ground fuel loads, which would lead to increased fire severity during a 

fire event. Based on fire-return intervals stated in Alternative A, the loss of surface organic matter and 

CWD would have short-term adverse effects on both soil productivity and water quality because 

organic matter and CWD are essential for both soil fertility and surface ground cover. 

Cumulative Effects—Implementation of this alternative would have similar effects as 

discussed under Alternative B. 

 Conclusion. The effects of mechanical treatment and prescribed fire on the organic matter 

component would have localized minor to negligible adverse effects on the soil resource due to the 

continuous recruitment of organic matter from needle cast, leaf fall, and snags falling to the ground. 

This action alternative will protect long-term soil productivity by measurably reducing fire severity 

through the reduction of existing fuel loading. 

3.6.6 Affected Environment (Existing Conditions): Geology 

Two geologic formations (distinct accreted terrains) comprise the vast majority of the Assessment 

Area. The Western Paleozoic and Triassic Belt is a complex of mostly meta-sedimentary argillites and 

phyllites with interbedded cherts. This formation also includes metavolcanic rocks, blueschist facies 

(low-temperature, high-pressure metasediments), slightly metamorphosed volcanic breccias, and 

small bodies of peridotite in the complex. This formation occurs in the Assessment Area west of 

Black Bear Summit in the Black Bear Creek / Argus Gulch area. The argillite component of this 

formation is a relatively weak rock, which can pose slope stability risks. This formation also occurs 

just north of the divide between the North and South Forks in Eddy Gulch and Whites Gulch. 

The adjacent Stuart Fork Formation is dominated by phyllites and schists with varying degrees of 

structural competence and fracture spacing from massive boulder-sized material to intensely sheared 

and fractured. The contact between the Stuart Fork Formation and the Western Paleozoic and Triassic 

Belt is marked by numerous springs and seeps. The Stuart Fork Formation occurs in upper Crawford 

Creek, Shadow Creek, and Sixmile Creek. Where highly sheared and weathered, these rocks can pose 

significant landslide risk. 

Serpentinized peridotite is found in lower Crawford Creek and in small, scattered pockets in the 

Western Paleozoic and Triassic Belt. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-162 Chapter 3: Affected Environment and Environmental Consequences

Abrams mica schist occurs in a small pocket south of Grouse Point. Hydration of mica minerals 

during weathering causes expansion and weakening of the rock’s internal structure. This rock type is 

very weak and can be broken apart by hand. This structural incompetence also poses slope stability 

problems, but its occurrence is very limited in the Assessment Area. 

A small pocket of dioritic rocks occurs in Callahan Gulch. Elsewhere, granodiorite occurs in 

Upper South Russian Creek, grading to granite in the Russian Peak Wilderness. Deeply weathered 

rocks of this type form very noncohesive soils (typically silty sand soils) that tend to produce 

shallow-seated failures such as debris slides and debris torrents when saturated. In 1996, a debris 

torrent originating in granitic rocks of upper South Russian Creek scoured the channel down to its 

confluence with the North Fork. The point of origin of this debris torrent was well above the project 

Assessment Area and near the Russian Peak Wilderness boundary. Only roadside fuel reduction and 

underburning are proposed in the South Russian Creek watershed, and those are in the lower reaches 

of the watershed on mostly nongranitic geology. 

Landslides are the major geologic hazard in the Assessment Area, and their occurrence is related 

to the structural competence of the underlying rocks, pore pressures of water in rocks and soil, and 

triggering mechanisms. Triggering mechanisms are usually one or more of the following: (1) seismic 

activity, (2) removal of toe-slope buttressing, and (3) saturation by major rainfall/runoff events. 

Active landslides (active within the last 400 years) are scattered widely throughout the 

Assessment Area. The largest is approximately 40 acres in size and occurs in the west branch of 

Shadow Creek. 

Toe zones of old slides represent a landform with high risk for subsequent landslides. Toe-zone 

landforms are clustered in Argus Gulch and upper Eddy Gulch but are mostly absent elsewhere in the 

Assessment Area. All mapped toe zones are in areas proposed for underburning only. No road 

construction or timber harvest is proposed on toe-zone areas. 

Recently active landslides were encountered in upper Eddy Gulch and along the Grouse Point 

Fault in Crawford Creek. Another very small (0.10 acre) slump was located along National Forest 

System (NFS) road 39N20 in lower Shadow Creek. 

The Klamath National Forest CWE model includes a component that estimates potential sediment 

delivery to streams from management-induced landslides. Currently, only two 7th-field watersheds 

with significant areas in proposed treatment units have GEO risk ratios in a moderately elevated 

range: Upper North Russian Creek (risk ratio = 0.87) and Eddy Gulch (0.79). Two other 7th-field 

watersheds have elevated risk ratios (Indian Creek, 0.87 and Kanaka Olsen, 1.53), but those drainages 

are scheduled for only very minor amounts of underburning that will not affect their risk ratios. 

Areas With Watershed Concerns (AWWC) were identified in the Watershed Analyses covering 

the Assessment Area. Black Bear Creek watershed west of the main channel of Black Bear Creek was 

identified in the Lower South Fork Salmon Watershed Analysis (USFS 1997) as an AWWC in 1995. 

Substantial recovery has occurred in the intervening years as evidenced by low CWE risk ratios for 

all components. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.6 – Soils and Geology 3-163

Limestone Bluffs Research Natural Area occurs along the South Fork Salmon River between 

Cecilville and the Matthews Creek campground. The majority of this outcropping occurs south of the 

river in the St. Claire and French Creek drainages. The nearest project activity is a Fuel Reduction 

Zone (FRZ) more than 0.25 mile from the Bluffs. 

Airborne asbestos can be introduced into the air by road construction, reconstruction, or 

maintenance on roads underlain by ultramafic rock, or the development of rock quarries in ultramafic 

rock and placement of such aggregate on roads. Ultramafic rock is concentrated in the southwest 

corner of the Assessment Area. The community of Cecilville is located in this general area but is at 

least 2 miles from the nearest project activity. 

No domestic water wells are known to exist in or near the project boundary. There are numerous 

springs in the Assessment Area. Seeps and springs are especially common along both sides of the 

divide between the North and South Forks of the Salmon River, above 5,000 feet in the vicinity of the 

Eddy Gulch Lookout. Campbell Springs is the most prominent of these springs, but many others exist 

in this zone. 

3.6.7 Environmental Consequences: Geology 

3.6.7.1 Alternative A: No Action 

Geology Program Goals. The no-action alternative has a high probability of meeting all of the 

five geologic goals. 

Direct and Indirect Effects—Landslide Risk—Under this alternative, there would be no 

new soil or vegetation disturbances, and consequently, no direct or associated indirect effects from 

project-related activities. With no action taken, the existing risk of road-related landsliding would 

remain the same, and the adverse effects of past harvest and fire would decrease over time as 

vegetation continues to grow. In the long term, the risk of a large stand-replacing fire would continue 

to increase. Fire modeling (refer to Section 3.3 or the Fuels and Air Quality Resource Report) 

indicates that the effects of failing to reduce this risk can potentially result in significant increases in 

landslide-related sediment. Under wildfire conditions, adverse effects on geologic resources from 

high fire severity would be compounded by the impacts resulting from suppression equipment 

accessing the area and fireline construction under demanding circumstances. 

Failing to reduce fuel loads in the Assessment Area would result in continued high risk of standreplacing wildfire and the accompanying loss of rooting strength on unstable slopes. This, in turn, 

would increase the potential for accelerated sediment delivery to streams. A dense network of tree 

roots can add to the shear strength of potentially unstable slopes. This effect is limited to slopes prone 

to shallow-seated debris slide slope failures. Such slopes typically have thin soil profiles and 

relatively noncohesive soils. Following stand-replacing wildfire, the root network begins to decay, 

leading to a condition of minimum shear strength a few years following the fire. The direct effect of 

this process is the loss of soil productivity at the site of the landslide and sediment delivery to 

immediately adjacent stream channels. Because shallow-seated debris slides or debris flows can 

transport landslide debris and sediment long distances down slope, such processes can profoundly 

affect sediment transport dynamics, channel stability, and the abundance and quality of aquatic 

habitat. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-164 Chapter 3: Affected Environment and Environmental Consequences

Cumulative Effects—Landslide Risk—Existing cumulative effects are entirely the result of 

previous disturbances such as road construction, timber harvest, and mining. These are discussed and 

displayed under Alternative B below. Adverse cumulative effects could result from failure to reduce 

the risk of stand-replacing wildfire. The CWE analysis of the results of wildfire behavior modeling 

shows that wildfire under existing fuel conditions clearly has the potential to produce detectable 

adverse cumulative effects. 

Failing to reduce frequency of stand-replacing fires would increase landslide potential through 

loss of rooting strength, loss of vegetative soil water withdrawal, and creation of hydrophobic soils. 

Wildfire-related soil disturbance which, when added to that created by past actions, may exceed 

disturbance thresholds established to prevent long-term adverse changes to rates of landslide 

initiation. 

A CWE model run was generated from a modeled wildfire, with ignition in lower Shadow Creek. 

A marked increase in the GEO risk ratio is apparent for Shadow Creek, with the wildfire scenario 

pushing it above the inference point of 1.0. The amount of increase would be large (0.41 to 1.07), but 

the amount by which the fire exceeds threshold is not great. This suggests that effects from increased 

potential for landslide-generated sediment are likely to be detectable but not of such extent or severity 

as to significantly degrade water quality or aquatic habitat. 

Overall, cumulative effects on landslide-generated sediment delivery are expected to be minor to 

moderate, depending on the actual location and severity of wildfire. Were such effects to occur, they 

would be expected to persist for a decade or more until delivered sediments move through the stream 

network and landslide scars slowly revegetate. 

Conclusion. Landslide potential associated with existing roads would remain unchanged, but 

that associated with previous timber harvest would continue to decline as revegetation progresses. 

The no-action alternative, with the included modeled wildfire scenario, is likely to produce minor to 

moderate effects on rates of landslide initiation, water quality, and aquatic habitat. The exact 

magnitude of effects is wholly dependent on the spatial pattern of high-intensity fire. Were the entire 

7,200 acres of predicted wildfire to occur mostly within one 7th-field watershed, effects would be 

concentrated within that drainage. Otherwise, effects would be substantially less because the effects 

would be dispersed across multiple drainages. Recovery of rooting strength and natural soil moisture 

regimes can take a decade or more in areas of high fire intensity. Areas of lesser fire intensity are 

likely to recover within a decade. 

3.6.7.2 Alternative B: Proposed Action 

Geology Program Goals. Alternative B has a high probability of meeting all of five geologic 

objectives at a high level, provided geological RPMs are applied. 

Direct and Indirect Effects—Landslide Risk—A dense network of tree roots can add to the 

shear strength of potentially unstable slopes. This effect is limited to slopes prone to shallow-seated 

debris slide slope failures. Such slopes typically have thin soil profiles and relatively noncohesive 

soils. Thinning stands can result in a short-term decline in root shear strength as the roots of removed 

trees begin to decay, leading to a condition of minimum shear strength a few years following a fire. 

Slope failures can also originate in over-steepened fill slopes of roads and landings where they are 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.6 – Soils and Geology 3-165

situated on intrinsically unstable slopes. The direct effect of this process is the loss of soil 

productivity at the site of the landslide and sediment delivery to immediately adjacent stream 

channels. 

All fuel reduction treatments and thinning prescriptions leave substantial live vegetation, 

especially larger trees with deep, extensive root systems. Vegetative treatments are unlikely to 

significantly reduce the contribution of roots to soil shear strength or lessen soil water withdrawal 

from evapotranspiration. Proposed road alignments for new temporary roads are in stable, upper slope 

locations with no stream crossings. For these reasons, project effects from Alternative B are expected 

to be negligible relative to landslide risk and thus landslide-generated sediment delivery to streams. 

Direct and Indirect Effects by Project Activity—Direct and indirect effects associated with 

project activities are described below. It is assumed that geologic RPMs are implemented in all 

applicable situations. Refer to Appendix G of the Geology Report for further information on direct 

and indirect effects by management activity. 

Thinning—931 acres. These activities will result in a very small short-term decrease in root 

support, but most likely will not cause an increase landslide rates. In the longer term, stand vigor will 

be increased, and root support re-established. 

Tractor Yarding—361 acres. By restricting tractors to slopes less than 35 percent slope, and 

controlling skid trail locations (avoiding full-bench trails), ground disturbance on unstable lands 

would be avoided, and these activities would likely not increase landslide rates. 

Cable Yarding—570 acres. Ground disturbances associated with cable yarding will be 

excluded from unstable areas and, as a result, would not increase landslide rates. 

Construction of New Temporary Roads / Closure—1.03 miles. The new temporary roads 

would be closed upon project completion. There would be a reduction in root support and local 

evapotranspiration associated with clearing. Road segments are short, cross no major drainages or wet 

areas, and are generally located near ridgetops. All new temporary road alignments were inspected for 

landslide potential in the field and landslide potential evaluated. 

Use of Former Logging Access Routes / Closure—0.98 mile. Former logging access routes 

in varying states of revegetation would be reused. There would be a reduction in root support and 

local evapotranspiration, particularly where older vegetation is removed. All of these routes were 

inspected for landslide potential in the field and landslide potential evaluated. Potential for roadrelated landsliding is considered to be very low. Closure following use would eliminate any preexisting drainage problems and remove fill placed in draws, thereby restoring hydrologic conditions 

and reducing landslide risk. 

Use of Short Spurs—340 feet. The spurs proposed for use were inspected for landslide 

potential in the field and landslide potential evaluated. Since spurs are, in most cases, on gentle 

ground and near ridge crests, the risk of road-related landsliding is considered to be very low. Closure 

following use would reestablish hydrologic conditions that existed prior to project implementation 

and allow revegetation to commence. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-166 Chapter 3: Affected Environment and Environmental Consequences

 Road Maintenance. All haul roads will be maintained. This action would decrease the 

potential for road-related landslides, by better controlling road surface drainage. 

 Landings. Approximately 73 existing landings would be used for the thinning units. All are 

associated with tractor yarding. Cable yarding would use the road prism for “hot decking” of logs 

such that no additional landings are proposed for cable units. (Basically, hot decking occurs when the 

running surface of the road is not wide enough for both the cable yarder and the logs. The logs have 

to be moved out of the way so another load can be brought to the road, where trucks haul them 

away—this eliminates the need for landing construction because the road prism itself serves as the 

landing.) The total area of the existing 73 landings is estimated to cover 18 acres over the entire 

Assessment Area. Landing locations are mostly along existing roads and were used in previous 

harvest operations. Locations have been placed on the project GIS coverage and are shown in the 

Logging Systems Report contained in the project record. No landings are proposed in Riparian 

Reserves or other sensitive lands. 

Landing size could vary according to such factors as local conditions and the amount of timber 

volume being handled, but none are expected to exceed 0.5 acre. By limiting landings to gentler 

slopes, minimizing cut heights, and constructing stable fills, applying timber sale contract clause 

CT 6.602 Special Erosion Prevention and Control (May 4, 1998), landslides associated with landings 

are not anticipated. 

 Mastication in FRZs. Alternative B includes mechanical mastication of fuels on flatter areas 

(under 45 percent) along ridgetops. This is estimated to occur on 3,184 acres. The use of small, lowground-pressure equipment will limit soil disturbance and compaction. Residual soil cover will be left 

following treatment, which would minimize effects of soil disturbance. The ridgetop location of 

treatments will limit adverse effects on Riparian Reserves. 

 Hand Piling and Burning. Hand piling would be applied to steeper portions of the 16 miles 

of roadside treatment that occur outside of FRZs and Rx Units. This treatment may also be applied as 

part of preparing underburn units. In areas currently supporting heavy fuels, this activity would 

greatly reduce the risk of high-severity fire. This is particularly true where accumulations of down 

saplings and poles are present. 

 Underburning. This is the dominant treatment proposed in this alternative. Underburning 

will occur in cable portions of thinning units (post-harvest) and in FRZs and Rx Units. Thinning, 

mastication, and hand thin/pile represent preparatory steps to allow the introduction of prescribed fire 

without catastrophic consequences. This activity would reduce the potential for stand-replacing 

wildfire. However, there is always some risk of local high-severity fire occurring during 

implementation of prescribed burns, and if this should occur on unstable areas, it could increase 

landslide potential. Application of geologic RPMs is expected to minimize the risk of high-severity 

fire in unstable areas. 

The direct and indirect effects of various management activities are summarized in Tables 3-42

and 3-43. The tables provide a brief description of the effect and an evaluation of its intensity, as 

previously defined. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.6 – Soils and Geology 3-167

Table 3-42. Direct effects of Alternative B on geologic resources and hazards. 

Management 

Activity Type of Direct Effect Intensity Determination 

Thinning Reduced vegetation density Negligible to minor. Remaining trees 

rapidly occupy available canopy and 

root space. 

Professional 

judgment / experience 

Tractor yarding Soil disturbance and 

compaction; loss of organic 

matter 

Negligible to minor. Tractor yarding 

limited to gentle slopes near ridgetops. 

RPMs require residual groundcover and 

erosion control on skid trails and 

landings. 

Professional 

judgment / experience 

Cable yarding Soil disturbance; erosion Negligible to minor. Limited soil 

disturbance. RPMs require residual soil 

cover and limit openings in Riparian 

Reserves. 

Professional 

judgment / experience 

Landings Cuts and fills Minor. Most landings pre-existing with 

no evident problems. Minimal cut and fill 

required as most landings are located 

adjacent to existing roads. 

Professional 

judgment / experience 

Mastication in FRZs Mechanical soil disturbance; 

possible small changes in 

slope hydrology; short term 

reduction in 

evapotranspiration 

Negligible to minor. Low-groundpressure equipment will be used and 

limited to 45 percent slopes. Mastication 

leaves considerable soil cover.

Professional 

judgment / experience 

New temporary road 

construction or use 

of former logging 

access routes 

Cuts and fills Minor. Very little construction proposed. 

All segments short. No segments on 

unstable slopes. All will be closed. 

Professional 

judgment / experience 

Road closure Pulling of fills, outsloping, 

rocking of crossings; 

stabilizing existing landslides 

Minor short-term effects of creating bare 

soil. RPMs require mulch or other soil 

cover and erosion control. Long-term 

beneficial effects. 

Professional 

judgment / experience 

Road maintenance Cleaning of culverts, blading, 

ditch clearing 

Negligible. Beneficial effects. Professional 

judgment / experience 

Hand piling and 

burning 

Reduction of organic 

material, local areas of high 

intensity fire, loss of fine 

organic matter 

Negligible. Insignificant ground 

disturbance. 

Professional 

judgment / experience 

Underburning Reduction of fine organic 

material; local hot fire; loss of 

fine organic matter 

Negligible to minor. Burn prescription 

will include measures for maintenance 

of canopy, soil cover, and root density 

where slope stability is a concern. 

Professional 

judgment / experience 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-168 Chapter 3: Affected Environment and Environmental Consequences

Table 3-43. Indirect effects of Alternative B on geologic resources and hazards. 

Management 

Activity Type of Indirect Effect Intensity Determination 

Thinning Minor short-term reduction in 

root support and 

evapotranspiration; minor 

increased landslide potential. 

Negligible to minor. Remaining trees 

rapidly occupy available canopy and root 

space 

Professional 

judgment / experience 

Tractor yarding Changes in soil permeability and 

runoff patterns, local changes in 

mass balance; potential to 

channel water and increase 

landslide potential. 

Negligible to minor. Tractor yarding limited 

to gentle slopes near ridgetops. RPMs 

require residual groundcover and erosion 

control on skid trails and landings. No 

tractor yarding proposed on or near 

unstable slopes. 

Professional 

judgment / experience 

Cable yarding Local changes in soil 

permeability and channeling of 

water; potential to increase 

landslide potential. 

Negligible to minor. Limited soil 

disturbance. RPMs require residual soil 

cover and limit openings in Riparian 

Reserves. 

Professional 

judgment / experience 

Landings Large changes in slope 

hydrology; potential for fill and 

cut failure landsides. 

Minor. Most landings pre-existing with no 

evident problems. Minimal cut and fill 

required as most landings are located 

adjacent to existing roads. No landings 

proposed on or near unstable slopes. 

Professional 

judgment / experience 

Mastication in 

FRZs 

Soil compaction and reduction in 

evapotranspiration could 

produce increases in surface 

runoff, potentially generating 

sediment to streams. 

Negligible to minor. Low-ground-pressure 

equipment will be used and limited to 

45 percent slopes. Mastication leaves 

considerable soil cover. Tree canopy will 

be retained.

Professional 

judgment / experience 

New temporary 

road 

construction or 

use of former 

logging access 

routes and spurs 

Large changes in slope 

hydrology; potential for fill and 

cut failure landslides. 

Minor. Very little construction proposed. All 

segments short. No segments on unstable 

slopes. No road alignments intersect 

springs, seeps, or cross any stream 

channels. Special C-clause required for 

stabilization of cuts and fills. All will be 

closed. 

Professional 

judgment / experience 

Road closure Restoration of slope hydrologic 

patterns; large reduction in risk 

of stream crossing and fill 

failures; reduction in landslide 

failure. 

Minor short-term effects of creating bare 

soil. RPMs require mulch or other soil 

cover and erosion control. Long-term 

beneficial effects. 

Professional 

judgment / experience 

Road 

maintenance 

Reduction in potential for stream 

crossing fill failure. 

Negligible. Beneficial effects. Professional 

judgment / experience 

Hand piling and 

burning 

Reduction of fire risk. Negligible. Insignificant ground 

disturbance. Beneficial effects. 

Professional 

judgment / experience 

Underburning Reduction of fire risk; local 

increase in landslide potential 

where hot fire inadvertently 

occurs on unstable land. 

Negligible to minor. Burn prescription will 

include measures for maintenance of 

canopy, soil cover, and root density where 

slope stability is a concern. Critical areas 

will be reviewed for pretreatment of fuels 

where necessary to prevent flare ups. 

Professional 

judgment / experience 

Asbestos Hazard Associated with Roads and M Units. There are outcrops of ultramafic 

rock along some roads, and this rock type often contains asbestos. Table 3-44 lists such roads and 

identifies those that are closer than one mile to sensitive receptors (residences or campgrounds). 

Harvest units are similarly listed in the table. Listings are based on the Klamath National Forest 

bedrock coverage in the Klamath National Forest GIS library and supplemented by field survey. Also, 

see the Geology Report, Appendix I, for the report titled, “Naturally Occurring Asbestos in Eddy 

Gulch LSR Project.” 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.6 – Soils and Geology 3-169

Table 3-44. Locations of treatment units and roads underlain by ultramafic rocks. 

Road 

or Unit 

Sensitive 

Receptor 

Junction with 

Paved Road? Location 

FRZ 9 No N/A Lower portion of FRZ 9 south of unit M Unit 66. 

Rx Unit 4 No N/A Southern half of this Rx Unit along west branch of 

Crawford Creek. 

39N23 No 1C02 (South Fork Salmon 

Road) 

From Cecilville north to intersection of 38N17. 

FRZ 2 Black Bear Ranch N/A Small pockets of um west of M Unit 51. Um rocks 

prevalent vic. Blue Ridge Lookout. 

Rx Unit 1 Black Bear Ranch N/A Belt of um rocks underlies approximately 10% 

of unit. 

Cumulative Effects—Cumulative effects on geologic resources are gauged by evaluating 

GEO risk ratios produced by the CWE model. Input to the model for each treatment unit or road 

consists of physical attributes (slope gradient, soil type, bedrock type, and geomorphic terrain type) 

that are generally compiled from GIS coverages. The type of treatment or disturbance is also part of 

model input. Field assessments served to validate or upgrade mapped information and to arrive at a 

qualitative assessment of the potential impacts of the proposed treatment. The presence of indicators 

(such as nearby landslide features, abundant seeps and springs, structurally weak bedrock, hummocky 

slopes, irregular stream drainage patterns, or very steep slopes) would lead to a higher qualitative 

rating of the potential landslide risk. These ratings are also part of the input to the CWE model. 

GEO risk ratios for Alternative B are shown in Table 3-45. The column titled “Current” represents 

existing conditions. “Post-project” includes natural recovery of existing disturbances and the addition 

of project (Alternative B) disturbances. The last column includes effects of foreseeable future actions 

plus recovery projected out to 2021, the expected date of project completion. 

Only the Kanaka-Olsen watershed shows a risk ratio above 1.0 (GEO = 1.43), and that denotes 

the existing condition. Only 18 acres of FRZ treatment are proposed within the Kanaka-Olsen 

watershed. Note also that the risk ratio would improve steadily over the life of the project, going 

below threshold upon project completion. All other risk ratios would be quite low, and most are lower 

upon project completion than under existing conditions. 

Areas With Watershed Concerns. The GEO component of the CWE model indicates that 

under existing conditions, the potential for adverse CWE (landsliding) is highest in Kanaka-Olsen and 

Indian Creeks. Moderately high-risk ratios (0.8–0.9) are reported for Eddy Gulch and Upper North 

Russian Creek. In each instance, implementation of Alternative B, in combination with natural 

recovery processes, result in significantly reduced risk ratios upon project completion. The reason that 

the model predicts a drop in risk, despite the fact that the project involves thinning and some road 

activity, is as follows: (1) The model assumes that there will be no measurable increase in landslide 

potential associated with thinning; and (2) It assumes that opening and then closing currently 

abandoned roads will reduce landslide risk. This reduction in risk offsets the adverse effects of new 

temporary road construction. As a result, the mix of road activities results in a net reduction in 

CWE risk. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-170 Chapter 3: Affected Environment and Environmental Consequences

Table 3-45. Alternative B GEO risk ratio data from the CWE model run of October 20, 2008. 

Background 

Sediment 

Current 

Sediment 

Current Plus 

Future Actions 

Sediment Current Post-project 

Post-project 

Plus Future 

Actions 

Watershed Cubic Yard Risk Ratio 

7th-field watersheds 

Black Bear Creek 19,070 35,962 34,059 0.44 0.44 0.39 

Cody-Jennings Creek 20,997 41,734 39,171 0.49 0.49 0.43 

Crawford Creek 15,321 24,121 23,489 0.29 0.29 0.27 

Eddy Gulch 6,412 16,606 14,158 0.79 0.62 0.60 

Gooey-Ketchum Creek 6,289 12,537 12,525 0.50 0.50 0.50 

Gould-East Fork South 

Fork Salmon River 

5,963 11,375 11,343 0.45 0.45 0.45 

Indian Creek 9,818 26,995 22,831 0.87 0.87 0.66 

Kanaka-Olsen Creek 18,606 75,429 51,933 1.53 1.43 0.90 

Lower North Russian 

Creek 

6,898 13,443 12,530 0.47 0.41 0.41 

Lower South Russian 

Creek 

3,424 7,189 5,773 0.55 0.36 0.34 

Matthews Creek 8,229 15,891 15,797 0.47 0.47 0.46 

Robinson-Rattlesnake 

Creek 

7,621 12,761 12,345 0.34 0.32 0.31 

Shadow Creek 10,437 18,971 18,963 0.41 0.41 0.41 

Sixmile Creek 7,536 13,022 12,945 0.36 0.36 0.36 

Tanner-Jessups Creek 9,580 21,274 16,783 0.61 0.41 0.38 

Taylor Creek 8,440 11,847 11,009 0.20 0.15 0.15 

Timber-French Creek 12,872 20,849 20,625 0.31 0.31 0.30 

Upper North Russian 

Creek 

4,959 13,610 10,728 0.87 0.60 0.58 

Whites Gulch 11,581 19,662 15,439 0.35 0.19 0.17 

5th-field watersheds 

North Fork Salmon 392,308 690,282 650,418 0.38 0.38 0.33 

South Fork Salmon 232,540 488,838 390,997 0.55 0.48 0.34 

Indian Creek and portions of Black Bear Creek are classified as AWWC. Reported risk ratios 

suggest that substantial recovery has occurred since these designations were made in the mid-1990s. 

The Kanaka-Olsen watershed meets screening criteria for AWWC status (GEO = 1.53). However, 

Kanaka-Olsen is a watershed area of slopes draining directly to the North Fork Salmon River from 

both sides of the river and the watershed conditions driving the high-risk ratios stem from fire and 

other disturbances occurring on granodiorites on the north side of the river. As mentioned earlier, 

Indian Creek and Kanaka-Olsen are scheduled to receive very minor amounts of fuel reduction 

treatments only, with no road construction of any kind proposed. 

In summary, the potential for adverse CWE exists in some watersheds, due to existing road 

densities. New temporary road construction and opening of former logging access routes, followed by 

closure of all temporary roads/routes, results in a complex set of offsetting effects. The CWE model 

predicts a reduction in risk of adverse effects. However, there may be some small adverse effects 

associated with the reopening of former logging access routes that are in various states of 

revegetation. These adverse effects are not reflected by the model and would gradually recover as the 

closed roads revegetate.
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.6 – Soils and Geology 3-171

Conclusion. Alternatives B would likely not produce detectable adverse effects on rates of 

landslide initiation or landslide-generated sediment delivery to streams. Conversely, fuel treatments 

would likely reduce the potential for accelerated landslide rates by reducing the risk of standreplacing wildfire on potentially unstable slopes. This conclusion is based on (1) limited vegetation 

removal under fuel reduction and thin-from-below prescription; (2) limited road construction—all of 

it is on stable, upper slope locations; and (3) GEO risk ratios well below threshold with no increase 

during the life of the project. Direct, indirect, and cumulative effects on slope stability from project 

activities are expected to be negligible. 

3.6.7.3 Alternative C: No New Temporary Roads Constructed 

Geology Program Goals. Alternative C has a high probability of meeting all five geologic 

objectives at a high level, provided geological RPMs are applied. 

Direct and Indirect Effects—Landslide Risk—The direct and indirect effects of 

Alternative C are not significantly different from Alternative B. The effects of new temporary road 

construction are eliminated, but the effects of these were judged insignificant under Alternative B. 

Landslide risk from road construction is even less under Alternative C. The tables describing the 

direct and indirect effects of Alternative B (Tables 3-42 and 3-43 above) are equally applicable to 

Alternative C and, for the sake of brevity, are not repeated here. The elimination of fuels treatment on 

99 acres of potential thinning units and 822 acres of Rx Units poses some small but elevated risk of 

wildfire and its related impacts to landslide potential, as previously described. This increase in risk is 

judged to be negligible. 

Direct and Indirect Effects by Project Activity—The direct and indirect effects associated 

with Alternative C are described below. These descriptions highlight the differences between the two 

action alternatives. 

Thinning—832 acres. This is 99 acres less than Alternative B. 

Tractor Yarding—361 acres. No change from Alternative B. 

Cable Yarding—471 acres. No change from Alternative B. 

Construction of New Temporary Roads / Closure. None. 

Use of Former Logging Access Routes / Closure—0.98 mile. No change from 

Alternative B. 

Use of Short Spurs—340 feet. No change from Alternative B. 

Road Maintenance. No change from Alternative B. 

Landings. The number of tractor acres (361 acres) would be the same under Alternatives B 

and C, which means Alternative C also proposed to use approximately 73 existing landings. As with 

Alternative B, by limiting landings to gentler slopes, minimizing cut heights, and constructing stable 

fills, applying timber sale contract clause CT 6.602 Special Erosion Prevention and Control (May 4, 

1998), landslides associated with landings are not anticipated. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-172 Chapter 3: Affected Environment and Environmental Consequences

Mastication in FRZs. The type and extent of this treatment is unchanged from Alternative B. 

Hand Piling and Burning. Unchanged from Alternative B, so effects would be the same. 

Underburning. Total area of underburning is reduced by 822 acres under Alternative C. 

Application of geologic RPMs is expected to minimize the risk of high-severity fire in unstable areas. 

 Asbestos Hazard Associated With Roads and M Units. The description of the asbestos 

hazard is unchanged from Alternative B. 

Cumulative Effects—A CWE model run was conducted for Alternative C. The results were 

virtually identical to those for Alternative B. The reason for this is that the largest reduction in 

treatment acres under Alternative C occurred for Rx Units where the model assigns very low 

disturbance factors. The elimination of new temporary roads under Alternative C results in very slight 

reductions in predicted sediment yield in the Shadow Creek and Black Bear watersheds. The changes 

are so small that calculated risk ratios remain unchanged to two decimal places and are thus judged to 

be inconsequentially different from the risk ratios reported for Alternative B. As such, the cumulative 

effects discussion of Alternative B is equally applicable to Alternative C. Since the table of risk ratios 

is essentially identical between action alternatives, it is not repeated here. 

 Areas With Watershed Concerns. None of the temporary roads deleted under Alternative C 

were located within AWWCs. The discussion of this topic under Alternative B is equally applicable 

for Alternative C. 

Conclusion—The thinning and fuel treatments associated with Alternative C are not likely to 

cause landsliding due to the prescriptions required for unstable lands, low severity of prescribed fire, 

and the avoidance of unstable lands by temporary roads. It involves very little change in potential for 

adverse CWE. In fact, the landslide model indicates a slight reduction in this potential associated with 

the alternative. A small increase in wildfire potential and its related effects on slope stability results 

from reducing fuel treatment acres but this effect was judged to be negligible. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.7 – Botanical Resources and Noxious Weeds 3-173

3.7 Botanical Resources and Noxious Weeds _________________ 

3.7.1 Introduction 

This document describes the existing conditions of Threatened, Endangered, and Sensitive plant 

species, Other Species of Interest (formerly Survey and Manage species), and noxious weeds of 

record for the Eddy Gulch Late-Successional Reserve (LSR) Project. The environmental 

consequences section presents an analysis of the effects on botanical resources and noxious weeds 

that would result from taking no action (Alternative A: No Action) or from implementation of 

Alternative B: Proposed Action or Alternative C: No New Temporary Roads Constructed. The 

objective of the effects analysis is to 

 ensure that Forest Service actions do not contribute to loss of viability of any native or 

desired nonnative plant or animal species; 

 ensure that Forest Service actions do not hasten the federal listing of any species; and 

 ensure that Forest Service actions do not contribute to the introduction or spread of noxious 

weed species in the project area. 

3.7.2 Methodology: Botanical Resources 

3.7.2.1 Pre-Field Botanical Review 

A preliminary pre-field review was conducted to determine if the project Assessment Area is 

within the range of any federally listed Threatened, Endangered, or Proposed species, Forest Service 

Sensitive species, or Other Species of Interest (formerly known as the Survey and Manage “Manage 

Known List”), or if suitable habitat is present in the project Assessment Area. Surveys are not 

required for species for which suitable habitat is not present, or if the Assessment Area is outside the 

currently known range of the species. 

The pre-field review determined that the Eddy Gulch LSR Project Assessment Area is not within 

the range of, nor does it include habitat for, the four Klamath National Forest listed federal 

Endangered plant species, any of the Other Species of Interest, formerly known as the Survey and 

Manage “Manage Known List,” and there are no federally Threatened plant species on the forest. 

These species are not addressed further in this document. 

It was further determined that the project Assessment Area contains documented occurrences or 

potential suitable habitat for 23 of the 51 Forest Service Sensitive vascular and nonvascular plant 

species, and 6 Sensitive fungi species that were previously listed as “Survey and Manage Category B, 

Pre-Disturbance Surveys Not Practical or Category E, Status Undetermined.” Pre-disturbance surveys 

for the 6 Sensitive fungi are not required because it was determined that surveys would not be 

practical due to seasonal timing, difficulty in identification, or lack of habitat specificity, or because 

there was not adequate information available to conduct targeted field surveys (USDA, USDI 2004). 

Although no fungi surveys were conducted, an analysis of species habitat associations, presence of 

suitable or potential habitat, and a review of the literature on the effects to the Sensitive fungi were 

used to determine effects. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-174 Chapter 3: Affected Environment and Environmental Consequences

Of the 23 Forest Service Sensitive species, 10 Sensitive species were determined to not have 

potential to occur in the proposed treatment units. It was further determined that 4 of the 13 species 

(Cypripedium fasciculatum, Cypripedium montanum, Ptilidum californicum, and Hydrothyria venosa) 

were most likely to occur in the Assessment Area. The Assessment Area is within the range of the 

remaining 9 (of the 13) target Forest Service Sensitive species and potential suitable habitat appears 

to be present. To determine effects, the 9 species are assumed to be present in the Assessment Area. 

Table 3-46 is a summary of the 13 target Forest Service Sensitive species and assessment methods. 

Table 3-46. Summary of target Sensitive species and assessment methods, in the Eddy Gulch 

LSR Project Assessment Area. 

SPECIES CODE Assessment Method 

Vascular Species: 

Botrychium virginianum 

 Rattlesnake fern 

BOVI Assume presence 

Campanula wilkinsiana 

Wilkin’s harebell

CAWI8 Assume presence 

Chaenactis suffrutescens 

Shasta chaenactis 

CHSU Assume presence 

Cypripedium fasciculatum 

Clustered lady-slipper orchid 

CYFA Field survey 

Cypripedium montanum 

Mountain lady-slipper orchid 

CYMO2 Field survey 

Eriogonum hirtellum 

Klamath Mountain buckwheat 

ERHI7 Assume presence 

Eriogonum ursinum var. erubescens 

Blushing buckwheat 

ERURE Assume presence 

Eucephalis vialis 

Wayside aster 

EUVI8 Assume presence 

Minuartia stolonifera 

Scott Mountain sandwort 

MIST9 Assume presence 

Pedicularis howellii 

Howell’s lousewort 

PEHO Assume presence 

Smilax jamesii 

English Peak greenbriar 

SMJA Assume presence 

Bryophyte Species 

Ptilidium californicum 

 Pacific fuzzwort (liverwort) 

PTCA5 Field survey 

Lichen Species 

Hydrothyria venosa (syn. Peltigera hydrothyria)

Waterfan lichen 

HYVE7 Field survey 

Fungi Species 

Boletus pulcherrimus 

Red Pore bolete

BOPU4 

Cudonia monticola Mains CUMO2 

Dendrocollybia racemosa DERA5 

Phaeocollybia olivacea PHOL 

Sowerbyella rhenana SORH 

Tricholomopsis fulvescens TRFU3 

Assume presence 

(Fungi species: habitat evaluation 

only, no surveys required.) 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.7 – Botanical Resources and Noxious Weeds 3-175

3.7.2.2 Field Surveys 

Field surveys were conducted in August 2008 in the 1,887 acres of the Assessment Area 

identified as the highest potential habitat for the four species most likely to occur in the proposed 

treatment units (Cypripedium fasciculatum, Cypripedium montanum, Ptilidium californicum, and

Hydrothyria venosa). Following the field surveys, the locations of new and previously documented 

Forest Service Sensitive plant sites were added to the Geographic Information System (GIS) to 

analyze proximity of Sensitive plant sites to project treatment units to identify potential effects. 

Modifications were made to treatment units and incorporated in the final Proposed Action. See 

Resource Protection Measures in Section 2.9 of Chapter 2 of this final environmental impact 

statement (EIS). 

3.7.2.3 Intensity of Effects 

“Intensity” refers to the severity of effects or the degree to which the action may adversely or 

beneficially affect a resource. The intensity definitions used throughout this analysis are described 

below. 

Negligible. Effects would be at the lowest levels of detection and would have no appreciable 

effect on resources, values, or processes. 

Minor. Effects would be perceptible but slight and localized. 

Moderate. Effects would be readily apparent and widespread, and would result in a noticeable 

change to resources, values, or processes. 

Major. Effects would be readily apparent and widespread, and would result in a substantial 

alteration or loss of resources, values, or processes and would likely be permanent. 

3.7.2.4 Scope of the Analysis 

Analysis Area. The entire Eddy Gulch LSR totals approximately 61,900 acres. The Assessment 

Area is defined as the 37,239-acre portion of the LSR west of Etna Summit. The analysis area for 

botanical resources includes the proposed treatment units within the Assessment Area. Treatment 

units include those acres proposed for some type of on-the-ground treatment under the Proposed 

Action. 

Analysis Period. “Duration” of effects refers to the time period that the effects would affect 

plants or habitat, whether beneficial or adverse. The time period of effects has been classified into 

“short term” or “long term.” 

Short Term. Effects would be present or apparent for approximately 1 to 10 years (or less). 

Long Term. Effects would be present or apparent for more than 10 years. 

3.7.3 Affected Environment (Existing Conditions): Botanical Resources 

Previous district surveys and the results of August 2008 surveys include 36 sites of three Forest 

Service Sensitive vascular species and one bryophyte species in treatment areas: 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-176 Chapter 3: Affected Environment and Environmental Consequences

 11 previously documented and 10 new sites of Clustered Lady-Slipper Orchid 

(Cypripedium fasciculatum); 

 6 previously documented and 6 new sites of Mountain Lady-Slipper Orchid (Cypripedium 

montanum); 

 1 new site of English Peak Greenbriar (Smilax jamesii); and 

 2 new sites of Pacific fuzzwort (Ptilidium californicum) 

For detailed species accounts of the above four species, see the Botanical Resources Report or 

Biological Assessment/Biological Evaluation for Threatened, Endangered, Proposed, and Sensitive 

Plant Species included in the project record. 

A summary of the 36 Forest Service Sensitive plant sites in the proposed treatment units by 

population, location, and occurrence is presented in Table 3-47. 

Table 3-47. Summary of Forest Service Sensitive plant species sites within Eddy Gulch LSR Project 

proposed treatment units. 

Site 

Number and Legal Description 

Site 

Informationa UTM Locationb Location Within 

Proposed Treatment Unit

Cypripedium fasciculatum (Clustered lady-slipper orchid)

CYFA-198V (new site, temporary 

number assigned) 

T41N-R10W, S.21, SW of SE 1⁄4 

2 plants located 

in 2008 

500421, 

4581337 

Within Fuel Reduction Zone (FRZ) 20. On a 

northwest-facing upland slope, at -5,600 feet, 

1 mile south of Etna Summit. 2008 Botanical 

Survey Unit #23.

CYFA-200V (new site, temporary 

number assigned) 

T41N-R10W, S29, NW of SE 1⁄4 

6 new plants 

located during 

2008 surveys 

498462, 

4580369 

Within FRZ 20 in RS Treatment, in a shallow, 

northwest-facing draw above Sawyer’s Bar 

Road, at 3,600 feet. 2008 Botanical Survey 

Unit #21.

CYFA-201V (new site, temporary 

number assigned) 

T40N-R10W-S.20, SE of SW 1⁄4 

14 new plants 

located during 

2008 surveys 

496993, 

4573520 

Within Rx Unit 8, on a northwest-facing slope 

along John’s Meadow Creek (a tributary of 

South Russian Creek) at 3,300 feet. 2008 

Botanical Survey Unit #18.

CYFA-202V (new site, temporary 

number assigned) 

T40N-R10W-S.20, SW of SW 1⁄4 

2 plants located 

during 2008 

surveys 

496717, 

4573698 

Within Rx Unit 8, on a west-facing slope 

along John’s Meadow Creek (a tributary of 

South Russian Creek) at 3,200 feet. 2008 

Botanical Survey Unit #18.

CYFA-203V (new site, temporary 

number assigned) 

T39N-R11W-S8, NW of NW 1⁄4 

68 plants 

located during 

2008 surveys 

488009, 

4568030 

Within Rx Unit 12 on a northeast-facing slope 

east of Black Bear Summit, from 3,640 – 

4,000 feet. 2008 Botanical Survey Unit #16-

North.

CYFA-RAW1 (new site, temporary 

number assigned) 

T40N-R10W, S. 9, NW of NW 1⁄4 

2 plants located 

during 2008 

surveys 

498399, 

4578170 

Within Rx Unit 9, on steep, northeast-facing 

draw above Cow Creek, at 4,300 feet. 2008 

Botanical Survey Unit # 19-North.

CYFA-GSV2 (new site, temporary 

number assigned) 

T40N-R10W-S.20, NE of SW 1⁄4 

7 plants located 

during 2008 

surveys 

496775, 

4573804 

Within Rx Unit 8, on a northwest-facing 

convex slope above South Russian Creek, at 

3,200 feet. Population overlaps with CYMO2-

#GSV3. 2008 Botanical Survey Unit #18.
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Table 3-47. Summary of Forest Service Sensitive plant species sites within Eddy Gulch LSR Project 

proposed treatment units (continued). 

Section 3.7 – Botanical Resources and Noxious Weeds 3-177

Site 

Number and Legal Description 

Site 

Informationa UTM Locationb Location Within 

Proposed Treatment Unit

CYFA KM7 (new site, temporary 

number assigned) 

T40N-R10W-S.19, NE of SW 1⁄4 

73 new plants 

located during 

2008 surveys 

496290, 

4573984 

Within Rx Unit 8 in an RS treatment, on a 

north-facing convex slope above South Fork 

Music Creek, at 3,000 feet. 2008 Botanical 

Survey Unit #18.

CYFA-RB2A (new site, temporary 

number assigned) 

T39N-R11W, S.18, NE of SE 1⁄4 

15 plants 

located in 2008 

surveys 

487391, 

4565613 

Within Rx Unit 2, on a northeast-facing toe 

slope above Callahan Gulch, at 3,450 feet. 

2008 Botanical Survey Unit #14.

CYFA-RB2B (new site, temporary 

number assigned) 

T39N-R10W, S.18, NE of SE 1⁄4 

2 plants located 

in 2008 surveys 

487234, 

4565613 

Within Rx Unit 2, on a northeast-facing toe 

slope above Callahan Gulch, at 3,450 feet 

(site is 450 feet west of CYFA-RB2A, and 

same location as CYMO2 RB03). 2008 

Botanical Survey Unit #14.

CYFA-5-6 

T39N-R11W, S.7, NE of NE 1⁄4 

17 plants 

located in 2006 

Area not 

surveyed in 

2008 

Within FRZ 3 in a RS Treatment, on a 

northwest-facing slope southwest of Black 

Bear Summit. Outside 2008 Botanical Survey 

Units. (Population is in 2004 prescribed burn 

and overlaps with CYMO2-5-58A.)

CYFA-5-7A,B 

T39N-R11W-S8, NW of NW 1⁄4 

12 plants 

located in 2006 

11 plants 

located during 

2008 surveys 

487750, 

4567935 

Within Rx Unit 12 in a RS Treatment on a 

northeast-facing slope southeast of Black 

Bear Summit. 2008 Botanical Survey Unit 

#16-North. Same site as CYMO2-5-58B.

CYFA-5-9 

T38N-R11W-S.5, SE of SE 1⁄4 

54 plants 

located in 1991 

Area not 

surveyed in 

2008 

Within Rx Unit 4, in riparian area of 4th of 

July Gulch. (Site overlaps with CYMO2-5-

59). Outside 2008 Botanical Survey Units. 

CYFA-5-16A 

T38S-R11W-S.34, SE of SW 1⁄4 

2 plants located 

in 1981 

Area not 

surveyed in 

2008 

Within Rx Unit 4, along the riparian zone of 

upper Crawford Creek (along trail). Outside 

2008 Botanical Survey Units.

CYFA-5-16B 

T38N-R11W-S.3, NE of NE 1⁄4 

1 plants located 

in 1981 

Area not 

surveyed in 

2008 

Within Rx Unit 4, along the riparian zone of 

upper Crawford Creek (along trail, approx. 

0.5 mile north of CYFA-16A). Outside 2008 

Botanical Survey Units.

CYFA-5-39A,B 

T39N-R11W-S34, NW of NE 1⁄4 and 

T39N-R11W-S27, SW of SE 1/4 

72 plants 

located in 2002 

Area not 

surveyed in 

2008 

Within Rx Unit 4, on a northwest-facing slope 

above Crawford Creek (southeast of trail), at 

3,600 – 3,700 feet. Outside 2008 Botanical 

Survey Units.

CYFA-5-69 

T41N-R10W, S.21, NE of SE 1⁄4 

11 plants 

located in 1991 

1 plant 

relocated in 

2008 

500651, 

4581662 

Within FRZ 20 at southern boundary of 

M Unit 31. On a shady west-facing concave 

slope, (at the head of a small intermittent 

creek), at 5,600 feet, 1 mile south of Etna 

Summit. 2008 Botanical Survey Unit #23.
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

Table 3-47. Summary of Forest Service Sensitive plant species sites within Eddy Gulch LSR Project 

proposed treatment units (continued). 

3-178 Chapter 3: Affected Environment and Environmental Consequences

Site 

Number and Legal Description 

Site 

Informationa UTM Locationb Location Within 

Proposed Treatment Unit

CYFA-5-70 

T41N-R10W, S.21, SE of SE 1⁄4 

24 plants 

located in 1991 

Site not 

surveyed 

during 2008 

surveys 

Within FRZ 20. On a northwest-facing slope 

at 5,200 feet, 1 mile south of Etna Summit. 

Outside 2008 Botanical Survey area.

CYFA-5-73 

T40N-R10W-S.20, SE of SW 1⁄4 

65 plants 

located during 

1991 

Site not 

relocated 

during 2008 

surveys 

Within Rx Unit 8, on a west-facing draw 

(John’s Meadow Creek) above South 

Russian Creek. This site overlaps with 

CYMO2# 5-9. 2008 Botanical Survey 

Unit #18.

CYFA-5-78 

T41N-R10W, S.28, NE of NW 1⁄4 

No plants 

located in 2004 

Site not 

relocated 

during 2008 

surveys 

Within FRZ 20 in a RS Treatment, on a 

northwest-facing slope at 5,600 feet, south of 

Etna Summit. 2008 Botanical Survey 

Unit #22.

CYFA-5-81 

T39N-R12W-S.13, NW of SW 1⁄4 

10 plants 

located in 1995 

Area not 

surveyed in 

2008 

Within Rx Unit 1, along a north-facing side 

draw of Argus Creek. Outside 2008 Botanical 

Survey Units.

Cypripedium montanum (Mountain lady-slipper orchid) 

CYMO2-GSV1 (new site, temporary 

number) 

T41N-R10W-S.29, SE of SW 1⁄4 

1 plant located 

during 2008 

surveys 

498115, 

4579930 

Within FRZ 20 and RS Treatment, on a NWfacing convex slope above Sawyer’s Bar 

Road, at 3,600 feet. 2008 Botanical Survey 

Unit #21. 

CYMO2-KM1 (new site, temporary 

number) 

T41N-R10W-S.32, S/E of NW 1⁄4 

12 plants 

located during 

2008 surveys 

497977, 

4579145 

Within Rx Unit 9 on a north-facing slope 

above Taylor Creek road, 3,640 feet. Near 

2008 Botanical Survey Unit #20-East.

CYMO2-GSV3 (new site, temporary 

number assigned) 

T40N-R10W-S.20, NE of SW 1⁄4 

continuing to SW of SW 1⁄4 

13 plants 

located during 

2008 surveys 

496719, 

4573933 

Within Rx Unit 8, on a north-facing slope 

above South Russian Creek, at 3,200 feet. 

[Site overlaps with CYFA-GSV2]. 2008 

Botanical Survey Unit #18.

CYMO2-204V (new site, temporary 

number assigned) 

T39N-R11W-S8, NW of NW 1⁄4, 

10 plants 

located during 

2008 surveys 

488007, 

4568047 

Within Rx Unit 12 on an upland northeastfacing slope southeast of Black Bear 

Summit, and north of CYFA-7A. [Population 

has been monitored after previous 2004 

prescribed underburn]; 2008 Botanical 

Survey Unit# 16-North.

CYMO2-RB3 (new site, temporary 

number assigned) 

T39N-R10W, S.18, SW of NE 1⁄4, and 

NW of SE 1⁄4 

125 plants 

located in 2008 

surveys 

487347, 

4565613 

Within Rx Unit 2, on a northeast-facing toe 

slope above Callahan Gulch, at 3,350–3,650 

feet (at same location as CYFA- RB2B). 

2008 Botanical Survey Unit #14.

CYMO2-JS1 (new site, temporary 

number assigned) 

T39N-R12W-S.24, SE of NE 1⁄4 

25 plants 

located in 2008 

surveys 

486577, 

4565602 

Within Rx Unit 2 on a northwest-facing slope 

above Callahan Creek. 2008 Botanical 

Survey Unit #14.
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Table 3-47. Summary of Forest Service Sensitive plant species sites within Eddy Gulch LSR Project 

proposed treatment units (continued). 

Section 3.7 – Botanical Resources and Noxious Weeds 3-179

Site 

Number and Legal Description 

Site 

Informationa UTM Locationb Location Within 

Proposed Treatment Unit

CYMO2-5-9 

T40N-R10W-S.20, SW of SE 1⁄4 and SE 

of SW 1⁄4 

12 plants 

located during 

1981 

Site not 

relocated 

during 2008 

surveys 

Within Rx Unit 8, on southwest-facing draw 

and slopes above John Meadows Creek. 

(Site overlaps with CYFA-5-73). 2008 

Botanical Survey Unit #18.

CYMO2-5-30A,B,C 

T39N-R11W-S.34, NE of NE 1⁄4, and 

S.27, SE of SE 1/4 

7 plants located 

in 2002 

Area not 

surveyed in 

2008 

Within Rx Unit 4, on a northwest-facing slope 

above Crawford Creek (southeast of trail), at 

3,700 feet. Outside 2008 Botanical Survey 

Units.

CYMO2-5-32 

T39N-R11W-S.35, SW of SW 1⁄4 

50 plants 

located in 1985 

Area not 

surveyed in 

2008 

Within FRZ 10 and northern edge of M Unit 

52, on ridgeline, south of Grouse Point, in 

unique habitat of conifer-oak woodland. 

Outside 2008 Botanical Survey Units.

CYMO2-5-49 

T38N-R11W-S2, NW of NW 1⁄4 and S.3, 

NE, SE and SW of NE 1⁄4, and NE and 

NW of SE 1⁄4 

1,000+ plants 

located in 1991 

Area not 

surveyed in 

2008 

Within FRZ 10, Rx Unit 4 at southern 

boundary of M#52, on ridgeline and western 

slopes below Grouse Point, in unique habitat 

of conifer overstory/oak understory. Outside 

2008 Botanical Survey Units.

CYMO2-5-58A 

T39N-R11W-S7, NE of NE 1⁄4 

25 plants 

located during 

2006 

Area not 

surveyed in 

2008 

Within FRZ 3 on an upper west-facing slope 

south of Black Bear Summit. (Site within 

2004 prescribed burned area.) Site overlaps 

with CYFA-5-6. 2008 Botanical Survey Unit 

#16-North.

CYMO2-5-58B 

T39N-R11W-S8, NW of NW 1⁄4 

2 plants located 

during 2006 

Area not 

surveyed in 

2008 

Within Rx Unit 12 on a northeast-facing slope 

south of Black Bear Summit. 2008 Botanical 

Survey Unit #16-North. Same site as CYFA5-7A,B. 

CYMO2-5-59 

T38S-R11W-S.5, NE of SE 1⁄4 

24 plants 

located in 1995 

Area not 

surveyed in 

2008 

Within Rx Unit 4 and RS Treatment, on 

north-facing slope above 4th of July Gulch, 

Site overlaps with CYFA 5-9. Outside 2008 

Botanical Survey Units.

Ptilidum californicum (Pacific fuzzwort)

PTCA5-TE1 (new site, temporary 

number assigned) 

T39N-R11W-S.28, SW of NW 1⁄4 

2-inch x 4-inch 

area of plants 

located in 2008 

on one ABCO 

487991, 

4562459 

Within FRZ 5 and RS Treatment, on a 

northwest-facing flat slope, at 4,940 feet. 

2008 Botanical Survey Unit #13. Lafayette 

Point. 

PTCA5-RB1 (new site, temporary 

number assigned) 

T39N-R10W, S17, SE of SW 1⁄4 

1-foot by 1-foot 

area; 

approximately 

1,000 individual 

shoots on one 

ABCO; 2008 

Botanical 

Survey Unit #2-

East 

496747, 

4564884 

Within Rx Unit 6, at western boundary of 

M 24, on a northwest-facing slope north of 

Grasshopper Ridge at 5,460 feet. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

Table 3-47. Summary of Forest Service Sensitive plant species sites within Eddy Gulch LSR Project 

proposed treatment units (continued). 

3-180 Chapter 3: Affected Environment and Environmental Consequences

Site 

Number and Legal Description 

Site 

Informationa UTM Locationb Location Within 

Proposed Treatment Unit

Smilax jamesii (English Peak greenbriar)

SMJA-JS152 (new site, temporary 

number assigned) 

T41N-R10W, S.19, NE of SE 1⁄4 

7 new plants 

located in 2008 

surveys 

496040, 

4574052 

Within Rx Unit 8, along South Russian 

Creek, at 2,800 feet. 2008 Botanical Survey 

Unit #18. 

Notes: 

a. The surveys were conducted in August 2008. 

b. Universal Transverse Mercator (UTM) coordinates available only for sites located (or re-located) during 2008 project 

botanical surveys. 

The 36 sites of the four Forest Service Sensitive plant species are distributed within various 

project treatment types in the Assessment Area: 

 6 CYFA sites occur in FRZs, of which 4 are inside RS treatment areas; and 15 sites occur 

in Rx Units, of which 2 are within RS treatments. 

 4 of the CYMO2 sites occur in FRZs—1 of the 4 is in an RS treatment; 8 CYMO2 sites 

occur in Rx Units, 1 of the 8 occurs in an RS treatment. 

 1 SMJA site is located in the Riparian Reserve of Rx Unit 8. 

 1 PTCA5 site occurs within FRZ 5 and within an overlapping RS treatment; a second site 

occurs in Rx Unit 6, west of M Unit 24. 

3.7.4 Environmental Consequences: Botanical Resources 

3.7.4.1 General Direct, Indirect, Cumulative Effects 

The general direct, indirect, and cumulative effects of project-related activities on Sensitive plants 

are described below. 

 Direct Effects. Sensitive plants can be directly affected when they are driven over, covered, 

have trees fall on them, or are burned. These actions can physically break, crush, or uproot the plants, 

and the effects on individual plants can reduce their growth and development, population size, and 

potentially, the viability of the species across the landscape. The plants may also experience reduced 

or eliminated seed-set and reproduction. If the disturbance is severe, plants can be killed. For annual 

plant species, the timing of effects is critical. Management actions that take place after annuals have 

set seed have much less effect than management actions performed prior to seed-set. For perennial 

species, the timing of effects can be equally critical. Management actions that take place after the 

active growing season have less effect than management activities performed during the active 

growing season. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.7 – Botanical Resources and Noxious Weeds 3-181 

 Indirect Effects. Indirect effects (both beneficial and adverse) on Sensitive plants may be 

caused by alteration to habitat and typically include changes in vegetation composition, solar 

exposure, hydrologic patterns, fire regime, or soil characteristics. Indirect effects can also occur from 

noxious weed invasion or from effects on pollinators or mycorrhizae associated with the various 

species. 

 Cumulative Effects. The Klamath National Forest Schedule of Proposed Actions was 

reviewed to identify current and reasonably foreseeable future projects on the Salmon River and Scott 

River Ranger Districts that should be included in the cumulative effects analysis for the Eddy Gulch 

LSR Project. Ongoing projects include annual road maintenance, improvements to existing mining 

claims, hiking, and appropriate responses for fire suppression. Additional reasonably foreseeable 

future projects are listed above in Section 3.1.4. 

Cumulative, direct, and indirect effects will be minimized by conforming to Klamath LRMP 

Standards and Guidelines and implementing the resource protection measures developed for this 

project. With those measures in place, cumulative effects are less likely to be adverse. Current 

management direction is designed to eliminate or reduce possible negative cumulative effects by 

protecting Sensitive plant species from direct and indirect effects. 

3.7.4.2 Alternative A: No Action 

Sensitive Vascular Plant Species 

 Cypripedium fasciculatum—Clustered Lady-slipper Orchid—CYFA 

 Cypripedium montanum—Mountain Lady-slipper Orchid—CYMO2 

 Smilax jamesii—English Peak Greenbriar—SMJA 

 Direct and Indirect Effects. Twenty-one populations of CYFA, 12 populations of CYMO2, 

and 1 population of SMJA occur in the Assessment Area. The effects of a wildfire on these species are 

dependent on the intensity and type of fire, as well as the timing of the fire. A low or moderate surface 

fire (19 percent of the fire) that occurs after the growing season would result in some damage to an 

unknown number of CYFA and CYMO2 plants at each of the population sites (Harrod et al. 1996; 

USDA, USDI 1998; Knight 2008). An unknown number of damaged plants would recover, and 

populations in these areas would recover in the short term. A hot surface fire, or a fire that occurs 

during the CYFA and CYMO2 growing season, would damage or destroy an unknown number of 

CYFA and CYMO2 plants at each population site. Damaged and any unaffected plants would 

eventually recover and recolonize the affected populations in the long term. Recovery and 

recolonization is more likely to occur in populations with large numbers of individual plants. A 

moderate to hot surface fire could also indirectly affect CYFA and CYMO2 populations by reducing 

or eliminating critical mycorrhizal associations. Like other orchids, CYFA and CYMO2 seeds 

germinate in association with certain fungi that aid the developing embryo by providing nutrients 

necessary for development. (Orchid seeds, unlike those of other flowering plants, lack a seed coat, 

differentiated embryo, and endosperm.) Young orchid plants are also dependent upon mycorrhizal 

associations for several months or years before above-ground growth begins (USDA, USDI 1998). A 

surface fire that is hot enough to sterilize the soil would destroy associated mycorrhizae and seeds, 

indirectly affecting CYFA and CYMO2 viability and recovery after a wildfire. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-182 Chapter 3: Affected Environment and Environmental Consequences

A surface fire would damage above-ground portions of some or individual SMJA plants, while 

underground portions would be unaffected, and plants would recover in the short term. SMJA is a 

vine-like perennial that grows along the forest floor in riparian habitat. A surface fire within SMJA 

habitat would benefit SMJA populations indirectly by reducing riparian vegetation cover and 

competition for understory resources (moisture, substrate, soil minerals, understory light), resulting in 

increased viability of the SMJA population, until riparian vegetation recovers. 

A passive crown fire (70 percent of the fire) would result in effects similar to a surface fire, 

except the overstory could also be removed in scattered locations. The opening of canopy cover in 

CYFA and CYMO2 habitat would alter important habitat factors and decrease population viability. 

These two species require shade and the associated higher soil and duff moisture and humidity. The 

loss of canopy cover would result in the long-term loss of CYFA and CYMO2 plants until there is 

restoration of the canopy cover and important habitat characteristics. The scattered removal of 

overstory trees in SMJA habitat and the resulting increased sunlight would increase understory 

vegetation and competition. This would result in the long-term decline of SMJA plants until canopy 

cover is restored and understory vegetation is reduced. 

An active crown fire (11 percent of the fire) would burn with greater intensity and remove all 

canopy cover in the area affected. This would result in the direct loss of CYFA, CYMO2, and SMJA 

populations. Recovery of these CYFA and CYMO2 populations will not occur until a mature closedcanopied forest is re-established. Recovery of SMJA should be sooner, as riparian areas typically 

recover faster than mature conifer forests. 

As local populations are a minor fraction of occurrences throughout the region (northwestern 

California and southwestern Oregon), the loss of CYFA and CYMO2 plants or populations in the 

Assessment Area would have a negligible effect on the viability of the two species and would be less 

than significant at a regional level and across the range of the two species. 

While SMJA is limited to the four far-northwest counties of California, and the SMJA population 

in the Assessment Area represents 1 of only 17 sites in the Siskiyou County area, SMJA is currently 

secure in number of populations. The loss of the individual project populations would not affect 

viability of the species. 

 Cumulative Effects. The previous history of fire suppression has resulted in a build up of 

ground and ladder fuels in the Assessment Area. The ongoing recreational (mining, hiking, hunting) 

and rural community activities in the Assessment Area create potential for fire ignitions; these 

combined factors would increase the risk of stand-replacing wildfire. A frequent result of standreplacing wildfires, and the corresponding suppression activities, is the formation of conditions 

favorable to noxious weed invasion. Noxious weed infestations can compete directly with Sensitive 

plant populations and can permanently alter natural plant communities. Dyer’s woad is the most 

likely noxious weed species to invade CYFA, CYMO2, and SMJA habitat. This species is frequently 

found on roadsides and in open, disturbed dry sites, although at least one site in the Assessment Area 

continues down into a riparian area. An established infestation of Dyer’s woad (or other noxious weed 

species) in a CYFA, CYMO2, or SMJA project population would lead to a long-term decline of the 

Sensitive plant population over the long term. Noxious weed infestation is also a likely result of 

disturbance from annual road maintenance, fire suppression activities, and other future district 

projects, including the digging of a roadside trench for telephone and fiber-optic line installation, and 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.7 – Botanical Resources and Noxious Weeds 3-183 

the North Fork Roads Stormproofing Project. Each of these projects involves ground disturbance, 

which creates conditions for noxious weed infestations along roadsides and can permanently alter 

natural plant communities. Once noxious weed species are established, it can be costly to manage and 

remove them. 

Conclusion—A surface fire and portions of a passive crown fire that remain on the surface 

would result in minor adverse short-term direct effects on CYFA, CYMO2, and SMJA as plants are 

initially damaged and then recover. A surface fire hot enough to sterilize the soil would result in longterm moderate adverse indirect effects on CYFA and CYMO2 as mycorrhizae are eliminated and 

recolonization, seed germination, and juvenile plant development are reduced. Where the overstory is 

removed as a result of a passive or active crown fire, the indirect loss of CYFA, CYMO2, and SMJA 

plants from habitat alteration would result in a moderate long-term adverse indirect effect until 

mature forest canopy cover recovers. The cumulative effects of previous fire suppression 

management, associated high fuel loads, and increased fire ignitions from ongoing recreational 

(mining, hiking, hunting) and rural community activities in the Assessment Area would increase risk 

of stand-replacing fire and create conditions for the spread and introduction of noxious weeds into the 

Assessment Area and CYFA, CYMO2, and SMJA populations—the result would be a long-term 

moderate, adverse indirect effect as weed infestations out-compete CYFA, CYMO2, and SMJA plants 

and other native vegetation over time. The distribution and abundance of the three species would 

result in a negligible change from the current distribution and abundance. 

Nine Sensitive Target Species Assumed to be Present 

The pre-field review determined that potential suitable habitat occurs in the proposed treatment 

units for 13 Forest Service Sensitive vascular and nonvascular species. Surveys were conducted for 

the 4 species most likely to occur in the proposed treatment units. The remaining 9 Forest Service 

Sensitive species are assumed to be present in the project Assessment Area and include: 

 3 species of moist environments: Botrychium virginianum (Rattlesnake Fern) (BOVI), 

Campanula wilkinsiana (Wilkin’s harebell) (CAWI8), and Smilax jamesii (English Peak 

Greenbriar) (SMJA); 

 3 species serpentine environments: Chaenactis suffrutescens (Shasta chaenactis) (CHSU), 

Eriogonum hirtellum (Klamath Mountain Buckwheat) (ERHI7), and Minuartia stolonifera

(Scott Mountain sandwort) (MIST9); 

 2 species of canopy gaps and forest edge environments: Eucephalis vialis (Wayside Aster) 

(EUVI8) and Pedicularis howellii (Howell’s lousewort) (PEHO); and 

 1 species of montane chaparral and mixed-conifer forest environments: Eriogonum 

ursinum var. erubescens (Blushing Buckwheat) (ERURE). 

This effects analysis assumes some number of sites of the nine additional sensitive species may 

occur in the proposed treatment units outside of the 2008 botanical survey areas. One site of the 

sensitive species (Smilax jamesii) was located in a treatment unit during 2008 surveys. No sites of the 

remaining eight additional sensitive species were located during the 2008 surveys. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-184 Chapter 3: Affected Environment and Environmental Consequences

Species of Moist (and Riparian) Environments— 

 Botrychium virginianum (Rattlesnake Fern)—BOVI 

 Campanula wilkinsiana (Wilkin’s harebell)—CAWI8 

 Smilax jamesii (English Peak Greenbriar)—SMJA 

BOVI is a small fern with seasonal leaves appearing in spring and dying back in late summer. 

BOVI occurs in moist environments, including bogs, fens, seeps and riparian forests within lower 

montane coniferous forests, While the coarse-grained GIS analysis identified no acres of suitable 

BOVI habitat in the project treatment units, potential BOVI habitat is expected to occur in moist 

environments that the GIS query could not identify, including bogs, fens, seeps, and riparian habitat 

throughout the Assessment Area. 

CAWI8 is a rhizomatous herb that occurs in meadows and seeps in upper montane coniferous 

forests. The GIS query identified 43 acres of suitable CAWI8 habitat in proposed treatment units. 

Additional potential CAWI8 habitat is expected to occur in moist environments that the GIS query 

could not identify, including bogs, fens, seeps, and riparian habitat throughout the Assessment Area. 

SMJA is perennial trailing vine that occurs along streambanks in lower and upper montane 

coniferous forests. An expanded SMJA effects analysis is described here, as additional sites may 

occur in proposed treatment units outside of the 2008 botanical survey areas. The GIS query 

identified 3,080 acres of suitable SMJA habitat in the proposed treatment units. The effects of fire on 

BOVI, CAWI8, and SMJA have not been reported. 

 Direct and Indirect Effects. A surface fire would damage above-ground portions of some 

BOVI, CAWI8, and SMJA plants, while underground portions would be unaffected. BOVI, CAWI8, 

and SMJA sites would recover in the short term. A surface fire within BOVI, CAWI8, and SMJA 

habitat would benefit plants indirectly by reducing riparian vegetation cover and competition for 

understory resources (moisture, substrate, soil minerals, understory light), resulting in increased 

viability of any BOVI, CAWI8, and SMJA sites until riparian vegetation recovers. 

A passive crown fire (70 percent of the fire) would result in effects similar to a surface fire, 

except the overstory would also be removed in scattered locations. The scattered removal of overstory 

trees in BOVI, CAWI8, and SMJA habitat would increase sunlight and competition from understory 

vegetation. This would result in an indirect long-term decline of BOVI, CAWI8, and SMJA plants 

until canopy cover is restored and understory vegetation is reduced. 

An active crown fire (11 percent of the fire) would burn with greater intensity and remove all 

canopy cover in the affected area. This would result in the long-term direct loss of any BOVI, 

CAWI8, and SMJA sites until riparian overstory recovers. 

 Cumulative Effects. The previous history of fire suppression has resulted in a build up of 

ground and ladder fuels in the treatment units. The ongoing recreational (mining, hiking, hunting) and 

rural community activities in the Assessment Area create potential for fire ignitions; these combined 

factors would increase the risk of stand-replacing wildfire in the treatment units. A frequent result of 

stand-replacing wildfires, and the corresponding suppression activities, is the formation of conditions 

favorable to noxious weed invasion. Noxious weed infestations can compete directly with Sensitive 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.7 – Botanical Resources and Noxious Weeds 3-185 

plant sites and can permanently alter natural plant communities. Dyer’s woad is the most likely 

noxious weed species to invade BOVI, CAWI8, and SMJA habitat. While this weed species is 

frequently found on roadsides and in open, disturbed dry sites, at least one site in the Assessment Area 

continues down into a riparian area. An established infestation of Dyer’s woad (or other noxious weed 

species) in a BOVI, CAWI8, or SMJA project site would lead to a long-term decline of the Sensitive 

plant site over the long term. Noxious weed infestation is also a likely result of disturbance from 

annual road maintenance, fire suppression activities, and other future district projects, including the 

digging of a roadside trench for telephone and fiber-optic line installation, and the North Fork Roads 

Stormproofing Project. Each of these projects involves ground disturbance that creates the conditions 

for noxious weed infestations along roadsides that can permanently alter natural plant communities. 

Once noxious weed species are established, management and removal can be costly. 

Conclusion—A surface fire and portions of a passive crown fire that remain on the surface 

would result in short-term minor adverse direct effects on BOVI, CAWI8, and SMJA as plants are 

initially damaged and then recover. If the overstory is removed as a result of a passive or active crown 

fire, the loss of BOVI, CAWI8, and SMJA plants from habitat alteration would result in a long-term 

moderate adverse indirect effect until mature forest canopy cover recovers. The cumulative effects of 

previous fire suppression management, associated high fuel loads, and increased fire ignitions from 

ongoing recreational (mining, hiking, hunting) and rural community activities in the Assessment Area 

would increase risk of stand-replacing fire and create conditions for the spread and introduction of 

noxious weeds into the Assessment Area and BOVI, CAWI8, and SMJA sites. The result would be a 

long-term moderate adverse indirect effect as weed infestations out-compete BOVI, CAWI8, and 

SMJA plants and other native vegetation over time. The distribution and abundance of the three 

species would result in a negligible change from the current distribution and abundance. 

Species of Serpentine Environments— 

 Chaenactis suffrutescens (Shasta chaenactis)—CHSU 

 Eriogonum hirtellum (Klamath Mountain buckwheat)—ERHI7 

 Minuartia stolonifera (Scott Mountain sandwort)—MIST9 

The pre-field review GIS query identified 41 acres of potential suitable CHSU habitat in the 

treatment units. Additional potential CHSU habitat is expected to occur in the project Assessment 

Area in serpentine habitat that the GIS query could not identify. 

The GIS query identified no acres of potential suitable ERHI7 habitat in the treatment units. 

Potential ERHI7 habitat is expected to occur in the project Assessment Area in serpentine habitat that 

the GIS query could not identify. 

The GIS query identified only 3 acres of potential suitable MIST9 habitat in the treatment units. 

Additional MIST9 habitat is expected to occur in serpentine habitat in the project Assessment Area 

that the GIS query could not identify. 

The effects of fire on CHSU, ERHI7, and MIST9 have not been reported in the literature. 

Although the ecology of serpentine ecosystems in California has been the subject of many dozens of 

scientific studies, the fire ecology of serpentine habitats has remained largely unexplored, and the role 

of fire in serpentine ecosystems is poorly understood. Wildfire frequency and intensity in serpentine 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-186 Chapter 3: Affected Environment and Environmental Consequences

habitats is generally considered to be lower than in surrounding non-serpentine habitats due to lower 

availability and continuity of woody fuels (Safford and Harrison 2008). 

 Direct and Indirect Effects. A surface fire would burn above-ground portions (leaves, 

flowers/fruits, or stems) but not damage below-ground (caudex, roots) portions of CHSU, ERHI7, 

and MIST9. Surface fires, however, would also cause an increase in competing early seral vegetation 

cover (such as grass species), with a resulting decrease in plants at any CHSU, ERHI7, or MIST9 

sites. The result of a surface fire on CHSU, ERHI7, and MIST9 in serpentine habitat include (1) a 

short-term minor adverse direct effect as burned plants would recover in the short term, and (2) a 

long-term moderate adverse indirect effect because the increase in competing early seral vegetation 

(that is, grass species) would out-compete some CHSU, ERHI7, and MIST9 plants for resources. 

Passive and active crown fires would remove some or all canopy cover in CHSU, ERHI7, and 

MIST9 habitat. The physical removal of canopy would result in minimal effects because all three 

species occur in open overstory habitats. However, crown fires in serotinous cone species in the 

overstory (that is, Pinus sabiteana or P. contorta) would increase seed supply and germination, 

resulting in an increase in seedlings of these species that would compete with CHSU, ERHI7, and 

MIST9. Passive and active crown fires would result in (1) a long-term negligible adverse direct effect 

as canopy cover is reduced; and (2) a long-term moderate adverse indirect effect where an increase in 

serotinous pine seedlings would out-compete some CHSU, ERHI7, and MIST9 plants for resources. 

 Cumulative Effects. The previous history of fire suppression has resulted in a build up of 

surface and ladder fuels in the treatment units. The ongoing recreational (mining, hiking, hunting) and 

rural community activities in the Assessment Area create potential for fire ignitions; these combined 

factors would increase the risk of stand-replacing wildfire in the treatment units. A frequent result of 

stand-replacing wildfires, and the corresponding suppression activities, is the formation of conditions 

favorable to noxious weed invasion. Noxious weed infestations can compete directly with Sensitive 

plant sites and can permanently alter natural plant communities. Dyer’s woad, yellow starthistle, and 

meadow knapweed are the most likely noxious weed species to invade serpentine habitat. An 

established infestation of noxious weeds in any CHSU, ERHI7, and MIST9 sites would lead to a 

long-term decline of these three serpentine species. Noxious weed infestation is also a likely result of 

disturbance from annual road maintenance, fire suppression activities, and other future district 

projects, including the digging of a roadside trench for telephone and fiber-optic line installation, and 

the North Fork Roads Stormproofing Project. Each of these projects involves ground disturbance that 

creates the conditions for noxious weed infestations along roadsides. Once noxious weed species are 

established, management and removal can be costly. 

In addition to the indirect effects of noxious weed infestations, the increase in fuels in serpentine 

habitats above historic levels would result in an increase in fire intensity. The increased fire intensity 

would create hotter surface fires, resulting in damage and possible destruction of the three serpentine 

plants, as high soil temperatures destroy underground portions of plants. The result would be a longterm moderate adverse direct effect. 

Conclusion. A surface fire would result in a short-term minor adverse direct effect as burned 

plants would recover in the short term, and a long-term moderate adverse indirect effect because the 

increase in competing early seral vegetation (such as grass species) would out-compete some CHSU, 

ERHI7, and MIST9 plants for resources. Passive and active crown fires would result in a long-term 
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Section 3.7 – Botanical Resources and Noxious Weeds 3-187 

negligible adverse direct effect as canopy cover is reduced; and (2) a long-term moderate adverse 

indirect effect where an increase in serotinous pine seedlings would out-compete some CHSU, 

ERHI7, and MIST9 plants for resources. The cumulative effects of previous fire suppression 

management, associated high fuel loads, and increased fire ignitions would (1) increase the risk of 

stand-replacing fire and create conditions for the spread and introduction of noxious weeds—the 

result would be a long-term moderate adverse indirect effect as weed infestations out-compete CHSU, 

ERHI7, and MIST9 plants and other native vegetation for resources; and (2) create hotter surface 

fires, with damage and possible destruction of CHSU, ERHI7, and MIST9 plants, resulting in a longterm moderate adverse direct effect. 

Species of Canopy Gap and Forest Edge Environments— 

 Eucephalis vialis (Wayside Aster)—EUVI8 

 Pedicularis howellii (Howell’s lousewort)—PEHO 

EUVI8 is a perennial herb with a thickened woody stem (caudex) and rhizomes. EUVI8 sites 

occur in canopy gaps, clearcuts, forest edges, and on roadsides. The species’ preferred habitat is 

thought to have been historically sustained by frequent fire return intervals that created open forest 

conditions with widely spaced conifers. EUVI8 flowers in late summer to early fall and occurs from 

eastern Del Norte to southern Humboldt counties and north to Oregon. The coarse-grained GIS query 

identified no potential suitable EUVI8 acres in the treatment units, but potential suitable EUVI8 

habitat is expected to occur along roads (including roads outside of and within RS treatments), and in 

forest edge / canopy gap habitat within FRZs and Rx Units.

PEHO is an herbaceous perennial green root parasite in the Scophulariaceae (figwort) plant 

family. This species is found in partial shade or along the edges of forest openings in a variety of 

conifer/shrub plant associations. PEHO is most abundant where the mixed-conifer canopy is less than 

40 percent, created by either natural forest processes (fire, windthrow, disease) or manmade forest 

edges such as trails, roads, or other openings. This species flowers in June and July and is found only 

in the Siskiyou Mountains of southwestern Oregon and northwestern California. The coarse-grained 

GIS query identified no potential suitable PEHO habitat in the treatment units, but potential suitable 

PEHO habitat is expected to occur in forest edge / canopy gap habitat within FRZs and Rx Units. 

 Direct and Indirect Effects. A surface fire would burn above-ground portions (leaves, 

flowers/fruits or stems) but would not damage below-ground portions (caudex [stem], roots) of any 

EUVI8 and PEHO plants. Both species are associated with canopy gap habitat and are likely tolerant 

of surface fires. The results would be a very short-term minor adverse direct effect (as plants resprout 

and recover) and a long-term minor beneficial indirect effect as competing vegetation decreases and 

EUVI8 or PEHO site vigor increases. 

A passive crown fire would result in effects similar to a surface fire, except the overstory could 

also be removed in scattered locations. The removal of some canopy overstory would improve any 

EUVI8 and PEHO site conditions by creating more edge-canopy gap habitat, resulting in a long-term 

minor beneficial indirect effect as EUVI8 and PEHO site vigor increases. 

An active crown fire would burn with greater intensity and remove all canopy cover in the 

affected area. This would result in the direct loss of some EUVI8 or PEHO sites—the preferred 
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habitat for both species includes some canopy overstory. The result would be a long-term moderate 

adverse indirect effect until some canopy overstory is re-established. 

 Cumulative Effects. The previous history of fire suppression has resulted in a buildup of 

ground and ladder fuels in the treatment units. The ongoing recreational (mining, hiking, hunting) and 

rural community activities in the Assessment Area create potential for fire ignitions; these combined 

factors would increase the risk of stand-replacing wildfire in the treatment units. A frequent result of 

stand-replacing wildfires, and the corresponding suppression activities, is the formation of conditions 

favorable to noxious weed invasion. Noxious weed infestations can compete directly with Sensitive 

plant sites and can permanently alter natural plant communities. Dyer’s woad, yellow starthistle, and 

meadow knapweed are the most likely noxious weed species to invade EUVI8 and PEHO habitat. An 

established infestation of noxious weeds in these species’ sites would lead to a long-term decline of 

the sites. Noxious weed infestation would also be a likely result of disturbance from annual road 

maintenance, fire suppression activities, and other future district projects, including the digging of a 

roadside trench for telephone and fiber-optic line installation and the North Fork Roads 

Stormproofing Project. Each of these projects involves ground disturbance, which creates conditions 

for noxious weed infestations along roadsides and can permanently alter natural plant communities. 

Once noxious weed species are established, management and removal can be costly. 

Conclusion. A surface fire and portions of a passive crown fire that remain on the surface 

would result in a very short-term minor adverse direct effect (as plants resprout and recover) and a 

long-term minor beneficial indirect effect as competing vegetation is reduced and EUVI8 or PEHO 

site vigor increases. A passive crown fire would result in a long-term minor beneficial indirect effect 

as EUVI8 and PEHO site vigor increases from overstory canopy opening. An active crown fire would 

result in a long-term moderate adverse indirect effect until some canopy overstory is re-established. 

The cumulative effects of previous fire suppression management, associated high fuel loads, and 

increased fire ignitions would result in a long-term moderate adverse indirect effect as conditions are 

created for the spread and introduction of noxious weeds that would outcompete EUVI8 and PEHO 

plants and other native vegetation. 

Montane Chaparral and Mixed-Conifer Environments— 

 Eriogonum ursinum var. erubescens (Blushing Buckwheat)—ERURE 

ERURE is a spreading, matted perennial herb that occurs in gravelly metavolcanic soils in 

montane chaparral and conifer/mountain mahogany plant communities. ERURE flowers from June 

through September and is localized and rare, and known only to occur in Siskiyou County west of 

Yreka and the Shasta County / Trinity County line. The coarse-grained GIS query identified no 

potential suitable ERURE acres in the treatment units, but potential suitable ERURE habitat is 

expected to occur in the project Assessment Area in chaparral habitat that the GIS query could not 

identify. 

 Direct and Indirect Effects. A surface fire would burn above-ground portions (leaves, 

flowers/fruits, or stems) but not damage below-ground portions (roots) of ERURE. The result would 

be a short-term minor adverse direct effect on any ERURE sites as plants would recover in the short 

term. 
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Section 3.7 – Botanical Resources and Noxious Weeds 3-189 

A passive or active crown fire would have the same effects as a surface fire, with additional 

effects resulting from canopy removal. ERURE occurs in open chaparral and conifer / mountain 

mahogany habitat. Passive and active crown fires would remove some or all chaparral, hardwood, and 

conifer canopy cover. The result would be a long-term minor adverse indirect effect because any 

shade provided by the canopy would be lost, and surface temperatures would increase, resulting in 

some minor damage to any ERURE sites until chaparral or conifer canopy cover recovers. 

 Cumulative Effects. The previous history of fire suppression has resulted in a build up of 

ground and ladder fuels in the Assessment Area. The ongoing recreational (mining, hiking, hunting) 

and rural community activities in the Assessment Area create potential for fire ignitions; these 

combined factors would increase the risk of stand-replacing wildfire in the treatment units. A frequent 

result of stand-replacing wildfires, and the corresponding suppression activities, is the formation of 

conditions favorable to noxious weed invasion. Noxious weed infestations can compete directly with 

Sensitive plant sites and can permanently alter natural plant communities. Dyer’s woad, yellow 

starthistle, and meadow knapweed are the most likely noxious weed species to invade ERURE 

chaparral habitat. An established infestation of noxious weeds in any ERURE sites would lead to a 

long-term decline of the site as plants are outcompeted by invasive weeds. Noxious weed infestation 

is also a likely result of disturbance from annual road maintenance, fire suppression activities, and 

other future district projects, including the digging of a roadside trench for telephone and fiber-optic 

line installation, and the North Fork Roads Stormproofing Project. Each of these projects involves 

ground disturbance, which creates the conditions for noxious weed infestations along roadsides that 

can permanently alter natural plant communities. Once noxious weed species are established, 

management and removal can be costly. 

In addition to the indirect effects of noxious weed infestations, the increase in fuels in ERURE 

chaparral habitat above historic levels would result in an increase in fire intensity. The increased fire 

intensity would create hotter surface and canopy fires, resulting in damage and possible destruction of 

any ERURE plants because high soil temperatures can destroy underground portions of plants. The 

result would be a long-term moderate adverse direct effect. 

Conclusion—A surface fire and portions of a passive crown fire that remain on the surface 

would result in a short-term minor adverse direct effect on any ERURE sites because plants would 

recover in the short term. Passive and active crown fires would result in a long-term minor adverse 

indirect effect until destroyed canopy cover recovers. The cumulative effects of previous fire 

suppression management, associated high fuel loads, and increased fire ignitions would (1) increase 

risk of stand-replacing fire and create conditions for the spread and introduction of noxious weeds—

the result would be a long-term moderate adverse indirect effect because weed infestations would outcompete any ERURE plants and other native vegetation over time; and (2) create hotter surface fires, 

resulting in damage and possible destruction to ERURE plants and resulting in a long-term moderate 

adverse direct effect. 

Sensitive Fungi Species 

 Boletus pulcherrimus, Cudonia monticola, Dendrocollybia racemosa, Phaeocollybia

olivacea, Sowerbyella rhenana, Tricholomopsis fulvescens 
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There is no species-specific information available for the above 6 Sensitive fungi species that 

may be present within the project Assessment Area. General information is available, however, for the 

two major groups of fungi (mycorrhizal and saprophytic). Fungi differ from vascular plants 

(flowering plants) in several important ways that affect their response to management activities. 

Fungi do not have roots, but rather depend upon an extensive network of fungal mycelium to support 

the plants. Mycelia are fine, net-like structures that penetrate the soil, rotting wood, duff, or other 

substrates. Mycelia that penetrate the roots of vascular plants form mycorrhizae. The fruiting structure 

of a fungus can form anywhere along the network of mycelia. When the substrate within which the 

mycelial network occurs is disturbed, the fungus is not necessarily killed. Rather, the network will be 

broken into many fragmented parts that will continue to live and fruit as long as a nutrient source—

vascular plants for mycorrhizal species or rotten wood for saprophytic species—and a moisture 

source persists. Specifically, this means that ground disturbance from logging and fuel treatments, and 

changes in moisture levels from canopy removal (direct effect), will not necessarily kill fungi 

populations unless critical habitat elements are removed to an extent that the habitat can no longer 

support the fungi species (indirect effect) (USDA 2007). 

The following effects analyses are based primarily upon references provided in a literature review 

conducted by Lisa Hoover, Forest Botanist, Six Rivers National Forest (USDA 2007). There is little 

information available about species-specific effects, but information has been gathered about the 

effect of management actions upon ectomycorrhizal (ECM) fungi in general. While not eliminating 

potential effects to target fungal taxa, it is assumed that by managing for habitat elements, adverse 

effects on communities supporting any one of the target fungi will be reduced. 

Mycorrhizal Fungi Species— 

 Boletus pulcherrimus, Phaeocollybia olivacea

 Direct and Indirect Effects. Because there is an overall low probability that Boletus 

pulcherrimus (BOPU4) and Phaeocollybia olivacea (PHOL) are present within the project 

Assessment Area, there is also a low potential for an effect to individual fungi populations. The 

suitable habitat for these species is located along wet, north facing riparian areas within 25 feet of 

perennial streams, at the lower to mid-elevations, and within mature timber stands. A surface fire in 

these areas would generally be of low-intensity due to the higher moisture levels present. There is 

potential that a population could be affected if a portion is burned, but it is unlikely that a surface fire 

would burn at high intensity throughout the entire population. Because these species are not killed 

when a portion of a population is affected, this would not affect the entire population or habitat. 

Additionally, a surface fire would still retain important habitat elements including adequate mature 

live overstory and understory trees, substrate recruitment trees, and coarse and fine woody debris. The 

retention of these habitat elements would ensure that potential populations of these species would be 

maintained. A surface fire would result in a direct short-term minor adverse effect as individuals are 

destroyed but any entire population would be unaffected and/or recover in the short term. 

A passive or active crown fire would indirectly affect these two fungi species if suitable habitat 

elements are impacted. Because these two fungi are mycorrhizal with mixed-conifers and hardwood 

tree roots, if a passive or active crown fire destroys or damages mature overstory substrate trees (or 

substrate recruitment trees), and/or if canopy removal is extensive enough to significantly reduce 

adequate moisture levels, and/or if coarse woody debris is consumed, individuals would be indirectly 
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Section 3.7 – Botanical Resources and Noxious Weeds 3-191 

affected. Individuals might be burned, but, as with a surface fire, because these species are not killed 

when a portion of a population is affected, this would not affect the entire population or habitat. The 

overstory within the fungi’s riparian habitat, however, would burn with lower intensities than in 

upland stands and elements of suitable fungi habitat would be retained. The retention of these habitat 

elements would ensure that any populations of these species would be maintained. A passive or active 

crown fire would result in an indirect minor long-term adverse effect as some suitable fungi habitat 

would be damaged or destroyed and individual BPOU4 and PHOV would be impacted but any 

populations would remain or recover in the long term, and any impacted habitat elements would 

recover in the long term. 

 Cumulative Effects. The previous history of fire suppression has resulted in a buildup of 

ground and ladder fuels in the treatment units. The ongoing recreational (mining, hiking, hunting) and 

rural community activities in the project Assessment Area create potential for fire ignitions; these 

combined factors would increase the risk of stand-replacing wildfire in the treatment units. The direct 

and indirect effects of wildfire are discussed above. Future district projects expected to occur in the 

short- and long-term include annual road maintenance, fire suppression activities, the installation of 

telephone and fiber-optic lines (and associated disturbance from roadside trenches), and the North 

Fork Roads Stormproofing Project. Each of these district projects involves ground disturbance near 

road sides or other upland site locations, outside of BOPU4 and PHOV riparian habitat. Mining 

activities, however, do occur near streams and may occur within the riparian habitat of these two 

species. Ground disturbance from mining would damage or destroy individual BOPU4 or PHOV but 

any populations would be maintained. No cumulative effects are expected from effects from wildfire 

and mining. 

Conclusion—A surface fire would result in a direct short-term minor adverse effect as 

individuals are destroyed but any entire population would be unaffected and/or recover in the short 

term. A passive or active crown fire would result in an indirect minor long-term adverse effect as 

some suitable fungi habitat would be damaged or destroyed and individual BPOU4 and PHOV would 

be impacted but any populations would remain or recover in the long term, and any impacted habitat 

elements would recover in the long term. And mining activities would result in direct short-term 

negligible adverse effects as individual BOPU4 and PHOV may be destroyed but any populations 

would be maintained. No cumulative effects to these two fungi species are expected from wildfire and 

mining activities. 

Saprophytic Fungi Species— 

 Cudonia monticola, Dendrocollybia racemosa, Sowerbyella rhenana, Tricholomopsis 

fulvescens 

 Direct and Indirect Effects. Because there is an overall low probability that Cudonia 

monticola (CUMO2), Dendrocollybia racemesas (DERA5), Sowerbyella rhenana (SORH), and 

Tricholomopsis fulvescens (TRFU3) are present within the proposed project activity areas, there is 

also a low potential for an effect to individual fungi populations. The suitable habitat for these species 

is located along wet, north facing riparian areas within 25 feet of perennial streams, at the lower to 

mid-elevations, and within mature timber stands. A surface fire in these areas would generally be of 

low-intensity due to the higher moisture levels present. There is potential that a population could be 

affected if a portion is burned, but it is unlikely that a surface fire would burn at high intensity 
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throughout the entire population. Because these species are not killed when a portion of a population 

is affected, this would not affect the entire population or habitat. Additionally, a surface fire would 

still retain important habitat elements including adequate coarse and fine woody debris as fungi 

substrate and stand and surface moisture levels. The retention of these habitat elements would ensure 

that potential populations of these species would be maintained. A surface fire would result in a direct 

short-term minor adverse effect as individuals are destroyed but any entire population would be 

unaffected and/or recover in the short term. 

A passive or active crown fire would indirectly affect these four fungi species if suitable habitat 

elements are impacted. The four saprophytic fungi obtain nutrients from the decomposition of dead 

organic matter and are dependent upon adequate amounts of leaves, needles, limbs, large woody 

debris, other decomposing forest litter, or even dead animal carcasses to provide a substrate and to 

supply a continuous source of nutrients. Soil moisture is also important. The removal of canopy cover 

itself from a passive or active crown fire would not affect these species directly. If canopy cover is 

extensive enough to significantly reduce adequate soil moisture levels, and/or if coarse woody debris 

is also consumed, individuals would be indirectly destroyed or damaged, but because these species 

are not killed when a portion of a population is affected, this would not affect the entire population or 

habitat. The overstory within the fungi’s riparian habitat, however, would burn with lower intensities 

than in upland stands and elements of suitable fungi habitat would be retained. The retention of these 

habitat elements would ensure that any populations of these species would be maintained. A passive 

or active crown fire would result in an indirect minor long-term adverse effect as some suitable fungi 

habitat would be damaged or destroyed, individual CUMO2, DERA5, SORH and TRFU3 would be 

impacted but any populations would remain or recover in the long term, and impacted habitat 

elements (soil moisture) would recover in the long term. 

 Cumulative Effects. The previous history of fire suppression has resulted in a buildup of 

ground and ladder fuels in the treatment units. The ongoing recreational (mining, hiking, hunting) and 

rural community activities in the project Assessment Area create potential for fire ignitions; these 

combined factors would increase the risk of stand-replacing wildfire in the treatment units. The direct 

and indirect effects of wildfire are discussed above. Future district projects expected to occur in the 

short- and long-term include annual road maintenance, fire suppression activities, the installation of 

telephone and fiber-optic lines (and associated disturbance from roadside trenches), and the North 

Fork Roads Stormproofing Project. Each of these district projects involves ground disturbance near 

road sides or other upland site locations, outside of CUMO2, DERA5, SORH and TRFU3 riparian 

habitat. Mining activities, however, do occur near streams and may occur within the riparian habitat 

of these two species. Ground disturbance from mining would damage or destroy individual fungi but 

any populations would be maintained. No cumulative effects are expected from effects from wildfire 

and mining. 

Conclusion—A surface fire would result in a direct short-term minor adverse effect as 

individuals are destroyed but any entire population would be unaffected and/or recover in the short 

term. A passive or active crown fire would result in an indirect minor long-term adverse effect as 

some suitable fungi habitat would be damaged or destroyed, individual CUMO2, DERA5, SORH and 

TRFU3 would be impacted but any populations would remain or recover in the long term, and 

impacted habitat elements (soil moisture) would recover in the long term. And mining activities 

would result in direct short-term negligible adverse effects as individual fungi would be destroyed but 
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Section 3.7 – Botanical Resources and Noxious Weeds 3-193 

any populations would be maintained. No cumulative effects to these four fungi species are expected 

from wildfire and mining activities. 

Sensitive Bryophyte Species 

 Ptilidium californicum (Pacific Fuzzwort)—PTCA5 

Direct and Indirect Effects. Two populations of PTCA5 occur in the Assessment Area on 

northwest aspects, at the base of large-diameter white fir trees in upper elevation forests. The effect of 

a wildfire on this species is dependent on the intensity of the fire. A surface fire (19 percent of the 

fire) would result in damage to or loss of some or all PTCA5 plants. Where all plants are destroyed, 

recolonization is not likely to occur because PTCA5 does not recolonize over long distances and does 

not occur on burned substrates. Where a portion of a PTCA5 population remains, recolonization 

would occur slowly, with a short- to long-term recovery. A surface fire that also consumes PTCA5 

microhabitat components (duff layers and coarse woody debris, logs, associated bryophyte 

populations) would have an adverse indirect effect on PTCA5; the loss of microhabitat components 

that regulate humidity, temperature, and shade would lessen or slow the recovery and recolonization 

of PTCA5. 

A passive crown fire (70 percent of fire) would have the same effects as a surface fire with the 

additional loss of canopy trees in scattered locations. The loss of scattered canopy cover would alter 

critical PTCA5 habitat components (increased solar radiation, increased temperature, decreased soil 

moisture, decreased humidity, and a decrease in potential substrate tree bases), and unburned PTCA5 

populations would decline because recovery and recolonization of burned plants would be 

significantly reduced. 

An active crown fire (11 percent of the fire) would include the same effects as a surface fire and 

burn with greater intensity and remove all canopy cover. The active crown fire would result in the 

loss of all PTCA5 plants. PTCA5 recolonization would be unlikely or negligible and would not occur 

until a mature, closed-canopy forest is re-established. 

PTCA5 ranges from southeast Alaska, south to northern California. The loss of Assessment Area 

PTCA5 plants would result in a negligible adverse effect on the viability of this species. However, 

because the northern California PTCA5 populations represent the southern extent of the species and 

may be a fragment of a relict population, these populations should be managed to maintain the genetic 

diversity of this species (USFS 1997a, 2006b). 

 Cumulative Effects. The previous history of fire suppression has resulted in a build up of 

ground and ladder fuels in the treatment units. The ongoing recreational (mining, hiking, hunting) and 

rural community activities in the Assessment Area create potential for fire ignitions; these combined 

factors would increase the risk of stand-replacing wildfire in the treatment units. A frequent result of 

stand-replacing wildfires, and the corresponding suppression activities, is the formation of conditions 

favorable to noxious weed invasion. Competition from invasive noxious weeds would affect other 

vegetation (herbaceous and shrub layers) in PTCA5 stands, but would have a minor effect on the 

recovery or recolonization of PTCA5. District projects that include roadside disturbance (such as 

annual road maintenance and hazard tree removal, the digging of a roadside trench for telephone and 

fiber-optic line installation, and fire suppression activities) could damage PTCA5 plants or alter 
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3-194 Chapter 3: Affected Environment and Environmental Consequences

habitat as roadside trees are removed or disturbed. Disturbances would affect the roadside PTCA5 

population (PTCA5-#TE1) located on the northwest side of a roadside tree, approximately one mile 

south of Bacon Rind. If the substrate tree is removed, and no other disturbance occurs, the PTCA5 

population would have no immediate adverse effects. As the stump dies and bark sloughs off, the 

PTCA5 population would slowly decline and eventually die as the plant’s substrate deteriorates. If 

project activities along roads disturb the substrate tree or the PTCA5 plants directly, the population is 

likely to decline or be destroyed, and recolonization would be slow if at all. Where project activities 

along roads alter overstory habitat or other critical PTCA5 habitat features (humidity, soil moisture, 

shade, and associated bryophyte cover), individual PTCA5 plants and the population viability would 

decline over time. 

Conclusion—A surface fire and portions of a passive crown fire that remain on the surface 

would damage or destroy PTCA5 plants and result in short- and long-term minor to major adverse 

direct effects. A surface fire and portions of a passive crown fire would also alter important PTCA5 

habitat microhabitat features that would damage PTCA5 plants or slow the recovery/recolonization of 

PTCA5—the result would be short- and long-term minor to major adverse indirect effects on PTCA5. 

Where the overstory is removed as a result of a passive or active crown fire, PTCA5 habitat would be 

altered and PTCA5 plants would decline or die—the result would be a long-term moderate adverse 

indirect effect on PTCA5. The cumulative effects of increased fire ignitions and increased fuel loads 

from previous fire suppression management would increase the risk of stand-replacing fire and 

conditions for noxious weeds infestation into PTCA5 populations; the result would be a long-term 

minor adverse indirect effect on PTCA5. Cumulative effects from other district projects that disturb 

roadsides would result in a long-term moderate adverse direct effect from removing or damaging the 

PTCA5 substrate tree, and a long-term moderate adverse indirect effect from habitat alteration 

leading to the decline or loss of PTCA5 plants. 

Sensitive Lichen Species 

 Hydrothyria venosa (syn. Peltigera hydrothyria) (Waterleaf Lichen)—HYVE7 

 Direct and Indirect Effects. No sites of Hydrothyria venosa (HYVE7) are known to occur in 

the Assessment Area. Surveys in 2008 included a number of streams with low to moderate potential 

HYVE7 habitat. Additional potential habitat may occur outside of the 2008 survey areas. 

A surface fire (19 percent of a wildfire) would have no direct effect on this species because it 

occurs on rocks in perennial streams. Surface fires would, however, burn small understory trees and 

ground fuels along riparian areas, which would improve HYVE7 riparian habitat by (1) removing 

fuels and avoiding the potential for a destructive wildfire, and (2) increasing resources for riparian 

overstory trees that contribute shade and moderate stream temperatures important to HYVE7 

viability. The improved riparian habitat would result in a moderate short-term beneficial indirect 

effect until understory vegetation recovers and ground fuels are replaced. 

A passive or active crown fire (70 and 11 percent, respectively) would also not affect HYVE7 

directly, but would indirectly affect HYVE7 habitat. Passive and active crown fires would destroy 

some or all overstory trees along HYVE7 riparian habitat, which would result in a loss of important 

overstory shade and an increase in stream temperatures as solar radiation increases. The increased 
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Section 3.7 – Botanical Resources and Noxious Weeds 3-195 

solar radiation would result in a moderate indirect adverse long-term effect until overstory canopy is 

restored. 

 Cumulative Effects. The previous history of fire suppression has resulted in a build up of 

ground and ladder fuels in the Assessment Area. The ongoing recreational (mining, hiking, hunting) 

and rural community activities in the Assessment Area create potential for fire ignitions; these 

combined factors would increase the risk of stand-replacing wildfire in the treatment units. A frequent 

result of stand-replacing wildfires, and the corresponding suppression activities, is the formation of 

conditions favorable to noxious weed invasion. Noxious weed infestations are unlikely to directly 

affect any HYVE7 sites. Stand-replacing fires often result in post-fire increases in stream flows and 

siltation when large amounts of upland vegetation are consumed. The increase in stream flows and 

siltation would directly destroy HYVE7 plants and HYVE7 habitat, resulting in long-term moderate 

adverse indirect effects on HYVE7 until stream flows and siltation levels recover. Mining activities 

along streams with any HYVE7 sites are also likely to affect this aquatic lichen by disturbing HYVE7 

substrate habitat (rocks) and destroying plants and indirectly increasing stream siltation. Mining 

activities in HYVE7 sites would result in (1) a long-term moderate adverse direct effect if HYVE7 

substrate or plants are destroyed or disturbed, and (2) a long-term moderate adverse indirect effect if 

siltation levels increase and destroy plants. 

Conclusion—A surface fire would result in no direct effect on HYVE7 and a moderate 

indirect beneficial short-term effect until understory vegetation recovers and ground fuels are 

replaced. A passive or crown fire would increase solar radiation along HYVE7 riparian habitat and 

result in a moderate indirect adverse long-term effect until overstory canopy is restored. Cumulative 

effects of Alternative A include the likelihood of a stand-replacing fire with (1) an increase in noxious 

weeds and stream flows and stream siltation levels following the stand-replacing wildfire. The results 

include (1) no short-term or long-term direct effect on HYVE7 plants from weed infestations, and 

(2) a long-term moderate adverse indirect effect until stream flows and siltation levels recover. 

Mining activities would also have a cumulative effect by disturbing or destroying HYVE7 plants or 

habitat, resulting in (1) a long-term moderate adverse direct effect if HYVE7 substrate or plants are 

destroyed or disturbed, and (2) a long-term minor to moderate adverse indirect effect if siltation levels 

increase and indirectly destroy plants. 

3.7.4.3 Alternative B: Proposed Action 

Sensitive Vascular Species 

 Cypripedium fasciculatum—Clustered Lady-slipper Orchid—CYFA 

 Cypripedium montanum—Mountain Lady-slipper Orchid—CYMO2 

 Smilax jamesii—English Peak Greenbriar—SMJA 

 Direct and Indirect Effects: CYFA and CYM02. Twenty-one CYFA and 12 CYMO2 sites 

occur in the Assessment Area, within all treatment types (FRZs and Rx Units, RS treatments in FRZs, 

and within Riparian Reserves in both FRZs and Rx Units). The resource protection measures for 

CYFA and CYM02 have been designed into the Proposed Action (refer to Table 3-3). The resource 

protection measures (RPMs) are intended to protect individual plants and maintain habitat 

characteristics that are critical to the maintenance of long-term viable plant populations, in 

accordance with the desired conditions of the Standards and Guidelines contained in the Klamath 
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3-196 Chapter 3: Affected Environment and Environmental Consequences

National Forest Land and Resource Management Plan (Klamath LRMP) (USFS 1995). While it is 

assumed that CYFA and CYMO2 have evolved with wildfire in the landscape, the levels of ground 

and ladder fuels in these sites is considered outside the historic range due to fire suppression. The 

resource protection measures, therefore, allow fuel reduction treatments to occur in stands containing 

CYFA and CYMO2 sites when it is outside the active growing period, or if within the growing period, 

those sites will be protected from treatments with a 25-foot buffer. With the implementation of the 

resource protection measures, Alternative B would enhance CYFA and CYMO2 habitat and protect 

plants from potential mortality from a stand-replacing fire and likely lead to long-term viability of the 

CYFA and CYMO2 populations in the Assessment Area. 

 Cumulative Effects: CYFA and CYM02. Ongoing district projects and projects scheduled for 

the foreseeable future include annual road maintenance, improvements to existing mining claims, 

hiking, and appropriate responses for fire suppression, installation of utility lines with associated 

roadside trenching, the North Fork Roads Stormproofing Project, and the construction of a fuelbreak 

system west of Black Bear Ranch. The Proposed Action would prevent the risk of stand-replacing fire 

from the cumulative effects of a previous history of fire suppression, a build up of ground and ladder 

fuels in the treatment units, and the potential for fire ignitions from the ongoing recreational (mining, 

hiking, hunting) and rural community activities in the Assessment Area. The prevention of standreplacing fire would benefit these two species by preventing the direct loss or damage of CYFA and 

CYMO2 plants and habitat from fire. 

A secondary benefit of the prevention of stand-replacing fire is the prevention of a potential weed 

infestation—a frequent result of stand-replacing wildfires and the corresponding suppression 

activities. The prevention of a weed infestation would directly benefit CYFA and CYMO2 by 

avoiding competition that could lead to a decline in native vegetation and CYFA and CYMO2 

populations. Other district projects, however, may increase the potential for noxious weed invasion 

through ground disturbance (that is, disturbance from annual road maintenance, fire suppression 

activities, the digging of a roadside trench for telephone and fiber-optic line installation, and the 

North Fork Roads Stormproofing Project). A weed infestation would compete with native vegetation 

and CYFA and CYMO2 populations and lead to a decline in population viability. Dyer’s woad is the 

most likely local noxious weed species to invade CYFA and CYMO2 habitat. While this weed is 

frequently found on roadsides and in open, disturbed dry sites, at least one site in the Assessment Area 

continues down into a riparian area. 

Conclusion: CYFA and CYMO2—The Proposed Action, with the implementation of 

resource protection measures, would result in long-term moderate beneficial direct and indirect 

effects on CYFA and CYMO2 populations as long-term population viability is enhanced, and plants 

and habitat are protected from a stand-replacing wildfire and secondary weed infestation. The 

cumulative effects of district projects that create ground disturbance may increase weed infestations 

in CYFA and CYMO2 habitat that would out-compete native vegetation and CYFA and CYMO2 

plants and contribute to the decline of CYFA and CYMO2 populations; the result would be a longterm moderate adverse indirect effect on CYFA and CYMO2 populations. 

 Direct and Indirect Effects: SMJA. One SMJA site occurs in a Riparian Reserve within an 

Rx Unit. The prescribed fire treatments in Riparian Reserves have been modified to protect riparian 

resources and include the following: (i) the building of handlines will stop within 25 feet of the 
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Section 3.7 – Botanical Resources and Noxious Weeds 3-197 

wetted edge of channels; (ii) prescribed fires will be ignited to minimize potential for moderate- or 

high-intensity burns; and (iii) when underburning, at least 90 percent of the large woody debris will 

not be consumed, both standing and on the ground. The low-intensity fires proposed for the SMJA 

habitat in the Riparian Reserve would directly burn above-ground portions (leaves, flowers/fruits, or 

stems) but not damage below-ground portions (caudex, roots) of SMJA. SMJA plants would recover 

in the short term. The low-intensity fires would enhance SMJA habitat by removing low to moderate 

amounts of competing vegetation and ground fuels and small-diameter trees. The removal of 

competing vegetation and understory fuels would reduce competition for resources until vegetation 

recovers and fuel loads eventually increase. 

 Cumulative Effects: SMJA. The Proposed Action would reduce the risk of stand-replacing 

fire that would result from the cumulative effects of a previous history of fire suppression, a build up 

of ground and ladder fuels in the treatment units, and the potential for fire ignitions from the ongoing 

recreational (mining, hiking, hunting) and rural community activities in the Assessment Area. The 

prevention of stand-replacing fire would benefit this species by avoiding the direct loss or damage of 

SMJA plants and habitat from fire. A secondary benefit of the prevention of stand-replacing fire is the 

prevention of a potential noxious weed infestation—a frequent result of stand-replacing wildfires and 

the corresponding suppression activities. The prevention of a weed infestation would directly benefit 

SMJA by avoiding competition that could lead to a decline in native vegetation and the SMJA 

population. Other district projects, however, that create disturbance along riparian areas (that is, 

improvements to mining claims) could destroy or damage SMJA plants directly or indirectly through 

alteration of riparian habitat. 

Conclusion—The proposed fuel reduction treatments under the Proposed Action would result 

in (1) a short-term negligible adverse direct effect if plants burn and then recover, and (2) a long-term 

moderate beneficial indirect effect as SMJA riparian habitat is enhanced and competition for 

resources is reduced, and plants and habitat are protected from a stand-replacing fire and secondary 

weed infestation. Cumulative effects from mining claim improvement activities in riparian areas may 

result in long-term minor to moderate adverse direct and indirect effects on SMJA as plants and/or 

habitat are destroyed or damaged. 

Additional SMJA sites may occur in proposed treatment units outside of the 2008 survey areas. 

Any new SMJA sites would occur in riparian habitat within FRZs or Rx Units. This species is 

unlikely to occur in RS treatments or in mechanical thinning units in FRZs, which are located on 

uplands and ridgetops. Any SMJA sites in riparian zones of FRZs or Rx Units would have the same 

effects as the known SMJA site described above. 

Nine Sensitive Target Species Assumed to be Present 

Species of Moist (and Riparian) Environments— 

 Botrychium virginianum (Rattlesnake Fern)—BOVI 

 Campanula wilkinsiana (Wilkin’s harebell)—CAWI8 

 Smilax jamesii (English Peak Greenbriar)—SMJA 

The effects on SMJA from implementing Alternative B is included in the section above. 
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3-198 Chapter 3: Affected Environment and Environmental Consequences

 Direct and Indirect Effects. No BOVI or CAWI8 sites are known to occur in the proposed 

treatment units. This effects analysis assumes that some number of BOVI and CAWI8 sites may occur 

in proposed FRZs or Rx Units outside the 2008 botany survey areas. BOVI and CAWI8 occur in 

moist habitats including meadows, seeps, bogs, and streamsides. This habitat is common in both 

FRZs and Rx Units within Riparian Reserves. BOVI and CAWI8 habitat is less likely to occur in 

mechanical thinning units located along upland and ridgeline areas and is unlikely in proposed RS 

treatments. The proposed treatments in Riparian Reserves in FRZs include mastication (on slopes less 

than 45 percent) or hand thinning and piling (on slopes greater than 45 percent) to remove small trees 

in FRZs. Within Riparian Reserves in Rx Units, low-intensity backing fires are proposed. 

The implementation of mastication or hand-thinning and piling of small trees in FRZs would 

damage or destroy BOVI and CAWI8 plants and result in a long-term minor to moderate adverse 

direct effect as few plants would recover or recolonize. The use of low-intensity backing fires in Rx 

Units would damage some above-ground portions of any BOVI or CAWI8 plants and would result in 

a short-term minor adverse direct effect as plants would recover and recolonize. The post-treatment 

reduction in ground and small ladder fuels in stands where these two species might occur would result 

in long-term moderate beneficial indirect effects because the likelihood of stand-replacing wildfires 

would be reduced, and BOVI and CAWI8 site stability and vigor would be maintained in the long 

term. 

 Cumulative Effects. The Proposed Action would reduce the risk of stand-replacing fire 

resulting from the cumulative effects of a previous history of fire suppression, a build up of ground 

and ladder fuels in the treatment units, and the potential for fire ignitions from the ongoing 

recreational (mining, hiking, hunting) and rural community activities in the Assessment Area. A 

secondary benefit is the avoidance of potential noxious weed infestations—a frequent result of standreplacing wildfires and the corresponding suppression activities. The prevention of a weed infestation 

would directly benefit BOVI and CAWI8 sites by avoiding competition that could lead to a decline in 

native vegetation and the BOVI and CAWI8 plants. Other activities (such as improvements to mining 

claims), however, that create disturbance along riparian areas could destroy and/or damage BOVI or 

CAWI8 plants. 

Conclusion—The implementation of proposed fuels reduction treatments would result in 

long-term minor to moderate adverse direct effects as mastication destroys BOVI and CAWI8 plants 

and short-term minor adverse direct effects from low-intensity backing fires. The reduction in fuels 

and the avoidance of stand-replacing fire and weed infestation would result in long-term moderate 

beneficial indirect effects as BOVI and CAWI8 site stability and vigor in increased or maintained. 

Cumulative effects from mining claim improvement activities within riparian areas may result in 

long-term minor to moderate adverse effects if BOVI and CAWI8 plants and riparian habitat are 

destroyed or damaged. 

Species of Serpentine Environments— 

 Chaenactis suffrutescens (Shasta chaenactis)—CHSU 

 Eriogonum hirtellum (Klamath Mountain Buckwheat)—ERHI7 

 Minuartia stolonifera (Scott Mountain sandwort)—MIST9 
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Section 3.7 – Botanical Resources and Noxious Weeds 3-199 

No CHSU, ERHI7, or MIST9 sites are known to occur in the proposed treatment units. This 

effects analysis assumes that some number of CHSU, ERHI7, or MIST9 sites may occur in proposed 

FRZs or Rx Units outside the 2008 botany survey areas. These three species occur in serpentine or 

ultramafic soils. These soil types are known to occur in FRZs and Rx Units in the Matthews Creek 

area, in the far southwestern region, and on FRZs on two ridgelines located west and east of East 

Crawford Creek. 

 Direct and Indirect Effects. Implementation of prescribed fire to reduce fuels in FRZs and 

Rx Units would burn above-ground portions (leaves, flowers/fruits, or stems) but not damage belowground portions (caudex, roots) of CHSU, ERHI7, and MIST9 plants. The result would be a shortterm minor adverse direct effect on any CHSU, ERHI7, and MIST9 sites as plants would recover in 

the short-term. The implementation of prescribed fire would have a secondary indirect effect on the 

habitat of these species. Prescribed fire would cause, (to a lesser degree than a wildfire), an increase 

in competing early seral vegetation cover (such as grass species), with a resulting decrease in plants at 

any CHSU, ERHI7, or MIST9 sites. The result is an indirect long-term minor adverse effect as the 

increase in competing early seral vegetation would out-compete some CHSU, ERHI7, and MIST9 

plants for resources. Mastication treatments (on slopes less than 45 percent) would damage or destroy 

to CHSU, ERHI7, and MIST9 plants from mechanical disturbance and result in long-term minor to 

moderate adverse direct effects as some plants would slowly recover and others would be lost. The 

reduction in ground and small ladder fuels in stands where these three species might occur would 

result in long-term moderate beneficial indirect effects because the likelihood of stand-replacing 

wildfires would be reduced, and CHSU, ERHI7, or MIST9 site stability and vigor would be 

maintained in the long term. 

 Cumulative Effects. The Proposed Action would reduce the risk of stand-replacing fire 

resulting from the cumulative effects of a previous history of fire suppression, a build up of ground 

and ladder fuels in the treatment units, and the potential for fire ignitions from the ongoing 

recreational (mining, hiking, hunting) and rural community activities in the Assessment Area. The 

avoidance of stand-replacing fire would benefit CHSU, ERHI7, and MIST9 sites by avoiding the 

direct loss or damage of plants and habitat. A secondary beneficial effect would be the avoidance of 

potential noxious weed infestations—a frequent result of stand-replacing wildfires and the 

corresponding suppression activities. The prevention of a weed infestation would directly benefit sites 

by avoiding competition that could lead to a decline in native vegetation and CHSU, ERHI7, and 

MIST9 plants. 

Conclusion—The implementation of prescribed burning in proposed FRZs and Rx Units 

would result in (1) short-term minor adverse direct effects if CHSU, ERHI7, or MIST9 plants are 

damaged and recover in the short term, and (2).an indirect long-term minor adverse effect as the 

increase in competing early seral vegetation would out-compete some CHSU, ERHI7, and MIST9 

plants for resources. Mastication treatments (on slopes less than 45 percent) would damage or destroy 

to CHSU, ERHI7, and MIST9 and would result in long-term minor to moderate adverse direct effects 

if plants are damaged or destroyed but result in some level of recovery. Post-treatment reductions of 

fuel loads and avoidance of stand-replacing fire and weed infestations would result in long-term 

moderate beneficial indirect effects on CHSU, ERHI7, and MIST9 site vigor and stability. 
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3-200 Chapter 3: Affected Environment and Environmental Consequences

Species of Canopy Gap and Forest Edge Environments— 

 Eucephalis vialis (Wayside Aster)—EUVI8 

 Pedicularis howellii (Howell’s lousewort)—PEHO 

No sites of EUVI8 or PEHO are known to occur in the proposed treatment units. This effects 

analysis assumes that some number of EUVI8 and PEHO sites may occur in treatment units outside 

the 2008 botany survey areas. These two species occur in canopy gaps and forest edge habitat, 

including habitat maintained by fire. EUVI8 also occurs in manmade openings along roads. Canopy 

gap and forest edge habitat occurs in proposed FRZs and Rx Units and RS treatments along 

emergency access routes. 

 Direct and Indirect Effects. Implementation of prescribed fire to reduce fuels in FRZs and 

Rx Units would burn plants above-ground potions (leaves, flowers/fruits, or stems) and leave belowground portions (caudex, roots) undamaged. Both species occur in habitat maintained by fire; plants 

burned in a prescribed fire would re-sprout, and EUVI8 or PEHO plant vigor and long-term site 

stability would be increased or maintained. Prescribed fire would, therefore, result in a long-term 

moderate beneficial direct effect. Mastication (on slopes less than 45 percent) and mechanical 

thinning treatments in FRZs would damage or destroy EUVI8 and PEHO plants and result in longterm minor to moderate adverse direct effects as some plants would slowly recover and others would 

be lost. Mechanical thinning would also increase suitable EUVI8 and PEHO habitat by opening 

overstory canopy cover, resulting in a long-term moderate beneficial indirect effect on any EUVI8 or 

PEHO site not destroyed by the mechanical disturbance of the thinning treatment. 

 Cumulative Effects. The cumulative effects of district projects with mechanical disturbance 

to roadsides have the potential to create long-term minor to moderate adverse direct effects if roadside 

EUVI8 or PEHO plants are disturbed or destroyed. The Proposed Action would reduce the risk of 

stand-replacing fire resulting from the cumulative effects of a previous history of fire suppression, a 

build up of ground and ladder fuels in the treatment units, and the potential for fire ignitions from the 

ongoing recreational (mining, hiking, hunting) and rural community activities in the Assessment Area. 

The avoidance of stand-replacing fire would benefit EUVI8 and PEHO sites by avoiding the direct 

loss or damage of plants and habitat. A secondary beneficial effect would be the avoidance of 

potential noxious weed infestations—a frequent result of stand-replacing wildfires—and the 

corresponding suppression activities. The prevention of a weed infestation would directly benefit sites 

by avoiding competition that could lead to a decline in native vegetation and EUVI8 and PEHO 

plants. 

Conclusion—The implementation of proposed FRZs and Rx Units would result in long-term 

minor to moderate beneficial direct effects, and mastication and mechanical thinning treatments 

would result in both long-term minor to moderate adverse direct effects and minor to moderate 

beneficial long-term indirect effects. The post-treatment reduction in fuels and the avoidance of standreplacing fire and weed infestation would result in long-term moderate beneficial indirect effects as 

EUVI8 and PEHO site vigor is increased or maintained over the long term. 

Species of Montane Chaparral and Mixed-Conifer Forest Environments— 

 Eriogonum ursinum var. erubescens (Blushing Buckwheat)—ERURE 
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Eddy Gulch LSR Project Klamath National Forest

Section 3.7 – Botanical Resources and Noxious Weeds 3-201 

No ERURE sites are known to occur in the proposed treatment units. This effects analysis does 

assume that some number of ERURE sites occur in proposed treatments units outside the 2008 

botanical survey areas. ERURE occurs in chaparral and open conifer/mountain mahogany habitat. 

This habitat type is most likely to occur in FRZs where prescribed burn and mastication treatments 

are proposed. 

 Direct and Indirect Effects. The implementation of prescribed fire treatments to reduce fuels 

in FRZ and Rx Units would burn above-ground portions (leaves, flowers/fruits, or stems) of plants 

and leave below-ground portions (caudex, roots) undamaged. The result would be a short-term minor 

adverse direct effect as burned ERURE plants would re-sprout in the short term. Mastication (on 

slopes less than 45 percent) or mechanical thinning in FRZs would damage or destroy EUVI8 and 

PEHO plants and result in long-term minor to moderate adverse direct effects as some plants would 

slowly recover and others would be lost. 

 Cumulative Effects. The Proposed Action would reduce the risk of stand-replacing fire 

resulting from the cumulative effects of a previous history of fire suppression, a build up of ground 

and ladder fuels in the treatment units, and the potential for fire ignitions from the ongoing 

recreational (mining, hiking, hunting) and rural community activities in the Assessment Area. The 

avoidance of stand-replacing fire would benefit ERURE sites by avoiding the direct loss or damage of 

plants and habitat. A secondary beneficial effect would be the avoidance of potential noxious weed 

infestations—a frequent result of stand-replacing wildfires—and the corresponding suppression 

activities. The prevention of a weed infestation would directly benefit sites by avoiding competition 

that could lead to a decline in native vegetation and ERURE plants. 

 Conclusion—The implementation of proposed FRZs and Rx Units would result in shortterm minor adverse direct effects, and mastication and mechanical thinning treatments would result in 

long-term minor to moderate adverse direct effects on ERURE sites. The post-treatment reduction in 

fuels and the avoidance of stand-replacing fire and weed infestation would result in long-term 

moderate beneficial indirect effects as ERURE site vigor is increased or maintained over the long 

term.

Sensitive Fungi Species 

 Boletus pulcherrimus, Cudonia monticola, Dendrocollybia racemosa, Phaeocollybia 

olivacea, Sowerbyella rhenana, Tricholomopsis fulvescens 

Several studies that have examined the effects of prescribed fire have found that the effects to 

mycorrhizal fungal species are related to the intensity of the fire within the species’ habitat. Fires that 

do not fully consume the large woody debris, litter, and organic layers and also retain moisture have 

reduced effects on fungi (USDA 2007). Fuel treatment prescriptions that retain adequate live 

overstory, understory, and shrub species would retain sufficient host species to form mycorrhizal 

connections. No specific studies have been found that have examined the effects of fuel treatments 

specifically upon saprophytic species. The effects are likely to be similar to those seen upon 

mycorrhizal species, which require canopy cover and large woody material to retain moisture levels 

within their habitat. This effects analysis is based on the assumption that the relationships will be 

similar to that seen in the studies cited above. Because there is an overall low probability that the 
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6 Sensitive fungi species are present within the proposed project activity areas, there is also a low 

potential for an effect to individual fungi populations. 

The Proposed Action includes mechanical and fuels treatments to reduce fuels. Suitable habitat in 

the project Assessment Area for the 6 Sensitive fungi species is located along wet, north-facing 

riparian areas within 25 feet of perennial streams, at the lower to mid-elevations, and within mature 

timber stands. Suitable habitat for the 6 Sensitive fungi does not occur within the proposed 

mechanical treatment units (M Units), located on ridges and upper slope positions. 

 Direct and Indirect Effects 

 Mechanical Treatments—The implementation of proposed mechanical treatments will have 

no effect on the 6 Sensitive fungi species as these species do not occur in the M Units. 

 Prescribed Fire Treatments—Suitable habitat for the 6 fungi is restricted to Riparian 

Reserves within the project Assessment Area. Prescribed burn activities in FRZ and Rx Units will be 

modified in these areas to reduce effects, i.e., underburning will be allowed to back into the Riparian 

Reserves down to the riparian area (see the Resource Protection Measures in Chapter 2, Section 2.10

of this final EIS or refer to the Botanical Resources Report). The prescription will retain an adequate 

percentage of the live tree overstory that will ensure the preservation of shade and a diverse mix of 

tree species to support underground ectomycorrhizal linkages, and will maintain mycorrhizal species. 

Understory trees, shrubs, and coarse woody debris will be reduced, but maintained at adequate levels 

to support the fungi that depend upon these vascular plant species. Saprophytic fungi species will be 

maintained by underburn prescriptions that ensure a low-intensity burn that will retain adequate 

woody debris. Best Management Practices (BMP) are being applied to provide adequate soil cover to 

prevent erosion, which will retain additional coarse woody debris and duff as a substrate for 

saprophytic fungi. There would be a long-term beneficial effect to the fungi species habitat through 

the maintenance of suitable habitat and by reducing the risk of stand-replacing wildfires. 

Underburning would burn some number of individual fungi populations. Because mycorrhizal 

and saprophytic fungi have large underground systems, any entire populations of the fungi would not 

be affected. Fungi species readily regenerate after impacts to a portion of the population as long as 

adequate vegetative cover, species diversity, soil cover and coarse woody debris is maintained. The 

habitat would not be affected to the extent that it would no longer be suitable for the fungi. In 

summary, prescribed burn activities in FRZ and Rx Units would result in (1) a direct short-term 

negligible adverse effect to individual fungi as underburning destroys some number of individuals 

(but entire populations are not impacted), and (2) an indirect long-term moderate beneficial effect as 

suitable fungi habitat is maintained and the risk of stand replacing wildfires are reduced. 

 Mastication Treatments—Mastication treatments are proposed to occur, within 875 acres of 

Riparian Reserves within FRZs on slopes less than 45 percent and within 0.25 mile of roads. No 

specific studies have been found that have examined the effects of mastication activities specifically 

upon fungi species. While mastication activities would likely destroy or damage some individuals 

and/or the substrate of some saprophytic fungi, the fungi populations would not be killed. When the 

substrate within which the mycelial network occurs is disturbed, the fungus is not necessarily killed. 

Rather, the network will be broken into many fragmented parts that will continue to live and fruit as 

long as a nutrient source—vascular plants for mycorrhizal species or rotten wood for saprophytic 
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Section 3.7 – Botanical Resources and Noxious Weeds 3-203 

species—and a moisture source persists. Mastication treatments also include leaving mulched coarse 

and fine woody debris on site. The increase in fine and coarse woody debris is expected to have a 

negligible to beneficial impact on fungi individuals. The increased woody debris is expected to 

increase forest floor moisture that would benefit both saprophytic and mycorrhizal fungi, and would 

increase substrate source for the saprophytic species. In summary, proposed mastication treatments 

would result in (1) a direct short-term minor adverse effect as individual fungi would be destroyed or 

damaged but any populations would persist and recover in the short term, and (2) an indirect shortterm minor beneficial effect as increased fine and coarse woody debris cover would increase forest 

floor moisture and provide increased substrate for saprophytic fungi species. 

 Roadside Fuels Treatments—Roadside (RS) treatments are proposed for 69.5 acres of 

Riparian Reserves. A masticator would be used on slopes less than 45 percent to remove trees less 

than 10 inches dbh, and hand thinning and pile burning would be used to remove trees up to 6 inches 

dbh on slopes greater than 45 percent. Hand thinning and pile burning would likely destroy or damage 

some fungi individuals and/or the substrate of some saprophytic fungi, the fungi populations would 

readily regenerate as long as adequate vegetative cover, species diversity, soil cover and coarse 

woody debris is maintained. The RS treatments would result in direct short-term minor adverse 

effects as individual fungi and/or substrate for saprophytic fungi species would be destroyed or 

damaged but any populations would persist and recover in the short term. 

 Cumulative Effects. The Proposed Action would reduce the risk of stand-replacing fire 

resulting from the cumulative effects of a previous history of fire suppression, a build up of ground 

and ladder fuels in the treatment units, and the potential for fire ignitions from the ongoing 

recreational (mining, hiking, hunting) and rural community activities in the Assessment Area. The 

avoidance of stand-replacing wildfire would result in an indirect long-term moderate beneficial effect 

by avoiding the direct loss or damage of fungi populations and habitat. 

Future district projects expected to occur in the short- and long-term include annual road 

maintenance, fire suppression activities, the installation of telephone and fiber-optic lines (and 

associated disturbance from roadside trenches), and the North Fork Roads Stormproofing Project. 

Each of these district projects involves ground disturbance near road sides or other upland site 

locations, outside of the 6 Sensitive fungi species’ riparian habitat. Mining activities, however, do 

occur near streams and may occur within riparian habitat of these species. Ground disturbance from 

mining would damage or destroy some fungi individuals, but any populations would be maintained. 

No cumulative effects are expected from effects from wildfire and mining. 

Conclusion. Effects from the proposed action include the following: (1) no effects would 

result from mechanical treatments as the 6 Sensitive fungi species do not occur in M Unit habitat; 

(2) prescribed fire fuels treatments would result in a direct short-term negligible adverse effect to 

individual fungi as underburning destroys some number of individuals (but entire populations are not 

impacted), and an indirect long-term moderate beneficial effect as suitable fungi habitat is maintained 

and the risk of stand replacing wildfires are reduced; (3) mastication fuels treatments would result in 

(i) a direct short-term minor adverse effect as individual fungi would be destroyed or damaged but 

any populations would persist and recover in the short term, and (ii) an indirect short-term minor 

beneficial effect as increased fine and coarse woody debris cover would increase forest floor moisture 

and provide increased substrate for saprophytic fungi species, and (4) roadside fuels treatments would 
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3-204 Chapter 3: Affected Environment and Environmental Consequences

result in direct short-term minor adverse effects as individual fungi and/or substrate for saprophytic 

fungi species would be destroyed or damaged but any populations would persist and recover in the 

short term. 

Sensitive Bryophyte Species 

 Ptilidium californicum (Pacific Fuzzwort)—PTCA5 

 Direct and Indirect Effects. Two sites of the Sensitive liverwort PTCA5 occur in Rx Units, 

one of the two is also located in an RS treatment (PTCA5-#TE1). Resource protection measures for 

the two PTCA5 populations have been designed into the Proposed Action (refer to Table 3-3). The 

resource protection measures are intended to protect individual plants and to maintain habitat 

characteristics that are critical to the maintenance of long-term viable plant populations, in 

accordance with the desired conditions of the Standards and Guidelines from the Klamath LRMP 

(USFS 1995a). Fuel reduction treatments proposed in both sites include broadcast burning to remove 

ground and small ladder fuels (less than 4 inches dbh). 

PTCA5 is a liverwort that occurs in patches on the base of Douglas-fir and true fir trees in upperelevation conifer forests. It is assumed that populations in northern California have evolved in spite of 

fire in the landscape; that is, individual plants or populations, once destroyed by fire, recover or 

recolonize slowly, if at all, at the same location, depending upon the severity of fire. In addition the 

levels of ground and ladder fuels in these sites are considered outside the historic range due to past 

fire suppression. The resource protection measures, therefore, allow the broadcast burning within the 

two PTCA5 stands but exclude burning of the substrate trees. The resource protection measures also 

exclude the harvesting of the substrate trees. With the implementation of the protection measures, the 

Proposed Action would result in a long-term indirect beneficial effect as PTCA5 habitat and plants 

are protected from mortality in a stand-replacing fire and would lead to long-term viability of the 

PTCA5 populations in the Assessment Area. 

 Cumulative Effects. The Proposed Action would reduce the risk of stand-replacing fire that 

may occur given the cumulative effects of a previous history of fire suppression, a build up of ground 

and ladder fuels in the treatment units, and the potential for fire ignitions from the ongoing 

recreational (mining, hiking, hunting) and rural community activities in the Assessment Area. The 

avoidance of stand-replacing fire would benefit this species by preventing the direct loss or damage of 

PTCA5 plants and habitat. The Proposed Action’s reduction of the potential for stand-replacing fire 

would also prevent the secondary effects from a weed infestation—a frequent result of standreplacing wildfires and the corresponding suppression activities. The direct benefit to PTCA5 would 

be minor. PTCA5 is a small liverwort that grows in patches on the base of large trees and is not in 

direct competition with herbaceous or shrubby weeds. The avoidance of weed competition for 

herbaceous and shrub vegetation in PTCA5 habitat, however, would be an indirect benefit to this 

species’ habitat. 

Future district projects expected to occur in the short- and long-term include annual road 

maintenance, fire suppression activities, the installation of telephone and fiber-optic lines (and 

associated disturbance from roadside trenches), and the North Fork Roads Stormproofing Project. 

Each of these district projects involves ground disturbance near road sides, and cumulative adverse 

effects are expected with the multiple roadside disturbances from the district projects. If the 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.7 – Botanical Resources and Noxious Weeds 3-205 

PTCA5-#TE1 tree is damaged or removed, PTCA5-#TE1 would be damaged or destroyed. If habitat 

is altered (that is, canopy cover and stand humidity is reduced, and/or if suitable substrate mature 

overstory tree species are removed), PTCA5-#TE1 plants would decline or be killed. In summary, 

cumulative effects of the proposed action would result in a long-term moderate beneficial indirect 

effect because species habitat would be maintained as result of reduced risk of wildfire and noxious 

weed infestation. The cumulative effects from ongoing and future district projects along roadsides 

would result in long-term moderate direct and indirect adverse effects if the PTCA5-#TE1 tree is 

removed or damaged and/or surrounding habitat is altered. 

Conclusion—The Proposed Action would result in a long-term beneficial indirect effect as 

PTCA5 habitat and plants are protected from mortality in a stand-replacing fire (and avoiding a 

secondary noxious weed infestation), and would lead to long-term viability of the PTCA5 populations 

in the Assessment Area. Cumulative effects from ongoing and future district roadside-disturbing 

projects would result in a long-term moderate adverse direct and indirect effect if the PTCA5-#TE1 

substrate tree is removed or damaged, and/or surrounding habitat is altered, leading to the decline or 

loss of PTCA5-#TE1 plants. 

Sensitive Lichen Species 

 Hydrothyria venosa (syn. Peltigera hydrothyria) (Waterleaf Lichen)—HYVE7 

No sites of HYVE7 are known to occur in the Assessment Area. Surveys in 2008 included a 

number of streams with low to moderate potential HYVE7 habitat. Additional potential habitat may 

occur outside of the 2008 survey areas. Potential HYVE7 sites of this aquatic lichen would occur in 

Riparian Reserves of Rx Units. 

Proposed treatments in Riparian Reserves include removal of small trees by hand thinning and 

pile burning and with low-intensity backing fires. Resource protection measures for Riparian 

Reserves are intended to maintain existing shade and moisture levels, litter, duff, and large woody 

debris components, and species composition. The protection measures include the following: (i) avoid 

construction of handlines within 25 feet of a watercourse; (ii) ignite prescribed fires to minimize the 

potential for burning material to increase the potential for moderate- or high-intensity burns; 

(iii) when underburning in Riparian Reserves, at least 90 percent of the large woody debris will not be 

consumed, both standing and on the ground; (iv) where more than 80 percent shade exists, at least 

80 percent shade on the water will be retained after treatment; (v) larger conifers (greater than 

20 inches dbh) felled within perennial stream channels or inner gorges will be left in place; however, 

slash will be minimized in the stream channel. 

 Direct and Indirect Effects. Proposed treatments in Riparian Reserves that maintain 

overstory shade, reduce understory fuels, and avoid disturbance to streams would result in short-term 

moderate indirect beneficial effects to any HYVE7 sites until riparian habitat fuels recover. Proposed 

treatments would result in no direct effects on any HYVE7 plants. 

 Cumulative Effects. The Proposed Action would reduce the risk of stand-replacing fires that 

may occur given the cumulative effects of a previous history of fire suppression, a build up of ground 

and ladder fuels in the treatment units, and the potential for fire ignitions from the ongoing 

recreational (mining, hiking, hunting) and rural community activities in the Assessment Area. A 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-206 Chapter 3: Affected Environment and Environmental Consequences

stand-replacing fire would affect HYVE7 habitat by reducing upland vegetation and increasing 

stream flows and silt loads. The result would be an indirect long-term moderate adverse effect until 

upland vegetation recovers and stream flows and silt loads stabilize. Cumulative effects of mining 

activities would be similar to Alternative A described above. 

Conclusion—The Proposed Action would result in a long-term moderate beneficial indirect 

effect, as HYVE7 habitat components (shade, stream temperature) are maintained. By reducing or 

avoiding the cumulative effects of a stand-replacing fire, the Proposed Action also would result in a 

long-term moderate beneficial indirect effect until upland vegetation recovers and stream flows and 

silt loads stabilize. The cumulative effects of mining activities along streams with any HYVE7 sites 

would result in (1) a long-term moderate adverse direct effect as HYVE7 substrate or plants are 

destroyed or disturbed, and (2) a long-term moderate adverse indirect effect as siltation levels 

increase and destroy plants. 

3.7.4.4 Alternative C: No New Temporary Roads Constructed 

Sensitive Vascular Species 

 Cypripedium fasciculatum (Clustered Lady-slipper Orchid)—CYFA 

 Cypripedium montanum (Mountain Lady-slipper Orchid)—CYMO2 

 Smilax jamesii (English Peak Greenbriar)—SMJA 

 Direct and Indirect Effects. Direct and indirect effects for the three Sensitive vascular 

species would not change from Alternative B, described above. The shift in treatment locations in 

Alternative C (as mechanical units are dropped) would be accounted for with the RPMs. 

 Cumulative Effects. Cumulative effects for the three Sensitive vascular species would not 

change from Alternative B. 

Conclusion—Alternative C, with implementation of resource protection measures, would 

result in long-term moderate beneficial direct and indirect effects on CYFA and CYMO2 populations 

as long-term population viability is enhanced, and plants and habitat are protected from standreplacing wildfire and secondary weed infestation. The cumulative effects of projects that create 

ground disturbance may increase weed infestations in CYFA and CYMO2 habitat, causing an adverse 

indirect effect as invasive weeds out-compete native vegetation and CYFA and CYMO2 plants, 

contributing to the decline of CYFA and CYMO2 populations; the result would be a long-term 

moderate adverse indirect effect on CYFA and CYMO2 populations. 

Alternative C, with the proposed fuel reduction treatments, would enhance SMJA riparian habitat; 

the result would be a long-term moderate beneficial indirect effect on the SMJA population in the 

Assessment Area as SMJA riparian habitat is enhanced, and plants and habitat are protected from a 

stand-replacing fire and secondary weed infestation. Cumulative effects from mining claim 

improvement activities within riparian areas may result in long-term minor to moderate adverse 

effects on SMJA as plants and habitat are destroyed or damaged. 

Nine Sensitive Target Species Assumed to be Present 

 Botrychium virginianum (Rattlesnake Fern)—BOVI 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.7 – Botanical Resources and Noxious Weeds 3-207 

 Campanula wilkinsiana (Wilkin’s harebell)—CAWI8 

 Chaenactis suffrutescens (Shasta chaenactis)—CHSU 

 Eriogonum hirtellum (Klamath Mountain buckwheat)—ERHI7 

 Minuartia stolonifera (Scott Mountain sandwort)—MIST9 

 Eucephalis vialis (Wayside Aster)—EUVI 

 Pedicularis howellii (Howell’s lousewort)—PEHO 

 Eriogonum ursinum var. erubescens (Blushing buckwheat)—ERURE 

 Smilax jamesii (English Peak Greenbriar)—SMJA 

The effects of Alternative C for SMJA is included in the section above; the remaining 8 species 

are discussed below. 

 Direct and Indirect Effects. Direct and indirect effects to the 8 Sensitive vascular species 

would not change from those discussed for Alternative B. See discussions of effects on individual 

species within the Alternative B section above. 

 Cumulative Effects. Cumulative effects to the 8 Sensitive vascular species would not change 

from those discussed for Alternative B. See discussions of effects on individual species in the 

Alternative B section above. 

Conclusion—See discussions of effects on individual species in the Alternative B 

section above. 

Sensitive Fungi Species 

 Boletus pulcherrimus, Cudonia monticola, Dendrocollybia racemosa, Phaeocollybia 

olivacea, Sowerbyella rhenana, Tricholomopsis fulvescens 

 Direct and Indirect Effects. Direct and indirect effects for the 6 Sensitive fungi species 

would not change from Alternative B, described above. 

 Cumulative Effects. Cumulative effects for the 6 Sensitive fungi species would not change 

from Alternative B described above. 

Conclusion—See Conclusion summary in Alternative B section above. 

Sensitive Bryophyte Species 

 Ptilidium californicum (Pacific Fuzzwort)—PTCA5 

 Direct and Indirect Effects. Alternative C proposes no new construction of the 1.03 miles of 

new temporary roads and no underburning treatments in portions of Rx Units 5 and 6. One known 

PTCA5 site (PTCA5-#TE1) occurs in an RS treatment within FRZ 5. The direct and indirect effects 

for this site would not change from Alternative B, as described above. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-208 Chapter 3: Affected Environment and Environmental Consequences

A second PTCA5 site (PTCA5-#RB1) occurs within the portion of untreated Rx Unit 6. The 

effects of no underburning in Rx Unit 6 would not change from Alternative A, the no-action 

alternative, as described above. 

 Cumulative Effects. Cumulative effects for the PTCA5-#TE1 site would not change from 

Alternative B, as described above. Cumulative effects for the PTCA5-#RB1 site would not change 

from Alternative A, as described above. 

Conclusion for PTCA5-#RB1: Alternative C proposes no underburning to Rx Unit 6 where 

PTCA5-#RB1 is located. Given the fuel hazard in the Eddy Gulch LSR, it is assumed at least one 

wildfire will escape initial attack and would burn with surface fires, passive crown and/or active 

crown fires. A surface fire and portions of a passive crown fire that remain on the surface would 

damage or destroy plants at PTCA5- #RB1 and result in short- and long-term minor to major adverse 

direct effects. A surface fire and portions of a passive crown fire would also alter important PTCA5 

habitat microhabitat features that would damage plants or slow the recovery/recolonization of PTCA5 

plants—the result would be short- and long-term minor to major adverse indirect effects to PTCA5-

#RB1 site. Where the overstory is removed as a result of a passive or active crown fire, habitat would 

be altered and PTCA5 plants would decline or die—the result would be an indirect long-term 

moderate adverse effect to PTCA5-#RB1. 

Conclusion for PTCA5-#TE1: Alternative C would enhance PTCA5 habitat, increase 

population viability, and protect plants from destruction in a stand-replacing fire; the result would be 

a moderate beneficial long-term indirect effect on PTCA5 populations. Cumulative effects from 

district roadside-disturbing projects could result in a long-term moderate adverse direct effect from 

removing or damaging the PTCA5-#TE1 substrate tree, and a long-term moderate adverse indirect 

effect from habitat alteration, leading to the decline or loss of PTCA5-#TE1 plants. 

Sensitive Lichen Species 

 Hydrothyria venosa (syn. Peltigera hydrothyria) (Waterleaf Lichen)—HYVE7 

 Direct and Indirect Effects. Direct and indirect effects for HYVE7 would not change from 

Alternative B, described above. HYVE7 is an aquatic lichen limited to perennial streams, and the lack 

of new temporary road construction would not change the direct or indirect effects on this species. 

 Cumulative Effects. Cumulative effects for HYVE7 would not change from Alternative B, 

described above. HYVE7 is an aquatic lichen limited to perennial streams, and the lack of new 

temporary road construction would not change the cumulative effects on this species. 

Conclusion—A surface fire would result in no direct effect on HYVE7 and a short-term 

moderate beneficial indirect effect until understory vegetation recovers and ground fuels are replaced. 

A passive or crown fire would increase solar radiation along HYVE7 riparian habitat and result in a 

long-term moderate adverse indirect effect until overstory canopy is restored. Cumulative effects of 

Alternative C include the likelihood of a stand-replacing fire with (1) an increase in noxious weeds 

and stream flows and stream siltation levels following the stand-replacing wildfire. The results 

include (1) no short-term or long-term direct effects on HYVE7 plants from weed infestations, 

(2) long-term moderate indirect adverse effects until stream flows and siltation levels recover. Mining 

activities would also have a cumulative effect by disturbing or destroying HYVE7 plants or habitat, 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.7 – Botanical Resources and Noxious Weeds 3-209 

resulting in (1) long-term moderate adverse direct effects as HYVE7 substrate or plants are destroyed 

or disturbed, and (2) long-term minor to moderate indirect adverse effects as siltation levels increase 

and indirectly destroy plants. 

3.7.5 Methodology: Noxious Weeds 

Noxious Weed List. The Klamath National Forest Noxious Weed List includes high-priority 

plants from the state and county lists that are known or expected to occur on the Klamath National 

Forest. Based on inventories and current understanding of species’ ranges, a total of 24 high-priority 

weeds are on the Klamath National Forest Noxious Weed List. 

3.7.5.1 Weed Risk Assessment 

Forest Service Manual 2080 Noxious Weed Management (USFS 1995b) includes a policy 

statement calling for a risk assessment for noxious weeds to be completed for every project. The risk 

assessment process has been standardized to determine the risk of introducing or spreading noxious 

weeds within a project and includes a Weed Risk Assessment document. For projects having 

moderate to high risk of introducing or spreading noxious weeds, the project decision document must 

identify noxious weed control measures that must be undertaken during project implementation. The 

Weed Risk Assessment identified this project as having high risks associated with all factors (known 

species, habitat vulnerability, nonproject-dependent vectors, habitat alteration, and increased vectors 

as result of project implementation). 

3.7.5.2 Pre-Field Review 

A pre-field review of noxious weed sites included a review of the Klamath National Forest 

Noxious Weed GIS Database, and weed site data from atlases and maps located at the office of the 

Salmon River and Scott River Ranger Districts, in Ft. Jones, California. 

3.7.5.3 Field Surveys 

The project Assessment Area is considered to have a low infestation of noxious weed sites with 

all but one known noxious weed site occurring along roadsides. Field surveys for noxious weeds were 

conducted in August 2008, along main roads and concurrent with botanical survey units. 

Following the field surveys, the locations of new and previously documented target noxious weed 

sites were added to the GIS to analyze proximity of noxious weed plant sites to project treatment units 

to identify potential effects. See Resource Protection Measures in Chapter 2, Section 2.9 of this final 

EIS. 

3.7.6 Affected Environment (Existing Conditions): Noxious Weeds 

Noxious weed sites in the project area are listed in Table 3-48 and include: 

 4 previously documented sites and 8 new sites of Dyer’s woad (Isatis tinctoria), 

 1 previously documented site and 4 new sites of yellow starthistle (Centaurea solstitialis), 

 3 previously documented site of Scotch broom (Cytisus scoparius), and 

 13 previously documented sites of spotted knapweed (Centaurea maculosa). 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-210 Chapter 3: Affected Environment and Environmental Consequences

Table 3-48. Summary of noxious weed sites in the Eddy Gulch LSR Project proposed treatment units, 

August 2008. 

Species Site 

Number* Number of 

Plants/Area 

Location 

(TRS) 

Location 

(UTM) 

Location in 

Proposed Treatment Unit 

Isatis tinctoria L. – Dyer’s Woad - ISTI 

ISTI-TE1 15 plants in 6 ft 

x 50 ft 

T38N-R11W, 

S.32 NW of SE 1⁄4 

487446, 

4560425 

RS treatment in FRZ 6, along National 

Forest System (NFS) Road #39N23, 

due south of Windy Gap. 

ISTI-#55, Unavailable 

Data 

T40N-R10W, S.19, 

West 1⁄2 of NW 1⁄4 

Shape files 

available 

A linear roadside population, along the 

40N54 road, that occurs in a RS 

treatment area outside of FRZs or Rx 

Units. 

ISTI-RAW2 (re-visit 

to previous site, 

no #) 

3.8 acre area T40N-R10W, S.19, 

SE of NW 1⁄4 

495304, 

4574562 

A linear roadside population, along the 

40N54 road, that occurs in a RS 

treatment area outside of FRZs or Rx 

Units. Located south of ISTI#55. 

ISTI-RAW3 2,000 plants in 

5 acres 

T41N-R10W, S.22, 

SW of SW 1⁄4 

501097, 

4581354 

RS treatment in Rx Unit 9 (northern), 

between NFS Road #41N18 and spur 

road heading south (1 mile southeast 

of Etna Summit) 

ISTI-GSV1 50 plants in 

15 ft x 5 ft 

T41N-R10W, S.28, 

NE of NW 1⁄4 

499785, 

4581205 

RS treatment in FRZ 20, on old 

roadbed in 2008 Botanical Survey Unit 

#22 South. 

ISTI-KM2 200 plants in 

2 acres 

T41N-R10W, S.32,31 497729, 

4579764 

RS treatment in Rx Unit 9, scattered in 

riparian area in 2008 Botanical Survey 

Unit #20-West 

ISTI-KM5 200 plants in 

1 acre 

T41N-R10W, S. 32 498502, 

4579045 

RX Unit 9, scattered in riparian area in 

2008 Botanical Survey Unit #20-East 

ISTI-RB4 1 plant in 1 ft x 

1 ft 

T39N-R11W, S.6, 

SE of SW 1⁄4 

487541, 

4568107 

RS Treatment in FRZ 2, along NFS 

road #1E001, due west of Black Bear 

Summit and M Units 51. 

ISTI-no site # 0.1 acre or less, 

most likely 

eradicated or 

one or two 

plants present. 

T40N-R11W-S.5 unavailable 

data 

Multiple sites in a RS treatment in Rx 

Unit 12, along NFS Road 39N60, 

northeast of Black Bear Summit. 

ISTI-no site # 0.1 acre or 

more, rock pit, 

at saddle; many 

plants, pretreatment being 

attempted. 

T39N-R12W, S.12, 

SE of NW 1⁄4 

Shape files 

available 

Within FRZ 2 and adjacent to M Unit 32 

(and continuing north outside any 

project treatment areas), at saddle and 

on multiple roads, located 

approximately one mile east of Blue 

Ridge Lookout 

ISTI-141 0.1 acre or less, 

most likely 

eradicated or 

one or two 

plants present. 

T40N-R10W-S16, SW 

1⁄4 and center 

Unavailable 

data 

RS treatment in FRZ 12 and M Unit 13: 

multiple sites along the main 39 road in 

the Klamath Basin area. 

ISTI-GC1 45 plants in 

20 ft x 25 ft 

T39N-R11W, S.16, 490298, 

4565625 

RS treatment area in FRZ 12, along 

NFS Road #39 due north of Klamath 

Basin. This site could be combined with 

ISTI-141 above. 

Centaurea solstitialis L. – Yellow starthistle – CESO3 

CESO3- no site # 1.24 acre area T39N-R11W, S.26, 

NE of SW 1⁄4 

Shape files 

available 

In FRZ 11, on a saddle at junction of 

NFS roads 39N74 and 39N51, and due 

south of M Unit 19. 

CESO3-JV1 100 plants in 10 

ft x 100 ft 

T39N-R11W, S29, 

NW of SE 1⁄4 

497217, 

4562358 

In RS treatment area outside of and 

due east of FRZ 15, linear population 

along Siskiyou County Cecilville Road 

east of Grasshopper Ridge. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.7 – Botanical Resources and Noxious Weeds 3-211 

Table 3-48. Summary of noxious weed population sites in the Eddy Gulch LSR Project proposed 

treatment units, August 2008 (continued).

Species Site 

Numbera Number of 

Plants/Area 

Location 

(TRS) 

Location 

(UTM) 

Location in 

Proposed Treatment Unit 

CESO3-JV2 1,500 plants in 

10 ft x 1,000 ft 

T39N-R10W, S30, SE 

of SW 1⁄4 to S. 31, 

NE of NW 1⁄4 

494780, 

4561723 

RS treatment area in FRZ 15, linear 

population along a 0.25-mile area of 

Siskiyou County Cecilville Road, south 

of Grasshopper Ridge. 

CESO3-GC1 600 plants in 

0.2 acre 

T38N-R12W-S16, 

NW 1⁄4 of NE 1⁄4 

482259, 

4557065 

In RS treatment area within Rx Unit 3, 

on the Cecilville Road approximately 

1 mile south of Matthews Creek. 

CESO3-JDS10 50 plants in 

40 ft x 20 ft 

T38N-R12W, S.22, 

SE of NW 1⁄4 

482549, 

4556296 

Just outside of RS treatment area in Rx 

Unit 3, along County Cecilville Road due 

west of Butcher Creek. 

Cytisus scoparius (L.) Link. Scotch Broom - CYSC4 

CYSC4-no site # 0.10 acre area T40N-R10W, S.19, NW 

of NW 1⁄4 

Shape files 

available 

Within a RS treatment area (outside of 

FRZ or Rx Unit) west of the 40N54 road 

0.10 mile south of Idlewild Campground. 

CYSC4- no site # 0.10 acre area T40N-R10W-S19, SE 

of NW 1⁄4 

Shape files 

available 

Within a RS treatment area and outside 

of any FRZ or RX Unit, along the 40N54 

road, above South Fork Russian Creek, 

approximately 0.50 mile south of 

Idlewild Campground, due south of 

ISTI#RAW2. 

CYSC4-no site # 0.10 acres T40N-R10W-S19, Shape files 

available 

Within a RS treatment area just outside 

of Rx Units 8, along the 40N54 road 

above South Fork Russian Creek. 

Centaurea maculosa Lam. Spotted Knapweed CEMA4

CEMA4-#22.6 0.10 acre T40N-R10W-S6, NW 1⁄4 

of SW 1⁄4 

Shape files 

available 

Along county road, outside of, but on the 

far SW edge of Rx Unit 9. 

CEMA4-#RN28 0.10 acre T41N-R10W, S.28, NE 

of NW 1⁄4 

Shape files 

available 

Along county road in FRZ 20 and RS 

treatment area. 

CEMA4-#RN145 0.10 acre T41N-R10W, S.29, SW 

of NE 1⁄4 

Shape files 

available 

Along county road in FRZ 20 and RS 

treatment area. 

CEMA4-#RN88 0.10 acre T41N-R10W, S.29, NE 

of SW 1⁄4 

Shape files 

available 

Along county road in FRZ 20 and RS 

treatment area. 

CEMA4-#RN87 0.10 acre T41N-R10W, S.31 Shape files 

available 

Along county road in Rx Unit 9 and RS 

treatment area. 

CEMA4-#RN24.5 0.10 acre T41N-R10W, S.32 Shape files 

available 

Along county road in Rx Unit 9 and RS 

treatment area. 

CEMA4-#RN24.4 0.10 acre T41N-R10W, S.32 Shape files 

available 

Along county road in Rx Unit 9 and RS 

treatment area. 

CEMA4-#118 0.10 acre T39N-R10W-S.4, SE 1⁄4 

of SW 1⁄4 

Shape files 

available 

RS treatment area in FRZ 15, along 

Siskiyou County Cecilville Road, south 

of Grasshopper Ridge. 

CEMA4-#122 0.10 acre T40N-R10W-S18, SE 

of NE 1⁄4 

Shape files 

available 

Along county road in Rx Unit 8 and RS 

treatment area. 

CEMA4-#123 0.10 acre T40N-R10W-S18, NE 

of SE 1⁄4 

Shape files 

available 

Along county road in Rx Unit 8 and RS 

treatment area. 

CEMA4-#125 0.10 acre T40N-R10W-S18, SW 

of SE 1⁄4 

Shape files 

available 

Along county road in Rx Unit 8 and RS 

treatment area. 

CEMA4-#127.1 Approximately 

5 acres 

T40N-R10W-S18, NE 

of NW 1⁄4 

Shape files 

available 

Outside of any proposed treatment units 

or areas, but in the LRS boundary and 

adjacent to private ownership 1 mile 

south of Idlewild Campground 

CEMA4-#138 0.10 acre T39N-R10W-S5, NE of 

NW 1⁄4 

Shape files 

available 

Within Rx Unit 5, along the 39N73 road 

(outside of a RS treatment area). 

Note: *Population/site numbers were temporarily assigned during 2008 field surveys. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-212 Chapter 3: Affected Environment and Environmental Consequences

Eleven of the 12 Dyer’s Woad sites occur along paved or primary gravel roads or 

decommissioned roadbeds within a range of proposed treatment units, and 1 new site occurs in a 

riparian area within Rx Unit 9. The 11 roadside sites are distributed in the following treatment unit 

types: 6 occur in RS treatment areas of FRZs (2 of the 6 also occur within or adjacent to mechanical 

units), 3 sites occur within RS treatments within Rx Units, and 2 occur in RS treatments outside of 

any FRZ or Rx Unit. 

Four of the five yellow starthistle sites occur along the paved county Cecilville Road on the 

project’s southern and southwest boundaries; three of the four sites occur within proposed RS 

treatment areas (one of which is also in an FRZ) and the fourth site occurs just outside and south of a 

RS treatment area and Rx Unit. The fifth site occurs in an FRZ and due south of an M Unit at a saddle 

at the junction of two Forest Service roads. 

Two of the 3 Scotch broom sites occur within RS treatment areas, which are not part of an FRZ or 

Rx Unit, and 1 site is right on the edge of Rx Unit 8. This last site is also adjacent to private 

ownership. 

Seven of the 13 spotted knapweed sites occur in RS treatments within Rx units, 4 occur in RS 

treatments within FRZs, and 2 sites occur in RS treatments outside of any FRZ or Rx units. 

3.7.7 Environmental Consequences: Noxious Weeds 

3.7.7.1 Alternative A: No Action 

Direct and Indirect Effects. Weed infestations are likely to follow stand-replacing wildfires and 

the corresponding suppression activities. Factors like an ideal seed bed, reduced competition from 

native plants and increased nutrients released by the fire, all combine to make conditions ideal for 

weed seed to germinate and flourish following fire. Noxious weed infestation can have long-term 

negative effects on native vegetation, and can create permanent change in natural plant communities. 

Weed infestations following wildfire follow a typical pattern: modest weed infestation rates typically 

follow the first year, and dramatic increases in infestation rates occur after the second year, due to 

weed seed banks and plants re-sprouting (Asher et al. 2001). 

The four noxious weed species in the Assessment Area (Dyer’s woad, yellow starthistle, Scotch 

broom and spotted knapweed) all prefer open, disturbed habitat. Following a surface fire (depending 

upon the fire severity), infestations of the four species would increase most dramatically in burned 

open habitats, (roadsides, young silviculture stands, shrub communities and other natural openings), 

near and adjacent to the known sites in the Assessment Area. Weed infestations would increase 

dramatically within two years following a surface fire and beyond the first few years could quickly 

and permanently alter the native vegetation in these areas, if no control measures are taken. Open 

habitat, however, represents a relatively small area of the Assessment Area. Weed infestations would 

be minimal in shady habitat (mid-seral to mature forests with closed canopies) and would increase 

modestly within two years following a surface fire. Beyond the first two years, the infestation would 

continue to spread, although the increase would be modest and, even without control measures, is 

unlikely to permanently alter the vegetation in shady habitats. Shady habitat (mid-seral and older 

closed-canopy forests) is a common habitat type in the Assessment Area. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.7 – Botanical Resources and Noxious Weeds 3-213 

A passive crown fire would have the same effects as a surface fire, with the additional loss of 

overstory trees in scattered locations. The canopy cover loss would increase the area of open habitat 

and level of weed infestation in the Assessment Area with the rates of infestation occurring similarly, 

as described above for surface fires. An active crown fire would create large areas of open disturbed 

ground and potential for dramatic weed infestations in the Assessment Area. Weed infestations 

following an active crown fire would increase dramatically within two years following the fire in 

large areas of the Assessment Area, and without control measures has the potential to quickly and 

permanently alter natural plant communities over large areas of the Assessment Area. 

Cumulative Effects. Ongoing district projects and projects scheduled for the foreseeable future 

include annual road maintenance, hazard tree removal, improvements to existing mining claims, 

hiking, appropriate responses for fire suppression, installation of utility lines with associated roadside 

trenching, the North Fork Roads Stormproofing Project and the construction of fuelbreaks system 

west of Black Bear Ranch. District projects that disturb known weed sites are expected to spread 

noxious weeds in the Assessment Area. All Assessment Area weed sites (except one Dyer’s woad 

population) are located along existing or decommissioned roads. The following projects have the 

potential to spread current infestations: annual road maintenance, fire suppression, hazard tree 

removal, roadside utility line trenching, and improvements to existing mining claims (that occur along 

and adjacent to roads). Projects that alter habitat and create more open, disturbed areas (along roads 

or elsewhere in the Assessment Area) would create additional habitat for the spread of weeds. Fire 

suppression activities, the roadside utility line trenching, and the fuelbreak projects would all create 

additional disturbed habitat that is susceptible to weed infestation. 

Conclusion—By creating more disturbed open habitat susceptible to infestations, the surface 

and crown fires of the no-action alternative would increase the abundance of the four noxious weed 

species (Dyer’s woad, yellow starthistle, Scotch broom, and spotted knapweed) in the Assessment 

Area; the result would be a long-term minor to moderate adverse direct effect on the native 

vegetation. Post-fire monitoring and control measures would reduce these direct effects. 

By directly disturbing known noxious weed sites along roads, the cumulative effects of district 

projects that include roadside disturbance have the potential to spread infestation of the 32 current 

roadside noxious weed sites in the Assessment Area; the result would be a long-term moderate 

adverse direct effect on native vegetation in the Assessment Area. These effects would be reduced by 

noxious weed control measures, required by the Forest Service Manual (FSM) 2080 Noxious Weed 

Management (USFS 1995b). 

3.7.7.2 Alternative B: Proposed Action 

A Weed Risk Assessment was completed for the Proposed Action (see Section 1.9 in the 

Botanical Resources Report), in accordance with the FSM 2080 Noxious Weed Management (USFS 

1995b). The Weed Risk Assessment identified this project as having moderate to high risk of 

introducing or spreading noxious weeds. For projects having moderate to high risk of introducing or 

spreading noxious weeds, the project decision document must identify noxious weed control 

measures that must be undertaken during project implementation. Control measures include posttreatment surveys and site evaluation for treatment. See Section 2.9.6.3 of Chapter 2 of this final EIS. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-214 Chapter 3: Affected Environment and Environmental Consequences

Direct and Indirect Effects 

Mechanical thinning (M Unit) treatments—are planned in 42 units (931 acres) within 

FRZs. One site of Dyer’s woad occurs on a roadside in M Unit 13 near the Klamath Basin area; a 

second site occurs on a roadside adjacent to M Unit 32 east of Blue Ridge Lookout. The ground 

disturbance from mechanical treatments has the potential to create ideal conditions for the infestation 

or spread of Dyer’s woad. The risk for increased weed infestations at these two sites would be 

reduced through implementation of the noxious weed RPMs. The RPMs include the buffering of 

ground disturbance within known noxious weed sites (all weed sites will be flagged on the ground), 

the cleaning of all equipment before entering treatment units, post-treatment surveys of each M Unit, 

site evaluations for treatment of any weed sites located, and the monitoring of weed sites for as long 

as it takes vegetation to recover from disturbance. With the implementation of the RPMs, there would 

be a negligible increase in weed infestation at the two known weed sites and any new future sites in 

the project Assessment Area from mechanical treatments, resulting in a negligible adverse direct or 

indirect effect on noxious weed sites or native vegetation in the Assessment Area. 

 Mastication treatments—are planned within the 16 FRZ Units (in 3,207 acres) on slopes 

with less than 45 percent slope. Mastication treatments would reduce ground and ladder fuels only. 

Information is lacking on the effects of mastication on noxious weed infestations. Although 

mastication creates high soil disturbance (and therefore creates the conditions for weed infestation), 

this risk would be offset by the final treatment result of deep fuelbed loads that suppress germination 

of noxious weeds. In addition the RPMs require that mastication activities be excluded from weed 

population sites (all weed sites will be flagged on the ground). All equipment will be cleaned prior to 

entering treatment units, post-treatment surveys will be conducted in mastication units, and sitespecific evaluations will be used to determine treatment of any weed sites that may be located. All 

weed sites will be monitored following mastication treatments for as long as it takes vegetation to 

recover from disturbance. With the implementation of the RPMs, there would be a negligible increase 

in weed infestation sites in the project Assessment Area from mastication treatments, resulting in a 

negligible adverse direct or indirect effect on noxious weed sites or native vegetation in the 

Assessment Area. 

 Roadside treatments—are proposed within FRZs and Rx Units and include a mix of 

mastication and prescribed burn treatments (depending upon steepness of slope) in FRZs and 

broadcast burn treatments in Rx Units. The majority of weed sites in the Assessment Area occur 

within RS treatment units (11 of the 12 Dyer’s woad sites, 3 of the 5 yellow starthistle sites, 2 of the 

3 Scotch broom sites, and all 13 of the spotted knapweed sites) or along roads within the Assessment 

Area outside of FRZs or Rx Units. The occurrence of these weed sites within RS treatment areas 

poses a high risk of spreading noxious weeds to other sites in the Assessment Area. The risk would be 

offset through implementation of the RPMs incorporated into the Proposed Action. The RPMs require 

the cleaning of equipment before entering treatment units, that RS treatments be excluded from weed 

population sites (all weed sites will be flagged on the ground), post-treatment surveys will be 

conducted in RS areas, site-specific evaluations will be used to determine treatment of any weed sites 

that may be located, and all known weed sites will be monitored for as long as it takes vegetation to 

recover from disturbance. With the implementation of the RPMs, there would be a negligible increase 

in weed infestation sites in the Assessment Area from RS treatments, resulting in a negligible adverse 

direct or indirect effect on native vegetation in the Assessment Area. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.7 – Botanical Resources and Noxious Weeds 3-215 

Prescribed burn treatments—are planned in FRZs with slopes above 45 percent 

(5,107 acres), and in all Rx Units (17,524 acres); treatments include broadcast burning of ground and 

small ladder fuels and fireline construction (both handline and machine constructed). One Dyer’s 

woad site (ISTI-KM5) occurs within a riparian area of Rx Unit 9, and one yellow starthistle site 

begins roadside (outside of an RS treatment area) and continues north on a saddle at the junction of 

National Forest System Roads 39N51 and 39N74, within FRZ 11. Both weed sites occur where 

broadcast burning and fireline construction activities are expected to occur. While information on fire 

effects is often conflicting for many noxious weed species, prescribed fire has the potential to create 

the conditions for new infestations of weed species due to reduced competition from vegetation and 

litter, increased sunlight and nutrients, and soil disturbance. Possible effects of the broadcast burn 

treatments include the spread of the existing weeds and the introduction of new weeds into treatment 

units. Fire can have different effects on the introduction and establishment of different noxious weed 

species (USFS 2008b; BLM 2008). Where Dyer’s woad sites already occur near burned areas, 

infestations commonly explode in burned areas (Asher 2001). And while fire has been used to control 

existing infestations of yellow starthistle, fire may also create ideal conditions for the establishment of 

infestations by reducing competition and litter, exposing soils, releasing nutrients, and possibly even 

stimulating germination (USFS 2008b). 

Prescribed fire has been used to control Scotch broom when used repeatedly to deplete the seed 

bank (CAL-IPC 2006) and does not appear to increase infestation rates. Low-severity fire is not likely 

to kill spotted knapweed plants or seeds; fire may top-kill plants, plants can re-sprout from roots, and 

seeds are persistent to all but severe fire. Based on the species’ regeneration strategies, fire could 

actually promote the establishment and spread of spotted knapweed by creating areas of bare soil and 

increasing access to sunlight (USFS 2008b). 

Both weed species can quickly establish and spread in the disturbed bare ground that would result 

from prescribed burning and/or fireline construction. The broadcast burn treatments and fireline 

activities would therefore increase the risk of invasion by these weeds in the Assessment Area. Any 

increased risk of infestation from the current Dyer’s woad and yellow starthistle sites, or introduction 

of additional noxious weed species in the Assessment Area, however, would be reduced by the project 

weed RPMs. The RPMs require the exclusion of prescribed burn treatments and fireline construction 

within weed populations, the cleaning of all equipment before entering treatment units, that posttreatment surveys be conducted in Rx Units and FRZs, site-specific evaluations be used to determine 

treatment of any weed sites located, and the monitoring of weed sites for as long as it takes vegetation 

to recover from disturbance. With the implementation of the RPMs, the prescribed burn treatments 

(including fireline construction) would result in a negligible risk of weed infestation and a long-term 

negligible adverse indirect effect on native vegetation in the Assessment Area. 

 Road construction—The Proposed Action includes the construction and closure of 

1.03 miles (7 segments totaling 5,443 feet) of new temporary roads to access all or portions of seven 

M Units and the re-opening and closing of 0.98 mile (5 segments totaling 5,177 feet) of former 

logging access routes. No documented noxious weed sites occur along proposed temporary roads or 

existing roads proposed for re-opening, but all four weed species can quickly establish in disturbed 

ground. The disturbance and habitat alteration from new road construction commonly increases weed 

infestations. This effect would be reduced through implementation of the weed RPMs that require 

avoidance of project activities that create ground disturbance within noxious weed populations, the 
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3-216 Chapter 3: Affected Environment and Environmental Consequences

cleaning of all equipment before entering treatment units, post-treatment surveys be conducted, and 

site-specific evaluations be used to determine treatment of any weed sites located, and the monitoring 

of any new weed sites for as long as it takes vegetation to recover from disturbance following project 

completion. 

Cumulative Effects. Ongoing district projects, and projects scheduled for the foreseeable future, 

include annual road maintenance, improvements to existing mining claims, hiking, appropriate 

responses for fire suppression, installation of utility lines with associated roadside trenching, the 

North Fork Roads Stormproofing Project, and the construction of a fuelbreak system west of Black 

Bear Ranch. The Proposed Action would reduce the risk of stand-replacing fire that may occur given 

the cumulative effects of a previous history of fire suppression, a build up of surface and ladder fuels 

in the treatment units, and the potential for fire ignitions from the ongoing recreational (mining, 

hiking, hunting), and rural community activities in the Assessment Area. The avoidance of standreplacing fire would prevent an increase in weed infestations that is likely to follow stand-replacing 

wildfires and the corresponding suppression activities. Noxious weed infestation can have long-term 

adverse effects on native vegetation and can create permanent change in natural plant communities. 

The avoidance of increased weed infestations would benefit the native vegetation and contribute to 

the viability of the natural plant communities in the Assessment Area. Other future district projects 

that include disturbance to roadside habitat have the potential to increase the spread of known weed 

sites that occur along roads and to introduce new weeds to the Assessment Area. These effects would 

be reduced by noxious weed control measures that are required by FSM 2080 Noxious Weed 

Management (USFS 1995b). 

Conclusion—With the implementation of the weed RPMs, direct and indirect effects from 

the proposed treatments include a negligible increase in weed infestations; the result would be a shortterm negligible adverse direct or indirect effect on native vegetation in the Assessment Area. The 

Proposed Action would reduce the risk of a wildfire resulting from the cumulative effects of fire 

suppression, the build up of surface and ladder fuels, and the potential for fire ignitions from the 

ongoing recreational (mining, hiking, hunting) and rural community activities. The avoidance of 

wildfire would prevent an increase in weed infestations, and the result would be a long-term moderate 

beneficial indirect effect on native vegetation in the Assessment Area. With the implementation of 

control measures required by FSM 2080 Noxious Weed Management (USFS 1995b), the cumulative 

effects from other district projects would be reduced and no effects would be expected. 

3.7.7.3 Alternative C: No New Temporary Roads Constructed 

Alternative C is similar to the Proposed Action (Alternative B) but without the construction of the 

1.03 miles of new temporary roads. The lack of new temporary roads results in the following changes 

from the Proposed Action: the total acres of mechanical thinning treatments would be reduced by 

99 acres in portions of seven M Units, the total acres of fuels treatments in Rx Unit 5 would be 

decreased by 26 percent (418 acres), the total acres of fuels treatments in Rx Unit 6 would be 

decreased by 28 percent (404 acres), and the acres of cable yarding would be reduced from 570 to 

471 acres (tractor yarding would remain the same). 

Direct and Indirect Effects. The direct and indirect effects on noxious weeds would remain the 

same as described above in Alternative B for mastication treatments, RS treatments, and prescribed 

burn treatments. Minor differences in effects would occur for mechanical thinning treatments. The 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Section 3.7 – Botanical Resources and Noxious Weeds 3-217 

reduced acres of mechanical treatments would result in a minor reduced risk of new weed 

infestations, resulting from fewer acres of ground disturbance. With the implementation of the RPMs, 

however, there would still be a negligible increase in weed infestation sites in the project Assessment 

Area from mechanical treatments and negligible adverse direct or indirect effects on noxious weed 

sites or native vegetation in the Assessment Area. 

Direct and indirect effects on noxious weeds would be reduced in areas without construction of 

new temporary roads. The reduction in road construction would result in a reduced risk of new weed 

infestations from disturbance and habitat alteration. The (reduced) risk of weed infestation would be 

further reduced by the weed RPMs, which require avoidance of project-related ground disturbance in 

noxious weed populations, the cleaning of all equipment before entering treatment units, that posttreatment surveys be conducted, site-specific evaluations be used to determine treatment of any weed 

sites located, and the monitoring of any new weed sites for as long as it takes vegetation to recover 

from disturbance following project completion. 

Cumulative Effects. The cumulative effects from Alternative C would not differ from 

Alternative B. See the discussion of cumulative effects under Alternative B above. 

Conclusion—With the implementation of the weed RPMs, direct and indirect effects from 

Alternative C treatments would include a negligible increase in weed infestations for mastication 

treatments, RS treatments, and prescribed burn treatments; the result would be a short-term negligible 

adverse direct or indirect effect on native vegetation in the Assessment Area. Alternative C would 

greatly reduce the risk of a wildfire resulting from the cumulative effects of fire suppression, the build 

up of surface and ladder fuels, and the potential for fire ignitions from the ongoing recreational 

(mining, hiking, hunting) and rural community activities. The prevention of wildfire would prevent an 

increase in weed infestations, and the result would be a long-term moderate beneficial indirect effect 

on native vegetation in the Assessment Area. With the implementation of control measures required 

by FSM 2080 Noxious Weed Management (USFS 1995b), the cumulative effects from other district 

projects would be reduced and no effects would be expected. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-218 Chapter 3: Affected Environment and Environmental Consequences

3.8 Social Values ________________________________________ 

3.8.1 Introduction 

A social analysis uses social science information to determine how proposed actions affect 

humans. Because changes in the management policy of the Klamath National Forest established by 

the Klamath Land and Resource Management Plan (Klamath LRMP) are not proposed, the social 

effects of this proposal are limited in scope. For the Eddy Gulch Late-Successional Reserve (LSR) 

Project, effects on social values are discussed in narrative form. Indicators of the social environment 

are local community capacity, economics, visual quality (scenery), recreation, human health and 

safety, roadless areas, Wild and Scenic Rivers, transportation, heritage resources, and environmental 

justice. 

3.8.2 Methodology 

3.8.2.1 Analysis Methods 

The analyses contained in this section are summarized from the following resource reports that 

were prepared for the Eddy Gulch LSR Project (these reports are on the project website: 

http://www.eddylsrproject.com): 

 Social Assessment 

 Economic Report 

 Scenery Report 

 Recreation Report 

 Wild and Scenic Rivers Report 

 Roads Report 

 Heritage Report 

3.8.2.2 Analysis Area 

The Klamath National Forest lies in Siskiyou County, California, and a small portion of Jackson 

County, Oregon. The Eddy Gulch LSR Project Assessment Area is contained entirely in Siskiyou 

County. The county, the Salmon River subbasin, and Eddy Gulch LSR Project Assessment Area 

make up the analysis area for determining current conditions and project effects on social values. 

3.8.3 Affected Environment and Environmental Consequences 

3.8.3.1 Community Capacity 

Affected Environment 

Community capacity (the community’s ability to respond to stresses and take advantage of 

opportunities to meet community needs) is fluid. The infrastructure (underlying framework) in small 

communities surrounding the Assessment Area is limited and unemployment and poverty are high 

(Doak and Kusel 1997). 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.8 – Social Values 3-219

The Salmon River Subbasin is an unincorporated area of Siskiyou County. Approximately 

250 people currently reside in the Subbasin, and residences are dispersed throughout the subbasin, with 

concentrations located in or near the towns of Sawyers Bar, Cecilville, Somes Bar, and Forks of 

Salmon. The subbasin also contains several outlying small neighborhoods and isolated forest 

residencies. The “Social Assessment” provides additional information about community capacity and 

community well-being and effects on these elements that could result from implementation of the Eddy 

Gulch LSR Project. 

Environmental Consequences 

Alternative A 

The future social situation in the vicinity of the project would likely be similar to the present. 

Community capacity and infrastructure would remain limited, and unemployment and poverty would 

remain high where it is currently high. Wildfires can result in both adverse and beneficial effects on 

community capacity. Short-term adverse effects on community well-being can occur if residents are 

temporarily displaced from their homes or communities during wildfire. Fires can also provide 

employment opportunities for the local community in suppression and rehabilitation activities. 

Alternatives B and C 

Alternatives B and C would not affect the future social situation in the vicinity of the Eddy Gulch 

LSR Project. Community capacity and infrastructure would remain limited, and unemployment and 

poverty would remain high where it is currently high. There would be a contribution to contract work 

in the local communities from either action alternative, which could result in beneficial effects. 

3.8.3.2 Economics 

Affected Environment 

The analysis area for economics is Siskiyou County. Available employment opportunities include 

logging, planting, precommercial thinning, masticating, and conducting surveys. People in the area 

spend money on gas, equipment, clothing, and food, which creates a small multiplier effect in 

Siskiyou County. People employed by nonprofit groups also work in the county. Activities such as 

hunting and recreational use can generate direct or indirect employment, which can be cumulative 

when combined with employment generated by project activities. The median number of households 

in the county (as of 2000) was 18,556, and the median household income (in 2004) was $32,531. The 

median per capita income (2004) was $17,570. 

Environmental Consequences 

Alternative A 

Timber or biomass from the Assessment Area would not be available to regional markets, and 

demands will be satisfied by other domestic or foreign sources. Contract work from awarded timber 

sales, stewardship contracts, road contracts, and survey work would not be realized. Conversely, there 

would be no costs associated with hazardous fuels reduction and no funding needs for fuel reduction 

work proposed throughout the Assessment Area. 

The calculated value of benefits is related to the value of timber that would be lost if the 

7,200-acre wildfire modeled for Alternative A were to occur. For this analysis, the volume of timber 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-220 Chapter 3: Affected Environment and Environmental Consequences

killed in the 7,200 acres was calculated using the 1995 Timber Type Inventory, volumes from stand 

examination data processed using Forest Vegetation Simulator, and values calculated for the harvest 

units. The estimated volume lost would be 1,005,400 thousand board feet (MBF), with a current value 

of $119.18 per MBF. Thus, the total value of lost timber would be $12,828,450. The discounted value 

would be $11,449,759. 

Alternative B 

Alternative B would result in a positive residual value and would provide for jobs and the 

production of wood commodities, which would have economic benefits for the surrounding 

communities. 

With an estimated volume of 10.8 million board feet (MMBF), this alternative could potentially 

create 108 jobs. It would also provide the wood commodity to support local mills and provide the 

basis of numerous products sold abroad. The positive residual value from thinning treatments in 

M Units would be approximately $1,286,301. The total discounted cost for mastication and 

underburning in FRZs, underburning in Rx Units, and hand cutting, piling, and burning in RS 

treatments would be approximately $4,976,661. Alternative B would result in beneficial effects on the 

local communities and Siskiyou County. 

Alternative C 

Alternative C would also result in a positive residual value and would provide for jobs and the 

production of wood commodities, which would have economic benefits for the surrounding 

communities. 

With an estimated volume of 9.6 MMBF, Alternative C could potentially create 96 jobs. It would 

also provide the wood commodity to support local mills and provide the basis of numerous products 

sold abroad. The total discounted cost for mastication and underburning in FRZs, underburning in 

Rx Units, and hand cutting, piling, and burning in RS treatments would be $4,953,088. Alternative C 

would result in beneficial effects on the local communities and Siskiyou County. 

3.8.3.3 Environmental Justice 

Affected Environment 

Executive Order 12898 requires that each federal agency shall make achieving environmental 

justice part of its mission by identifying and addressing, as appropriate, “disproportionately high and 

adverse human health or environmental effects” of its programs, policies, and activities on minority 

populations and low-income populations. 

This assessment was conducted using the format described in the “Guide for Environmental 

Justice Analysis with the Environmental Impact Analysis Process” (USAF 1997). The analysis area 

for Environmental Justice is Siskiyou County, California. 

The census data for Siskiyou County was obtained from the United States Census Bureau 

(USCB 2005). The data show that the population of Siskiyou County is made up of Caucasians 

(82 percent), Hispanics (9 percent), Native Americans (4 percent), Blacks (1.4 percent), and Asians or 

Hawaiians (1.4 percent) (2005 data). Approximately 15.5 percent of the population is below the 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.8 – Social Values 3-221

poverty line (2004 data). There is no specific data for the rural communities in the vicinity of the 

Eddy Gulch LSR Project Assessment Area. The Salmon River Community Wildfire Protection Plan 

(CWPP) (SRFSC 2007) contains additional information about the rural communities and 

neighborhoods in the vicinity of the Eddy Gulch LSR. 

Environmental Consequences 

Alternative A 

No disproportionately high or adverse human health or environmental effects on minority 

populations and low-income populations would occur under Alternative A. 

Alternatives B and C 

No disproportionately high or adverse human health or environmental effects on minority 

populations and low-income populations would occur under Alternative B or C. 

3.8.3.4 Human Health and Safety 

Affected Environment 

The analysis area for health and safety is the Eddy Gulch LSR Project Assessment Area. A 

number of laws and regulations to protect human health and safety govern forest practices, including 

the Federal Highway Safety Act, Occupational Safety and Health Administration regulations, and air 

quality regulations. 

Environmental Consequences 

Alternative A 

Alternative A would not implement fuels reduction treatments to improve the safety of travelers 

on emergency access routes within the Eddy Gulch LSR, as specified in the Salmon River CWPP. 

This would result in potential adverse effects on residents and suppression crews in the event of a 

wildfire because roads could be blocked by fires that have jumped the road or by fallen trees. Blocked 

roads could require residents to take a longer route out of the area or affect the timely access for 

suppression crews. Refer to “Section 3.2 Forest Vegetation,” “Section 3.3 Fire, Fuels, and Air 

Quality,” and the “Recreation Report” for more information on the effects of taking no action under 

Alternative A. 

Alternatives B and C 

Alternatives B and C both propose fuel reduction treatments along 44 miles of emergency access 

routes inside FRZs and Rx Units and 16 miles of RS treatments outside of FRZs and Rx Units. There 

could be beneficial effects on human safety from providing safe emergency access for residents to 

evacuate and for suppression forces to safely enter the LSR in the event of a wildfire. Refer to 

“Section 3.2 Forest Vegetation” and “Section 3.3 Fire, Fuels, and Air Quality” for more information 

on the effects of implementing Alternative B or C. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-222 Chapter 3: Affected Environment and Environmental Consequences

3.8.3.5 Visual Quality (Scenery) 

Affected Environment 

The visual quality analysis area for the Eddy Gulch LSR Project encompasses several Klamath 

LRMP (USFS 1995) “Management Areas,” which establish direction for scenic integrity (Visual 

Quality Objectives [VQOs]) (see the “Scenery Report” for “Map A-5. Klamath LRMP Visual Quality 

Objectives, as applied to the Eddy Gulch LSR”). Sensitive viewpoints outside of the Eddy Gulch LSR 

have been included in the analysis area if proposed treatment areas are visible from those viewpoints. 

In Eddy Gulch LSR Assessment Area, scenic character is composed of steep rugged mountain 

landforms, steeply incised stream channels, and diverse mixed-conifer forests. Scenic attractiveness

varies little throughout the Assessment Area, with the majority of the Eddy Gulch LSR being “Typical 

or Common.” Areas within the Wild and Scenic Salmon River can be classified as “Distinctive.” 

“Indistinctive” areas do not occur in the Assessment Area. 

The vast majority of the Eddy Gulch LSR has a scenic integrity goal of Partial Retention. Since 

the overall impression of the Assessment Area ranges from Partial Retention to Preservation, the 

current condition meets Klamath LRMP VQOs, even though individual disturbances may result in 

lower ratings in a localized area. The corridor of the “Scenic” segment of the Wild and Scenic South 

Fork of the Salmon River and the Pacific Crest National Scenic Trail (PCT) both have a Klamath 

LRMP VQO of Retention. The scenic stability of the Eddy Gulch LSR’s scenic character is of 

concern primarily because of the existing excessively dense vegetative conditions, which have largely 

replaced attractive scenery attributes such as open and diverse forest canopies, large tree prominence, 

and views to understory vegetation and wildlife. Many of the stands may not be sustainable because 

they have departed too far from reference/historic conditions. The existing scenic stability for the 

majority of the Assessment Area is low primarily due to the high probability of large stand-replacing 

fires in the Eddy Gulch LSR, which would further threaten and impair the historic scenery attributes 

above. 

Environmental Consequences 

Alternative A 

There would be no direct effects on Scenic Stability and Scenic Integrity from the no-action 

alternative. Indirect effects would result from maintaining current vegetation conditions and fuel 

loads. Scenic Stability could degrade further from low to low/very low if future vegetation growth of 

ladder fuels (overly dense stands of small and intermediate size trees) and lack of open stands 

increases the wildfire risk. Climate change may result in further drying conditions and an extended 

dry season, further increasing the risk of fire and lowering the areas of Scenic Stability currently rated 

as moderate/low to a low/very low level. 

Uncontrolled burning of large wildfires that exceeds the area’s historic range in terms of size and 

intensity could result in significant impairments to both Scenic Integrity and Scenic Stability. Due to 

the density of vegetation growth in the Assessment Area, wildfires covering a projected 5,065 acres of 

passive crown fire and 780 acres of active crown fire would likely create uncharacteristically large 

openings in the forest canopy, exposing existing roadway disturbances and the effects resulting from 

past salvage operations. These effects have a strong probability of lowering the Scenic Integrity levels 

to “Modification” or “Maximum Modification,” which are well outside Klamath LRMP VQOs. Such 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.8 – Social Values 3-223

large fires would also reduce the presence of attractive forest canopy attributes for long periods of 

time, further impairing the existing poor Scenic Stability conditions. In summary, this alternative 

continues and increases the likelihood of large wildfires indirectly resulting in long-term major 

adverse effects on scenery. 

Alternatives B and C 

The Eddy Gulch LSR Project would result in two primary moderate to major beneficial effects: 

(1) increase in Scenic Stability due to reduction of fire hazard, and (2) increase in scenic character due 

to creating more open, park-like forest canopy conditions with larger trees. Potentially adverse effects 

would generally range from negligible to minor and include scenery disturbance effects such as stump 

visibility from moderate concern roads, visibility of temporary roads, and visibility of cable corridors. 

The “Scenery Report” and “Scenery Analysis” provide considerable information about current 

conditions in the Assessment Area and detailed discussion of how visual quality would be affected by 

project activities. 

The thinning that would occur in FRZs would reduce the likelihood of a large wildfire spreading 

from one watershed to the next, thereby increasing Scenic Stability throughout the Assessment Area. 

Reducing ladder fuels through prescribed burning would reduce the likelihood that a large standreplacing wildfire that exceeds the historic range of variability would occur in the Assessment Area, 

and as a result increasing resiliency of valued scenic resources and improving Scenic Stability to 

moderate to high levels. This thinning would also increase the development of large tree character in 

these stands, which is an important scenery attribute enhancement. 

Moderate beneficial effects on scenic character of the PCT foreground views include creating 

more open, park-like settings with larger trees and better visibility into the forest (middle-ground and 

back-ground views from PCT and other identified trails would remain within the historical range of 

variability). Potentially short-term moderate adverse effects on Scenic Integrity include visible 

disturbance in foreground through stumps, slash, and other debris, and/or evidence of tractor 

operations and skid and cable corridors. Implementing RPMs (which include flush-cutting and 

obscuring stumps and removal of debris from the vicinity of the PCT) will reduce these potential 

effects to minor or negligible levels. The one mastication treatment visible from the PCT is 

approximately 400 feet below the trail, thus only the tops of the trees would be visible, and treatments 

within this unit would have negligible affects on PCT users. Effects of fuel reduction treatments on 

Scenic Integrity occurring in middleground and background views would be negligible. 

3.8.3.6 Recreation 

Affected Environment 

According to an August 2002 National Visitor Use Monitoring Report (USDA 2002), the popular 

recreational activities in the Klamath National Forest include viewing wildlife and scenery, general 

relaxing and retreat, pleasure driving, hiking/walking, camping, picnicking, nature study, off-highway 

vehicle use, fishing, and cross-country skiing / snowshoeing. 

Existing camping areas include Shadow Creek and Idlewild (outside, but adjacent to the LSR). 

Campgrounds outside, but nearby, the LSR include Mulebridge, Shadow Creek, Trail Creek, and East 

Fork. Matthews Creek and the Matthews Creek river access border the Assessment Area’s southwest 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-224 Chapter 3: Affected Environment and Environmental Consequences

corner. Existing recreation / hiking trails include the PCT and numerous trails in and around the 

Russian Wilderness, along Russian Creek, following the east fork of Whites Gulch, and along Sixmile 

Creek and Trail Creek. Additionally, the Deacon Lee trailhead provides access to the Deacon Lee trail 

eastward to the Russian Wilderness. During the summer months, whitewater rafting and kayaking are 

popular activities on the South Fork of the Salmon River below Matthews Creek. The North Fork of 

the Salmon River only skirts the Eddy Gulch LSR for a short distance, and no segments of the 

Salmon River lie entirely within the LSR; however, camping sites located in the Assessment Area 

could serve as staging areas for boating expeditions. 

According to the Klamath LRMP (USFS 1995), 20 percent of visitors engage in recreation at 

developed sites, with 80 percent participating in dispersed activities such as hiking, fishing, and 

nature viewing. The Klamath LRMP places emphasis on dispersed recreation, particularly in the 

LSRs, as well as maintenance of existing developed sites. 

Most of the LSR that was inventoried as Roaded Modified in 1990 has regrown sufficiently to be 

classified today as Roaded Natural. Some of it would be classified as Semi-Primitive Motorized 

depending on the size of the area and primitive nature of the roads. The inventoried roadless areas 

retain most of their Semi-Primitive Non-Motorized and Primitive characteristics. 

Environmental Consequences 

Alternative A 

Direct and indirect effects of the no-action alternative on recreation would be negligible and 

remain within Semi-Primitive or Roaded Natural Recreation Opportunity Spectrum (ROS) classes. 

Cumulative effects of continuing current vegetation management, combined with a large wildfire, 

would be major and adverse and result in conditions not meeting Klamath LRMP ROS directives. 

Alternatives B and C 

Alternatives B and C would have major beneficial effects on recreation setting and experience 

primarily through reduction of the possibility of a major wildfire. Minor beneficial effects would 

occur due to creation of a more open, park-like setting with large trees and increased opportunities for 

wildlife viewing. Temporary adverse effects could occur primarily due to the effect of fuel reduction 

treatments and prescribed burning. These effects would be reduced to minor levels with proper 

scheduling and implementation of standard health and safety measures. Except for these temporary 

effects, the Roaded Primitive and Semi-Primitive Natural ROS classes would continue to be met. 

3.8.3.7 Wild and Scenic Rivers 

Affected Environment 

The Wild and Scenic River Act was created in 1968 to preserve selected rivers in a free-flowing 

condition and to protect their associated river resources. Most of the North and South Forks of the 

Salmon River, as well as a segment of Russian Creek in the Eddy Gulch LSR, are either Designated 

as, or Recommended for, future designation as segments of the National Wild and Scenic River 

(WSR) system, with a “Recreational” WSR classification (USFS 1995). Fisheries is the primary 

“outstandingly remarkable” value for the North Fork and South Fork of the Salmon. Other WSR 

values to be protected include free-flowing condition, water quality, and scenery. Fisheries, water 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.8 – Social Values 3-225

quality, and wildlife are the primary “outstandingly remarkable” values for the East Fork South Fork 

Salmon River. In particular, values to protect include pristine riparian habitat, high quality water, a 

peregrine falcon eyrie, goshawk territory, fisher, and pileated woodpecker habitat. Outstandingly 

remarkable values for South Russian Creek include vegetation and water quality, and the specific 

values to protect are vegetation diversity, including a stand of old-growth Engelman spruce and a 

pristine watershed. 

A section of the North Fork of the Salmon River that flows through the Assessment Area is a 

Designated “Recreational” WSR. Additionally, a nearby portion of the North Fork of the Salmon 

River is a Recommended WSR eligible for “Wild” classification, although this area is outside the 

LSR boundary within the Marble Mountain Wilderness Area. One Designated WSR segment of the 

South Fork of the Salmon River contains sufficiently primitive and undeveloped character, dramatic 

scenic bluffs and incised canyons, to be classified as “Scenic.” There is also a portion of the South 

Fork of the Salmon River that occurs in the Assessment Area that is Recommended as a WSR with a 

“Recreational” classification. Russian Creek occurs in the Assessment Area and is Recommended as a 

WSR, with this segment recommended for classification as “Recreational.” Outside of the 

Assessment Area, within the Russian Wilderness Area, a second nearly pristine segment of Russian 

Creek has been recommended as a WSR with a “Wild” classification. The few “Distinctive” scenic 

attractiveness areas in the Assessment Area are located in the WSR corridors. 

Environmental Consequences 

The analysis for Wild and Scenic Rivers focuses on the effects to the integrity of the WSR 

corridors and protection of their Outstandingly Remarkable Values, and other WSR values (Water 

Quality, Free-flowing Condition, and Scenery), per requirements of the Klamath LRMP, Aquatic 

Conservation Strategy Objectives, and other pertinent laws and direction. 

Alternative A 

Potential benefits of the no-action alternative would be negligible on free-flowing condition, 

scenery, water quality, fisheries, watershed condition, wildlife/riparian habitat, and vegetation 

diversity; however, when considered cumulatively with the possibility of future wildfire, the noaction alternative has the potential for major adverse effects on Outstandingly Remarkable Values in 

fisheries and water quality on the North and South Fork of the Salmon River; pristine watershed 

condition and vegetation diversity on Russian Creek; and fisheries, riparian habitat, and wildlife on 

the East Fork South Fork Salmon River. WSR values and resources are fully protected per LRMP 

direction and associated resource requirements, such as the Aquatic Conservation Strategy, and 

current/potential WSR classifications may not be perpetuated under the no-action alternative. 

Alternatives B and C 

Minor beneficial effects on “outstandingly remarkable” values include protection of larger trees 

and vegetation in and around the riparian corridor and reduction of the risk of the amount of high 

intensity wildfire in the area. These two alternatives would have no adverse effects on free-flow and 

the other outstandingly remarkable values of Recommended Rivers (vegetation diversity, watershed 

condition, fisheries, and wildlife/riparian habitat). All WSR values and resources are fully protected 

per LRMP direction and associated resource requirements, such as the Aquatic Conservation 

Strategy, and due to the project design, including current resources protection measures, would not
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-226 Chapter 3: Affected Environment and Environmental Consequences

“adversely impact the river’s eligibility or designation.” The current/potential WSR classifications 

will be perpetuated through implementation of Alternatives B and C. For more information on 

potential project effects on the North and South Forks of the Salmon River and South Russian Creek, 

refer to Section 3.5 above and also the Aquatic Resources Report for Water Quality and Fisheries. 

3.8.3.8 Transportation 

Affected Environment 

The Eddy Gulch LSR Assessment Area is well roaded. The road network provides access for 

management activities, human uses, recreation, firefighting, and other emergency responses. The 

system roads are very stable with few, if any, problem spots. There is little sediment coming off of the 

roads in the Assessment Area, and the road system will function for commercial use with only 

maintenance. The unauthorized roads in the Assessment Area are mostly former logging access 

routes, abandoned railroad grades, or roads created to access camp sites or water sources. 

Environmental Consequences 

Alternative A 

The no-action alternative would provide for continued routine maintenance on system roads as 

funding allows. Continued road system improvements by the Klamath National Forest would result in 

short- and long-term minor to major beneficial effects, depending on the extent of future 

improvements. 

Alternatives B and C 

Maintenance of haul roads by the project would improve driver safety and comfort by clearing, 

blading, and dust abatement where required for haul. Clearing roadside vegetation would improve 

visibility. Blading would remove rocks and debris and smooth the road surface. Dust abatement 

would improve user safety on gravel and native surfaced roads. But, the increased truck and heavy 

equipment traffic during implementation of the project would make the haul routes more hazardous 

during the life of the project. The Proposed Action is equally more likely to improve user safety and 

comfort in the years after the project than the no-action alternative, which depends on routine 

maintenance, as funds allow, for accomplishing maintenance work. 

For Alternative B, the effects on resources from construction of 1.03 miles of new temporary 

roads and use of former logging access routes and operational spurs are discussed in detail in the 

various resource sections in this final EIS. 

3.8.3.9 Heritage Resources 

Affected Environment 

Topographic conditions and water sources in the Assessment Area have significantly influenced 

land use of Native Americans and, to a large extent, Euro-Americans. In general, human use in the 

Assessment Area follows similar patterns of habitation and resource use, so historic and 

archaeological sites often overlap each other. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest 

Section 3.8 – Social Values 3-227

American Indian Resources 

American Indians resided in the Salmon River drainage for thousands of years prior to contact 

with Europeans. Areas that sustained American Indian use generally are located within deep canyons 

adjacent to the Salmon River and secondary streams. These are the areas most likely to contain 

American Indian cultural resources. Currently, Indian use of the Assessment Area is very low; only 

one prehistoric site has been recorded. No sacred/spiritual-use sites or traditional plant-gathering sites 

have been documented. 

Members of the Shasta and Karuk tribes continue to be an integral part of communities along the 

Salmon River and its tributaries. They use the area for gathering of traditional materials and foods, 

including beargrass, willows, fish, acorns, and mushrooms. Throughout their history, American 

Indians have used fire to enhance conditions for traditional materials; however, this practice is not 

currently being used in the Eddy Gulch area. 

Historic Resources 

Historic resources include trails, mining sites, logging camps, communities, isolated structures, 

and artifact scatters. Portions of the Live Yankee Gulch and Eddy Gulch watersheds are part of a 

historic mining district, with numerous mining-related artifacts and sites. Twenty-three historic 

properties related to mining or other historic uses have been recorded for the Area of Potential Effects 

(APE) and were visited. Two sites could not be relocated, and one no longer exists. One site (White’s 

Gulch Arrastra) is on the National Register of Historic Places. No determinations have been made on 

the other sites. 

Environmental Consequences 

Alternative A

Direct and Indirect Effects. Direct effects include scorching or loss of resources during a 

wildfire. Depending on fuel moistures, wooden structures or artifacts can be adversely affected or lost 

even from a relatively low-intensity surface fire. High-intensity fire can split stone artifacts (such as 

those made with obsidian). High temperatures can melt solder in cans and other artifacts. Indirect 

effects include ongoing deterioration of historic artifacts from weathering, which will occur under any 

alternative. 

Under the no-action alternative, fuel levels would support active or passive crown fire over most 

of the landscape. The high temperatures associated with crown fire would adversely affect historic 

resources within the fire perimeter. Depending on fire location, this alternative could result in a loss 

of one structure, loss of wooden artifacts on two other sites, and impacts on the prehistoric site. Stone 

and metal artifacts would be affected but not lost. 

Cumulative Effects. There are no other proposed actions for this area that would affect 

heritage resources. There are no projected cumulative effects. 

Conclusion. The risk of adversely affecting heritage resources is highest under this 

alternative due to the potential for crown fire throughout most of the APE. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

3-228 Chapter 3: Affected Environment and Environmental Consequences

Alternative B 

Direct Effects. Direct effects include physical disturbance of heritage resources through site 

disturbance (road construction), and impacts to or loss of resources to fire during prescribed burns or 

wildfire. 

Resource protection measures would be implemented on three properties within fuel treatment 

areas. Properties would be pretreated (such as with hand line and removal of fuels within property 

boundaries) prior to implementation of fuels reduction activities, which would ensure that they are not 

burned over or otherwise damaged. No properties are within the alignment of temporary roads or 

former logging access routes; these activities would not affect heritage resources. 

Indirect Effects. There are no recorded sites along proposed new road alignments; therefore, 

there would be no indirect effects from road construction. 

Under this alternative, wildfire would burn fewer acres at a lower intensity than under no action, 

so there would be less risk of losing historic artifacts. Pretreatment of sites should also provide some 

measure of protection against low-intensity wildfire. Indirect effects include ongoing deterioration of 

historic artifacts from weathering, which will occur under any alternative. 

Cumulative Effects. There are no other proposed actions for this area that would affect 

heritage resources. There are no projected cumulative effects. 

Conclusion. Fuels treatments would reduce fire behavior and rate of spread, which would 

reduce the risk of a heritage site being burned. Pretreatment of three sites will provide some 

protection against wildfire effects. Construction/reopening and closure of new temporary roads and 

former logging access routes would have no adverse effect on heritage resources. 

Alternative C 

Direct and Indirect Effects. Direct and indirect effects are similar to Alternative B. 

Cumulative Effects. There are no other proposed actions for this area that would affect 

heritage resources. There are no projected cumulative effects. 

Conclusion. Effects are similar to those listed for Alternative B. 

3.8.3.10 Inventoried Roadless Areas 

Affected Environment 

The Inventoried Roadless Areas in the Eddy Gulch LSR are not within the boundary of the 

project Assessment Area. 

Environmental Consequences 

The project does not propose to construct roads within the Inventoried Roadless Areas, and 

wildfire does not affect roadless character. There would be no effect on roadless character or the 

Inventoried Roadless Areas under any alternative. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 3: Affected Environment and Environmental Consequences 3-229

3.9 Short-term Uses and Long-term Productivity ______________ 

NEPA requires consideration of “the relationship between short-term uses of man’s environment 

and the maintenance and enhancement of long-term productivity” (40 CFR 1502.16). As declared by 

Congress under NEPA, this includes using all practicable means and measures, including financial 

and technical assistance, in a manner calculated to foster and promote the general welfare; to create 

and maintain conditions under which man and nature can exist in productive harmony; and fulfill the 

social, economic, and other requirements of present and future generations of Americans. 

Short-term uses, and their effects, are those that occur within the first few years of project 

implementation. Long-term productivity refers to the capability of the land and resources to continue 

producing goods and services long after the project has been implemented. Under the Multiple-Use 

Sustained-Yield Act, and the National Forest Management Act, all renewable resources are to be 

managed in such a way that they are available for future generations. The harvesting and use of 

standing timber can be considered a short-term use of a renewable resource. Long-term productivity 

is maintained through the application of the Resource Protection Measures described in Chapter 2, in 

particular, those applying to the soil and water resources. 

All treatments would contribute to increased tree vigor over the long term, which would reduce 

the probability of insect attack. The resulting stand conditions would be more sustainable over the 

long term from the standpoints of vegetative diversity and non-declining flow of timber. Treatments 

are expected to promote the development of larger trees sooner than if left untreated. 

Both action alternatives would experience a short-term period of increased fire hazards 

immediately after thinning in M Units (approximately 3.5 percent of the treated acres) due to slash, 

which would increase ground fuels. Subsequent fuels reduction treatments would reduce those ground 

fuels to a level that would meet the project objective. Broadcast burning is designed to result in 

mortality to smaller size classes in the treated stands. The loss of these ladder fuels would reduce the 

potential for a crown fire in the future. Both action alternatives would increase opportunities for 

successful direct attack tactics during fire suppression and control of fire size. Reductions in fire size 

and behavior would reduce subsequent post-fire delivery of sediment to streams in the Assessment 

Area. This would provide long-term benefits to municipal water supplies and aquatic habitat. Both 

action alternatives would reduce the potential for crown fires, which can reduce the riparian cover 

that shades aquatic habitat. 

The construction of 1.03 miles of temporary roads, re-opening of former logging access routes, 

and use of the short spurs may increase short-term risks to water quality (refer to the fish BA/BE or 

Aquatic Resources Report for Water Quality and Fisheries for this project or Section 3.5 above). 

However, all of the proposed temporary roads and those that would be re-opened are at the highest 

elevations of the watersheds, reducing the risk of displaced soil becoming a new sediment source that 

reaches adjacent stream channels. Closure of the temporary roads and former logging access routes 

following thinning and water-barring roads that are re-opened would preclude the formation of longterm sources of suspended sediment. 

Alternatives B and C comply with the Clean Water Act through implementation of BMPs, 

meeting water quality objectives (suspended sediment, turbidity, and temperature), and protecting 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-230 Chapter 3: Affected Environment and Environmental Consequences

beneficial uses (USDA Forest Service 2007a). These actions ensure compliance with the Clean Water 

Act and North Coast Regional Water Quality Board Basin Plan. Further, projects must comply with 

the California Regional Water Board’s Categorical Waiver for Discharges Related to Timber Harvest 

Activities on Federal Lands Managed by the United States Department of Agriculture, Forest Service 

in the North Coast Region, Order No. R1-2004-0015 (Waiver). The Eddy Gulch LSR Project meets 

all conditions and eligibility requirements of the Categorical Waiver. 

Alternatives B and C may affect forested habitat used by northern spotted owls (NSOs) in the 

short term; however, most of the affected habitat occurs in home ranges where there is currently 

surplus nesting/roosting or foraging habitat. Short-term effects would be similar for Pacific fishers. 

There would be long-term beneficial effects because stands would be less susceptible to the loss of 

crowns during a wildfire. 

Alterations in scenery would be slightly noticeable in the short term under both action 

alternatives. The scenic mosaic in the two action alternatives would increase as a result of the 

different treatments and would result in a substantially greater likelihood of being perpetuated, 

compared to the no-action alternative. 

3.10 Unavoidable Adverse Effects___________________________ 

Unavoidable adverse effects would occur during project implementation. There would be some 

unavoidable short-term adverse effects on soils from equipment, on local communities from smoke, 

and avoidance of areas by wildlife during project implementation. These activities are necessary to 

achieve long-term beneficial effects from the project. The Standards and Guidelines contained in the 

Klamath LRMP, resource protection measures, and Best Management Practices (BMPs) will be 

implemented to avoid, reduce, or minimize those short term adverse effects to less than significant. 

Chapter 2 presents the resource protection measures for each resource. The BMPs, by treatment unit, 

are discussed in the Aquatic Resources Report for Water Quality and Fisheries, the Soils Report, and 

Geology Report. 

3.11 Irreversible and Irretrievable Commitment of Resources ____ 

An irreversible commitment of resources is a permanent or essentially permanent loss of 

nonrenewable resources, such as mineral extraction, heritage (cultural) resources, or to those factors 

that are renewable only over long time spans or at great expense (for example, soil productivity), or to 

resources that have been destroyed or removed. No irreversible commitments of resources were 

identified for the project. 

Irretrievable commitment applies to losses that are not renewable or recoverable for future use. 

The loss of production would be irretrievable, but it would not necessarily be irreversible. Under all 

alternatives, based on modeled wildfire effects, there would be some loss of forest vegetation and 

wildlife habitat in the event of a wildfire. Under the action alternatives, the risk of wildfire and 

subsequent loss of forest vegetation would be reduced. Over time, vegetation and NSO habitat 

components will regrow. None of the alternatives constitutes an irretrievable commitment of 

resources. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 3: Affected Environment and Environmental Consequences 3-231

3.12 Cumulative Effects ____________________________________ 

Cumulative effects have been discussed in the individual resource sections earlier in this chapter. 

Cumulative effects for this project include past, present, and ongoing actions. The list of actions 

considered for cumulative effects analyses can be found above in Section 3.1.4. Resource specialists 

considered the listed actions but may have used only a subset of the listed actions in their effects 

analysis based on the potential effects on their resource. 

3.13 Climate Change_______________________________________ 

Increasingly, the relationships between human-caused emissions, climate change, and the role of 

forests as carbon sinks are being documented (IPCC 2007). Although uncertainty exists in quantifying 

the impact of emissions on climate, a climate change of 1.4 to 5.8 degrees centigrade is projected by 

2100 (Millar et al. 2007). Adapting to climate change and its potential impacts poses challenges and 

opportunities for managing resources, infrastructure, and the economy (ibid). Forests and rangelands 

are seen as part of the solution to reducing atmospheric carbon dioxide and other greenhouse gases; 

however, the magnitude of the opportunity for carbon storage and carbon trading is not well 

quantified or thoroughly understood (ibid; IPCC 2007). 

The use of future climate scenarios and ecological models suggests that the impact of climate 

change in California ecosystems could include increases in ecosystem productivity in the short term 

and additional shifts in the distribution of plants and animals in by the end of this century (Lenihan 

et al. 2006; Westerling and Bryant 2006). Changes in distribution of most forests and their associated 

fauna will result from higher temperatures and increased fires. 

Treatments in the Eddy Gulch LSR Assessment Area are designed to reduce competition among 

mature trees and increase forest health in M Units. The treatments would reduce ground, ladder, and 

crown fuels so as to change crown fires to surface fires within the treated areas, which would increase 

resistance to the spread of wildfires in the FRZs. Treatments in the Rx Units are designed to reduce 

ground and ladder fuels in order to improve resilience to changes associated with wildfires. These 

planned changes in stand characteristics may not reduce projected direct effects from climate change 

(for example, increased temperature). They will however, reduce impacts from wildfires that will 

increase indirectly from the increase in temperatures (longer fire seasons and drier fuels). Managing 

forests for carbon sequestration is a poorly understood science but utilization of durable wood 

products and active forest management is believed to be an effective method of carbon sequestration 

(IPCC 2007). Thinning and fuels treatments would remove some sources of carbon sequestration, and 

prescribed burning would generate additional emissions. These emissions can be managed and result 

in fewer annual emissions than a wildfire. Thinning in M Units would increase productivity and 

carbon sequestration in the residual stand and long-term reductions in acres burned by crown fires 

would facilitate carbon sequestration and fewer emissions. 

For more information on the status and trends of the nation's resources and climate change, please 

visit the Research and Development Resources Planning Act Assessment website at 

http://www.fs.fed.us/research/rpa/. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

3-232 Chapter 3: Affected Environment and Environmental Consequences

3.14 Energy Requirements, Conservation 

Potential, Depletable Resource Requirements_____________ 

Consumption of fossil fuels by vehicles and equipment will occur with the action alternatives 

during thinning activities and timber hauling, construction and closure of temporary roads, and 

opening and closing of former logging access routes. No unusual energy requirements are included 

nor do opportunities exist to conserve energy at a large scale. With the proper application of the 

Klamath LRMP Standards and Guidelines for soils, soil productivity will be conserved; supporting 

information can be found in the Soils Report. The project was developed, in part, to promote the 

conservation and recovery of late-successional-dependent wildlife species, such as the NSO. 

3.15 Prime Farmland, Rangeland, and Forest Land_____________ 

The Eddy Gulch LSR Project Assessment Area does not contain any prime farmland or 

rangeland. Prime forest land does not apply within the National Forest System. 

3.16 Possible Conflicts with Other Land Use Plans_____________ 

The action alternatives are entirely on National Forest System lands. The project incorporates 

components of the Salmon River CWPP, which is designed to reduce the threat of wildfire on private 

lands. The action alternatives are not in conflict with planning objectives for Siskiyou County or local 

tribes. 

3.17 Other Required Disclosures____________________________ 

Consultation with the NMFS and USFWS has been completed as required by the Endangered 

Species Act. 

Archaeological field inventories were conducted in the Assessment Area and are recorded in 

Archeological Reconnaissance Report ARR#2008050517270. No properties eligible for the National 

Register of Historic Places will be affected. 
Chapter 4 

Consultation 

and Coordination 
Welcome 

You are now in the “Consultation and Coordination” chapter. Here 

are the topics you can read about. 

4.1 Preparers and Contributors..................................................................4-1 

4.2 Federal, State, and Local Agency Collaboration 

and Consultation ....................................................................................4-5 

4.3 Tribal Consultation................................................................................4-8 

4.4 Distribution of the Final Environmental Impact Statement.........4-10 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 4: Consultation and Coordination 4-1 

Chapter 4. Consultation and Coordination 

4.1 Preparers and Contributors 

4.1.1 Contractor Interdisciplinary Team Members 

Contractor: RED, Inc. Communications 

Name Title / Responsibility Education / Experience

Steve Holl  Team Leader 

 Liaison with Forest Service 

 Project Quality Control (QC) 

 Senior Ecologist 

 Developed Proposed Action and 

Purpose and Need 

 Citizen collaboration and public 

involvement 

 BS Wildlife and Fisheries 

 MS Vertebrate Biology 

 10 years experience as Forest Service District 

Resource Officer and Wildlife Biologist 

 21 years natural resources and NEPA project 

and program management, biological surveys 

and evaluations, ESA compliance, CWPPs and 

fuel reduction and forest restoration plans 

Susan Hale  Assistant to the Team Leader 

 Writer/Editor 

 Citizen collaboration and public 

involvement 

 Developed Purpose and Need 

 Social Assessment 

 BA Elementary Education 

 Environmental and Occupational Health 

Certification, USAF 

 30 years as writer-editor, 20 of those on NEPA 

documents (EIS focus) 

 20 years managing public involvement 

programs 

Ken Denton  EIS and Project Design Advisor 

 Developed Proposed Action and 

Purpose and Need 

 BS Natural Resources 

 34 years Forest Service experience and served a 

Regional Silviculturist for Regions 5 and 6 

 Northwest Forest Plan USFS/BLM SEIS team 

member; served on the LSR Workgroup for the 

Regional Ecosystem Office

Jim Harvey  Registered Professional Forester 

(Cal 2121)

 EIS and Project Design Advisor 

 Developed Proposed Action and 

Purpose and Need 

 35 years Forest Service experiences as certified 

silviculturist and 6 years experience as a 

consulting Forester 

Ed Matthews  Registered Professional Forester 

(Cal 1280) 

 Developed Proposed Action and 

Purpose and Need 

 Forest Vegetation section in EIS 

 Silviculture Report 

 35 years Forest Service experiences as certified 

silviculturist and 6 years experience as a 

consulting Forester 

Mike Mateyka  Silviculturist 

 QC on Proposed Action 

 Forest Vegetation section in EIS 

 Economic Analysis 

 BS Forest Management 

 Graduate Studies in Forest Economics 

 31 years Forest Service experience as Forester 

in timber sale planning and District 

Silviculturist 

Barry Callenberger  Fire and Fuels Specialist 

 Stewardship Fireshed Analysis 

 Developed Proposed Action and 

Purpose and Need 

 Fire, Fuels, and Air Quality section 

in EIS 

 Fuels and Air Quality Report 

 FLAMMAP, FARSITE modeling 

 25 years Forest Service experience as District 

Fuels Officer, Region 5 Fuels / Prescribed Fire 

Management Specialist 

 12 years private consultant in fuels / prescribed 

fire management 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

4-2 Chapter 4: Consultation and Coordination

Name Title / Responsibility Education / Experience

Brooks Henderson  Fire and Fuels Specialist 

 Stewardship Fireshed Analysis 

 Developed Proposed Action and 

Purpose and Need 

 Fire, Fuels, and Air Quality section 

in EIS 

 Fuels and Air Quality Report 

 AA, emphasis in Forestry and Economics 

 27 years Forest Service experience as Fuels 

Specialist and Division Chief 

Brian Williams  Wildlife Biologist 

 Developed Proposed Action and 

Purpose and Need 

 Wildlife and Habitat section in EIS 

 Wildlife Biological Assessment / 

Biological Evaluation 

 Wildlife and Habitat Report 

 BS Biology 

 MS Biological Conservation 

 17 years biological consulting for biological / 

ecological surveys, monitoring, and research 

Stephanie Martin  Wildlife Biologist 

 Wildlife and Habitat section in EIS 

 Biological Assessment / Biological 

Evaluation 

 Wildlife and Habitat Report 

 BS Wildlife Ecology 

 MS Wildlife Biology 

 Over 10 years experience with biological issues 

in California (biological surveys, EIR/CEQA 

compliance, population monitoring) 

Jim Crane  GIS Specialist 

 Developed Proposed Action 

 Roads Report 

 Transportation section in EIS 

 AS Business and Computer Science 

 BS Forestry 

 23 years Forest Service experience as Natural 

Resource Information Manager and 

Geographical Information Systems (GIS) 

Specialist and Logging Systems / 

Transportation Planner 

 10 years as associate professor in ArcView 3.x, 

ArcGIS 8.x and ArcGIS 9.x 

Alice Berg  Fisheries Biologist 

 Aquatic Resources section in EIS 

 Aquatic Resources Report for Water 

Quality and Fisheries 

 Fish Biological Assessment / Biological 

Evaluation 

 AA General Education 

 BS Biology 

 MS Natural Resources: Fisheries 

 4 years experience as Forest Service Fisheries 

Biologist 

 4 years NMFS Fisheries Biologist 

 6 years as consulting Fisheries Biologist 

Ken Cawley  Hydrologist 

 Aquatic Resources section in EIS 

 Aquatic Resources Report for Water 

Quality and Fisheries 

 Geology section in EIS 

 Geology Report 

 BS in Forest Management 

 MS Natural Resources, Watershed 

Management / Forest Hydrology 

 17 years experience as Forest Service 

hydrologist 

 8 years as tenured professor of environmental 

science; taught a wide-ranging curriculum, 

including watershed management, forestry, soil 

science, statistics, geology, chemistry 

 8 years consulting hydrologist 

Denny Churchill  Soil Scientist 

 Soils section in EIS 

 Soils Report 

 BS Soil and Water Science 

 26 years of experience as Forest Service Soil 

Scientist, including District Soil Scientist 

 4 years consulting soil scientist preparing 

erosion and sediment control plans and 

conducting soil interpretations and 

environmental analysis 

Robin Warren  Geologist (GE Cal 2678; 

RG-Cal 7541) 

 Geology section in EIS 

 Geology Report 

 BS Civil Engineering 

 MS Civil Engineering (Geotechnical Specialty) 

 20 years of geotechnical and geologic 

experience in field investigations, geologic 

evaluation, engineering supervision 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 4: Consultation and Coordination 4-3 

Name Title / Responsibility Education / Experience

Gretchen Vos  Botanist 

 Botanical Resources section in EIS 

 Botanical Resources Report 

 Botany Biological Assessment / 

Biological Evaluation 



 BA Linguistics 

 M.Ag. Agroforestry (Botany/Rangeland/Soils) 

 12 years consulting botanist, conducting field 

surveys, NEPA and CEQA documentation 

[Central Valley, CA to Cascades, OR and WA] 

 3 years experience as a Forest Service Temp 

Botanist (GS-9), SW Oregon 

Ed Armstrong  California Landscape Architect, #4870 

 Scenery, Recreation, and Wild and 

Scenic Rivers section in EIS 

 Scenery Analysis 

 Scenery Report 

 Recreation Report 

 Wild and Scenic Rivers Report 

 BS Physics 

 Bachelor of Landscape Architecture 

 Master of Landscape Architecture 

 10 years of experience in planning and design 

for watershed and creek systems; wetland, 

stream and riparian restoration projects 

Cheryl Priest  Desktop Publishing Director 

 Format and layout of EIS 

 18+ years experience in word processing and 

formatting documentation for web- and paperbased publication 

Stephannie Lambert  Website Developer / Graphic Designer 

 Eddy Gulch LSR Website design 

development 

 Front and back cover design 

 BFA Graphic Design 

 12+ years experience and education in direction 

and production of effective visual 

communications 

Kris Burnham  Graphic Designer 

 The Eddy LSR Project “Pathway to a 

healthy future” Newsletters design 

 BS Fine Arts 

 Over 23 years experience in fine arts and 

graphic design 

4.1.2 U.S. Fish and Wildlife Representative for 

Collaboration and Consultation 

Name Title / Responsibility Education / Experience

David Johnson  Collaborator with ID Team 

 Review of wildlife section in EIS and 

Wildlife Biological Assessment / 

Biological Evaluation 

 Issuance of Concurrence Letter or 

Biological Opinion 

 MS in Wildlife Management 

 12 years experience in wildlife biology 

 8 years experience with consultation under 

ESA 

4.1.3 Forest Service Inspectors and Resource Specialists 

Name Title / Responsibility Education / Experience

Patty Grantham  Forest Supervisor / Eddy Gulch LSR 

Project Decision Maker 

 EIS review 

 Bachelor Degree in Forest Science 

 27 years of experience with the US Forest 

Service in silviculture, timber sale preparation 

and administration, fuels and fire, land use 

planning, recreation management, lands and 

special uses. Notable positions include District 

Ranger, Forest Staff Officer, Deputy Forest 

Supervisor, and Forest Supervisor. 

Ray Haupt  Line Officer / District Ranger 

 EIS review 

 AS Biology 

 BS Natural Resources Management, Forestry 

Concentration 

 31 years experience in fire and fuels 

management, forestry, silviculture, sale 

preparation, sale contracting, and as district 

ranger 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

4-4 Chapter 4: Consultation and Coordination

Name Title / Responsibility Education / Experience

 Certified as Timber Contracting Officer and 

Logging Systems Specialist 

 Provided direction for interdisciplinary team 

Julie Perrochet  Klamath National Forest Liaison 

 Inspector: Fisheries and Earth/Water 

Sciences 

 Resource Specialist: Fisheries 

 BA Environmental Studies-Ecology 

 MA Geography–Fisheries Habitat 

Relationships 

 13 years fisheries and wildlife program 

manager 

 18 years fisheries biologist 

Jan Ford  Inspector: Scenery, Recreation, Roads, 

Engineering, and Heritage 

 NEPA and LRMP Compliance 

 BS Wildlife Management 

 28 years experience in wildlife, minerals, 

lands, recreation, and planning 

Emelia Barnum  NEPA and LRMP Compliance  NEPA and NFMA Planning Specialist 

Sue Stresser  Inspector: Wildlife  BS Biology 

 15 years experience in wildlife habitat 

management 

 Level 1 Representative for Endangered 

Species Act consultation 

 Certified COR 

Debi Wright  Inspector: Fire and Fuels  27 years experience in silviculture, timber, and 

fuels 

Clint Isbell  Resource Specialist: Fire and Fuels  BS and MS in Natural Resources, Fire 

Ecology 

 3 years as USFS Fire Ecologist 

Vicki Stephens  Resource Specialist: Fire and Fuels  BS in Resource, Recreation, and Tourism 

Management 

 MS in Forest Resources, Fire Ecology and Fire 

Management 

 15 years experience in fire and fuels 

management 

Carl Varak  Inspector: Silviculture, Forest 

Vegetation 

 BS Forest Management 

 31 years forestry experience in timber sale 

preparation, silviculture and contract 

administration 

 Level III Contracting Officers Representative 

Dan Blessing  Resource Specialist: Economics  BA in Forestry 

 30 Years silviculture and timber experience 

Greg Bousfield  Resource Specialist: Hydrology  MS in Natural Resources, Watershed 

Management Hydrology 

 BS in Forestry, emphasis on Forestry 

Hydrology 

 3.5 years as USFS Hydrologist 

 Assistant Forest Hydrologist, modeling 

specialist 

Tom Laurent  Resource Specialist: Soils  BA Geology 

 MS Soil Science 

 29 years experience in soil science 

Juan de la Fuente  Resource Specialist: Geology  BS Geology 

 35 years experience in geology/ geomorphic 

processes 

Marla Knight  Resource Specialist: Botany  BS in Renewable Natural Resources 

 30 years experience in botanical resources 

management on the Klamath National Forest 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 4: Consultation and Coordination 4-5 

Name Title / Responsibility Education / Experience

Candy Cook-Slette  KNF Heritage Resources Manager / 

Tribal Relations Program Manager 

 Prepared Heritage Resources Section 

and Resource Report 

 BA Anthropology 

 23 years experience in archaeology 

 15 years experience in tribal relations 

Richard 

VandeWater 

 Inspector: GIS  MS in Sociology 

 17 years experience in GIS and database 

management with the U.S. Forest Service 

Jerry Mosier  Resource Specialist: Scenery, 

Recreation, and W-S Rivers 

 BS Landscape Architecture 

 32 years experience in landscape architecture 

Jim Davis  Resource Specialist: Roads / 

Engineering 

 BS Wildlife/Fisheries Biology 

 34 years experience in engineering 

4.2 Federal, State, and Local Agency 

Collaboration and Consultation _________________________ 

4.2.1 Federal, State, and Local Agencies 

The contractor ID team consulted with the following federal agencies during the development of 

this EIS. 

4.2.1.1 United States Fish and Wildlife Service 

The United States Fish and Wildlife Service (USFWS) in Yreka, California, is a collaborating and 

consulting agency for the Eddy Gulch LSR Project. The USFWS issued the species list for the 

Klamath National Forest on April 23, 2003, and an updated list was generated from the computer 

database on May 13, 2009 (reference #52820799-8338). The list fulfills the requirement to provide a 

current species list pursuant to Section 7(c) of the ESA, as amended. 

Wildlife. Communication and consultation between the Contractor Wildlife Biologist, Forest 

Service, and USFWS began on July 7, 2008 but was postponed until October 2008 when more details 

of the Proposed Action and northern spotted owl distribution data would become available. Initial 

communication began on September 25, 2007, when David Johnson, USFWS Level 1 representative, 

attended the interdisciplinary (ID) team meeting in Yreka, CA, and on September 26, 2007, attended 

a field trip to review the project Assessment Area to better understand baseline conditions in the 

Assessment Area, and to determine the probable effects of the project. The September visits initiated 

ongoing communications between the contractor’s Wildlife Biologist, Forest Service, and USFWS. 

The USFWS Level 1 representative on the project attended ID team meetings; reviewed and 

commented on the Stewardship Fireshed Analysis for the Eddy Gulch LSR Project; assisted with 

preparation of the purpose and need for the project; reviewed the early design of the Proposed Action 

and subsequent versions until it was finalized for the draft EIS; reviewed and provided comments on 

the preliminary draft and draft EIS and this final EIS; and participated in Endangered Species Act

(ESA) streamlining consultation meetings and conference calls. The purpose for all communications 

was to ensure that the proposed activities would not adversely affect northern spotted owls (NSOs) or 

their Critical Habitat. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

4-6 Chapter 4: Consultation and Coordination

The ID team biologists and the Klamath National Forest and USFWS Level 1 team discussed the 

proposed project to review locations of actions relative to NSO habitat, potential effects of the 

proposed actions, and appropriate measures to minimize adverse effects on NSO and its Critical 

Habitat (for example, the 2007 programmatic prescribed fire and fuels hazard reduction BA) (USFS 

2007). USFWS and Klamath National Forest staff conducted unit-level reviews of proposed activities 

in NSO core areas and home ranges to determine the potential risks to NSOs and their habitat. 

USFWS staff has preliminarily concurred that proposed activities are not likely to adversely affect 

NSOs or their Critical Habitat. 

Drafts of the wildlife BA/BE were reviewed by the USFWS Level 1 representative on May 1 and 

June 1, 2009, and it was approved by Ray Haupt (District Ranger) on June 5, 2009, via email from 

S. Stresser. 

Plants. On November 18, 2008, the Arcata Field Office of the USFWS provided the Klamath 

National Forest with the list (USFWS 2008) of four federally Endangered plant species (the list 

shows no federally Threatened species occurring on the forest) (Reference #443293162-163413). 

The Eddy Gulch LSR Project Assessment Area is not within the range of, nor does it include 

habitat for, the four federally Endangered plant species; therefore, no ESA consultation is required. 

4.2.1.2 National Marine Fisheries Service 

The National Marine Fisheries Service (NMFS) in Yreka, California, is a consulting agency for 

the Eddy Gulch LSR Project. The ESA fish species list for the Eddy Gulch LSR Project was obtained 

online at http://www.nwr.noaa.gov/ESA-Salmon-Listings/upload/snapshot0208.pdf, and the Sensitive 

species list is from the USDA Pacific Southwest Region Sensitive Species List, June 1998. The list 

fulfills the requirement to provide a current species list pursuant to Section 7(c) of the Endangered 

Species Act, as amended. 

On September 24, 2007, Donald Flickinger, NMFS Level 1 representative, attended a full 

interdisciplinary team (ID team) meeting in Yreka, California, and on June 3, July 1, and August 14, 

2008, attended field trips to review the Assessment Area to better understand baseline conditions in 

the Assessment Area, and to determine the probable effects of the project. In late September 2008, the 

Threatened, Endangered, Proposed, Sensitive, and Candidate species with the potential to occur in the 

Eddy Gulch LSR Project Assessment Area were reviewed with the NMFS representative. 

In the summer and fall of 2008, the Klamath National Forest / NMFS Level 1 team discussed the 

proposed project to review locations of actions relative to SONCC coho salmon habitat, potential 

effects of the proposed actions, and to include appropriate measures to minimize adverse effects on 

SONCC coho salmon and its critical habitat. NMFS and Klamath National Forest staff conducted 

unit- / site-level reviews of proposed activities in the 7th-field watersheds to determine the potential 

risks to anadromous fish and their habitat. During the site visit on June 3, 2008, NMFS reviewed the 

northwestern and western parts of the Assessment Area with the Klamath National Forest and 

stakeholders (field review hosted by Salmon River Restoration Council), specifically to review 

roadside treatment areas and Riparian Reserves. During the August 14, 2008, site visit, the NMFS and 

ID team fisheries biologist focused their review on Riparian Reserves in the Assessment Area, 

including a field review of treatment units in the Shadow Creek watershed, Sixmile Creek watershed, 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 4: Consultation and Coordination 4-7 

Campbell Springs area, Black Bear Creek watershed, Music Creek watershed, and other areas in the 

north part of the Assessment Area. Throughout the early coordination and consultation with NMFS, 

the ID team fisheries biologist discussed, with NMFS, the potential effects determinations for the 

biological assessment / biological evaluation (BA/BE) and existing guidance that would pertain to the 

project to minimize effects on aquatic species. That existing guidance is the programmatic precommercial thinning and fuel hazard reduction BA (USDA Forest Service 2001b) and Klamath 

National Forest Hazard Tree Policy—Safety Provisions on National Forest System Roads (USDA 

Forest Service 2005a), as well as the potential for this Project BA/BE to tier to the Klamath National 

Forest’s Biological Assessment and Evaluation for Pre-commercial Thin and Release Actions and 

Fuel Hazard Reduction Actions (USDA Forest Service 2001b). During the field visit on August 14, 

2008, NMFS staff preliminarily concurred that proposed activities were not likely to adversely affect 

SONCC coho salmon and their critical habitat, and that the fuels reduction actions could tier to the 

Klamath National Forest programmatic BA (USDA Forest Service 2001b) if guidelines in that 

programmatic BA/BE are incorporated into the Eddy Gulch LSR Project. 

Subsequent to completion of a draft BA/BE for the Eddy Gulch LSR Project, and NMFS and 

Klamath National Forest review of the draft BA/BE, a conference call was held on December 22, 

2008, to discuss comments on the BA/BE. During this conference call between A. Berg (ID team 

fisheries biologist), D. Flickinger (NMFS), and J. Perrochet (Klamath National Forest), it was 

determined that ESA consultation for the Eddy Gulch LSR Project could be concluded by using the 

tier form from the 2004 programmatic BA for the Facility Maintenance and Watershed Restoration 

on the Klamath National Forest for water drafting actions and that all the proposed actions, when 

considered collectively and individually, would either have no effect (as described in the “Efficiency 

Measures for Analysis” section of this BA/BE) or are not likely to adversely affect coho salmon and 

their critical habitat. Thus, ESA consultation for the actions with the ESA determination of “May 

Affect, Not Likely to Adversely Affect” has been completed using the tiering and compliance forms 

associated with the 2001 and 2004 programmatic consultation documents in the BA appendices. For 

this BA/BE, it was determined that the project would have indirect beneficial effects resulting from 

increased protection from wildfire. 

In addition to the ID team and Level I meetings described above and field reviews of the Action 

Area, the following email and phone correspondences occurred with NMFS during the course of this 

consultation: 

 Phone correspondence with Donald Flickinger, NMFS: 

- June 24, 2008, phone call to Don Flickinger discussed location of coho salmon critical 

habitat in Action Area relative to proposed actions; mechanical units, prescribed fire, 

previous Klamath National Forest consultations with NMFS for similar actions, 

temporary roads, and future field sites to visit. 

 Email correspondence with Don Flickinger, NMFS: 

- June 4, 2008, email regarding summary of June 3, 2008, field trip with Klamath 

National Forest and Salmon River Restoration Council. 

- June 24, 2008, transmittal of Klamath National Forest’s programmatic PreCommercial Thin and Fuels Hazard Reduction Biological Assessment. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

4-8 Chapter 4: Consultation and Coordination

- June 24, 2008, transmittal of Klamath National Forest Hazard Tree Policy—Safety 

Provisions on National Forest System Roads (USDA Forest Service 2005a). 

- June 25, 2008, email to ID team hydrologist regarding field reviews in future. 

- July 7, 2008, email to hydrologist regarding NMFS's comments to hydrologist’s field 

notes from July 1, 2008, field trip. 

- August 8, 2008, email regarding meeting location for August 14, 2008, field trip. 

Drafts of the BA/BE were reviewed by the NMFS Level 1 representative on December 11, 2008, 

and BA/BE was approved by Ray Haupt (District Ranger) Level 1 on April 20, 2009, via email from 

J. Perrochet. 

The BA/BE was updated subsequent to NMFS’s December 11, 2008, review to correct treatment 

acres (less acres than what was described in the BA/BE), and Alternative C was modified to include 

hand line construction around some burn areas and to reduce the amount of underburning acreage in 

two Rx Units (Rx Unit 5 reduced by 418 acres and Rx Unit 6 by 404 acres; refer to mapped treatment 

areas for Alternative C in Appendix A of this EIS). These changes represent a decrease in acreage to 

be treated and therefore potentially reduced the effects on listed species and their habitat relative to 

what was analyzed previously in the BA/BE and reviewed by NMFS. However, after consideration of 

these changes, it was determined that none of the changes to the BA/BE materially changed potential 

effects on listed species or their habitat, critical habitat, Essential Fish Habitat, or the ESA effects 

determination. Therefore, additional reviews by NMFS were not required. 

4.3 Tribal Consultation ___________________________________ 

4.3.1 Coordination Meetings 

September 13, 2007. A handout titled “Line Direction for the Development of the Eddy Project” 

was provided and a project overview given. Project will be developed utilizing the guiding principles 

contained in the handout. Tribal input is important for this project. Project will identify fire sheds that 

can accept fire. There will be a commercial component in strategic locations. 

Klamath National Forest Karuk Tribe 

Alan Vandiver, Happy Camp – Oak Knoll District Ranger Harold Tripp, Fire Management 

Chris Grove, Deputy District Ranger Bill Tripp, Eco-Cultural Restoration Specialist 

Ray Haupt, Scott – Salmon District Ranger 

Bill Rice, Orleans District Ranger 

Gay Baxter, Special Uses 

Brain Thomas, Fisheries 

December 10, 2007. During this summit meeting, it was explained that the Eddy Gulch LSR is 

using a new approach to planning for wildlife habitat protection through fuels treatments in the Eddy 

Gulch LSR. The project contractor fire and fuels specialists will be using the latest thinking in 

computer modeling to help set treatment priorities in the LSR. The priorities will be based on the 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Chapter 4: Consultation and Coordination 4-9 

most valuable wildlife habitat to treat and the most important acres to treat in order to protect local 

communities from wildfire. Red, Inc. is the contractor that has been hired to do most of the work on 

this project. The contractor will be working closely with Forest Service specialists. 

Klamath National Forest Karuk Tribe 

Peg Boland, Klamath National Forest Supervisor Leeon Hillman, Treasure, Karuk Tribe of California 

Patty Grantham, Klamath National Forest Deputy Forest 

Supervisor 

Florence Conrad, Council Member, Karuk Tribe of 

California 

Don Hall, Happy Camp Ranger District, Acting District 

Ranger 

Alvis Johnson, Council Member, Karuk Tribe of California 

Chris Grove, Happy Camp Ranger District, Acting Deputy 

District Ranger 

Roy Arwood, Council Member, Karuk Tribe of California 

Gay Baxter, Happy Camp Ranger District, Special Uses Sandi Tripp, Director Department of Natural Resources, 

Karuk Tribe 

Tyrone Kelley, Six Rivers National Forest Supervisor Erin Hillman, Director of Administrative Programs and 

Compliance, Karuk Tribe 

Dave Hohler, Six Rivers National Forest, Acting Deputy 

Forest Supervisor 

Dave Wrobleski, Director, People Center 

 Bill Tripp, Eco-Cultural Restoration Specialist, Karuk 

Department of Natural Resources 

 Earl Crosby, Watershed Coordinator 

June 12, 2008. A Klamath Forest Service / Karuk Tribe coordination meeting for the Eddy Gulch 

LSR Project was held in Happy Camp, California. Ray Haupt provided handouts and gave a 

presentation of the Eddy Gulch LSR Project. The Ranger explained that the project is a Healthy 

Forests Restoration Act project, and that the Salmon River Restoration Council, Fire Safe Council, 

and USFWS are involved. A Fireshed Analysis was conducted for the project, and that modeled what 

fire would do in certain landscapes. He explained that the Forest wants fire to play a role in the 

ecosystem, and that the project is proposing to compartmentalize areas and allow fire to do its 

ecological job, while preventing entire watersheds from burning. Meeting participants included the 

following: 

Klamath National Forest Karuk Tribe 

Ken Harris, Happy Camp-Oak Knoll District Ranger Leaf Hillman, Vice Chairman Karuk Tribal Council 

Ray Haupt, Scott-Salmon River District Ranger Earl Crosby, Interim Director Department of Natural 

Resources 

Don Hall, Happy Camp / Oak Knoll Deputy District Ranger Bill Tripp, Eco-Cultural Restoration Specialist 

Todd Salberg, Orleans District Silviculturist Bob Goodwin, Karuk Tribal Council Member 

Leroy Cyr, Fisheries Biologist Florence Conrad, Karuk Tribal Council Member 

September 30, 2008. A Klamath Forest Service / Karuk Tribe coordination meeting for the Eddy 

Gulch LSR Project was held in Somes Bar, California. The Proposed Action was discussed, as was 

the field trip to the Assessment Area on October 29, 2008. Meeting participants included the 

following: 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

4-10 Chapter 4: Consultation and Coordination

Klamath National Forest Karuk Tribe 

Ken Harris, Happy Camp-Oak Knoll District Ranger Earl Crosby, Interim Director Department of Natural 

Resources 

Ray Haupt, District Ranger, Salmon River and Scott River 

Ranger Districts 

Florence Conrad, Karuk Tribal Council Member 

Melissa Schroeder, Deputy District Ranger, Salmon River 

and Scott River Ranger Districts 

Gay Baxter, Happy Camp-Oak Knoll Special Uses 

Administrator 

Todd Salberg, Orleans District Silviculturist 

Leslie Goslin-Burrows, Orleans Lands and Minerals 

4.3.2 Other Tribal Communication 

The Klamath National Forest sent a letter on March 12, 2008, to Roy Hall, Jr., of the Shasta 

Nation, with a copy of the first project newsletter. 

The scoping letter (the second project newsletter, refer to Chapter 1 for a complete discussion 

about the scoping process) was mailed to BIA-Quartz Valley; Arch Super, Karuk tribe; Harold 

Bennett, Quartz Valley; and Howard McConnell, Yurok Tribe. 

4.4 Distribution of this Final 

Environmental Impact Statement _______________________ 

Portable document format (pdf) files of the draft EIS and this final EIS and related resource 

reports are available on the project website (http://www.eddylsrproject.com). Hard copies or 

electronic versions of the final EIS will be sent to those who commented on the draft EIS (see 

Appendix B) or requested a copy. 
Chapter 5 

Acronyms, Glossary, 

Literature Cited, Index 
Welcome 

These are the sections in this chapter. 

Acronyms...........................................................................................................5-1 

Glossary..............................................................................................................5-4 

Literature Cited............................................................................................... 5-20 

Index ................................................................................................................ 5-36 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Acronyms 5-1

Acronyms 

ACS Aquatic Conservation Strategy 

AMR Appropriate Management Response 

APE Area of Potential Effect 

AWWC Areas With Watershed Concerns 

BA/BE Biological Assessment / Biological Evaluation 

BLM Bureau of Land Management 

BMP Best Management Practice 

CBD crown bulk density 

CDFG California Department of Fish and Game 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

CH Critical Habitat 

CHU Critical Habitat Unit 

CO carbon monoxide 

CWD coarse woody debris 

CWE cumulative watershed effect 

CWHR California Wildlife Habitat Relationship 

CWPP community wildfire protection plan 

dbh diameter at breast height 

EIS environmental impact statement 

EPA U.S. Environmental Protection Agency 

ERA Equivalent Roaded Acre 

ESA Endangered Species Act 

FRCC Fire Regime Condition Class 

FRZ Fuel Reduction Zone 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

5-2 Acronyms

FSM Forest Service Manual 

FVS Forest Vegetation Simulator 

GIS geographic information system 

HFI Healthy Forests Initiative 

HFRA Healthy Forests Restoration Act 

ID interdisciplinary 

kg/m2

 kilograms per square meter 

kg/m3

 kilograms per cubic meter 

KMP Klamath Mountain Province 

LOP Limited Operating Period 

LRMP land and resource management plan 

LSR Late-Successional Reserve 

LWD large woody debris 

MOCA Managed Owl Conservation Area 

Mbf thousand board feet 

mi/mi2

 miles per square mile 

MIS management indicator species 

mm millimeter 

mph miles per hour 

NEPA National Environmental Policy Act 

NFS National Forest System 

NMFS National Marine Fisheries Service 

NOAA National Oceanic and Atmospheric Administration 

NOGO northern goshawk 

NSO northern spotted owl 

NWFP Northwest Forest Plan 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Acronyms 5-3

PCT Pacific Crest National Scenic Trail 

PM particulate matter 

psi pounds per square inch 

RAWS remote automated weather station 

ROS Recreation Opportunity Spectrum 

RPM Resource Protection Measure 

RS roadside 

SAF Society of American Foresters 

SDI stand density index 

SFA Stewardship Fireshed Analysis 

SONCC Southern Oregon / Northern California Coasts 

SQAS Soil Quality Assessment Standards 

TOC threshold of concern 

USDA United States Department of Agriculture 

USFS United States Forest Service 

USFWS United States Fish and Wildlife Service 

USLE Universal Soil Loss Equation 

V* The percentage of residual pool volume occupied by fine sediment. Another measure of 

stream sedimentation 

VQO Visual Quality Objective 

WEPP Water Erosion Prediction Project 

WSR Wild and Scenic River 

WUI wildland-urban interface 

WWOS Wet Weather Operation Standards 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

5-4 Glossary

Glossary 

90th Percentile Fire Weather — The highest 10 percent of fire weather days. Fuel moisture, 

temperature, relative humidity, and wind speed are only exceeded 10 percent of the time based on 

historical weather observations. 

Active Crown Fire — A fire that moves into and through the tree crowns, generally due to a 

combination of fire intensity and ladder fuels. 

Activity Fuels — Fuels created by management actions. 

Active Landslide — This term is defined in the Klamath LRMP as a landslide feature with evidence 

of movement within the last 400 years. 

Activity Center — The annual location of a nest site or a favored roosting location. 

Anadromous Fish — Species of fish that are born in freshwater, move to the ocean to mature, and 

return to freshwater to reproduce. 

Analysis Area — The area around treatment areas to be considered in the effects analysis (the 

analysis area may be larger than the Eddy Gulch LSR Project Assessment Area). The analysis area 

varies by resource. 

Annosus root disease (Heterobasidion annosum) — A fungus that attacks a wide variety of woody 

plants. Infection may spread by spores that colonize freshly cut stumps or basal wounds, or via root 

contact. 

Aquatic — Living or growing in water. 

Aquatic Conservation Strategy (ACS) — A strategy “developed to restore and maintain the 

ecological health of watersheds and aquatic ecosystems contained within them on public lands” 

(USDA Forest Service and USDI Bureau of Land Management 1994b, B-9). 

Aquatic Conservation Strategy Objectives — Objectives that “define the context for the agency 

review and implementation of management activities. Complying with the Aquatic Conservation 

Strategy objectives means that an agency must manage the riparian-dependent resources to maintain 

the existing condition or implement actions to restore conditions. The baseline from which to assess 

maintaining or restoring the condition is developed through a watershed analysis. Improvement 

relates to restoring biological and physical processes within their ranges of natural variability.” 

(USDA Forest Service and USDI Bureau of Land Management 1994b, B-10). 

Areas With Watershed Concerns (AWWC) — Areas identified in the LRMP ROD (USDA Forest 

Service 1995) because cumulative watershed effects are a special concern due to a combination of 

high disturbance levels (roads, timber harvest, fire), potential for landslides, potential for surface 

erosion, and poor aquatic habitat conditions. The LRMP ROD (ibid.) states that a “cautious approach 

will be taken in AWWC, with respect to future land management activities,” and that “Watershed 

Analysis, as part of ecosystem analysis, will be required prior to implementing site-disturbing 

activities.” 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Glossary 5-5

Assessment Area — The 37,239-acre portion of the Eddy Gulch LSR west of Etna Summit where 

various treatments are proposed. All inventoried roadless areas that occur in the LSR were excluded 

from planning efforts and are therefore not part of the Assessment Area. 

Background (relative to watershed) — A watershed’s natural sediment production and delivery, or 

sediment delivery, assuming no disturbance. 

Basal Area (BA) — A measure of stand density that defines the area of a given stand that is occupied 

by the cross-section of tree trunks and stems at their base. 

Beneficial Uses — “Beneficial uses” of the waters of the state that may be protected against water 

quality degradation include, but are not necessarily limited to, domestic, municipal, agricultural, and 

industrial supply; power generation; recreation; aesthetic enjoyment; navigation; and preservation and 

enhancement of fish, wildlife, and other aquatic resources or preserves (from Section 13050(f) of 

California’s Porter-Cologne Water Quality Control Act). 

Best Management Practices (BMPs) — Measures certified by the State Water Quality Control 

Board and approved by the Environmental Protection Agency as effective means of reducing water 

quality impacts from non-point sources of pollution. 

Biomass — Limbs and foliage (parts of trees other than logs) that can be collected, chipped, or 

ground; exported from the forest; and used for power production or manufacture of wood fiber 

products. 

Board Foot — A unit of measurement equal to an unfinished board one-foot square by one-inch 

thick. 

Bole — The main stem of a conifer tree, which becomes a log or logs when the tree is cut. 

Burn Severity — Effects of fire on the soil surface. Related to fire intensity and duration. 

Cable Yarding System — Moving logs from the stump to the landing either partially or fully 

suspended by a cable. Also referred to as a skyline system. 

Canopy (Crown) — The branches and foliage of trees; does not include stems and boles. 

Canopy Base Height — For a single tree, it is the height from an imaginary line drawn across the 

trunk to the bottom of the obvious lowest live foliage. Stated also as the height above the ground of 

the first canopy layer where the density of the crown mass within the layer is high enough to support 

vertical movement of a fire. 

Canopy Cover — The ground area covered by tree crowns, or the degree to which the canopy (forest 

layers above one’s head) blocks sunlight or obscures the sky, expressed as a percent of ground area; 

also referred to as canopy closer or crown cover. 

Capable Lands — Lands where at least 20 cubic feet of commercial wood products can be grown 

per acre per year. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

5-6 Glossary

Classified Road — Roads wholly or partially within or adjacent to National Forest System lands that 

are determined to be needed for long-term motor vehicle access, including State roads, county roads, 

privately owned road, National Forest System roads, and other roads authorized by the Forest Service. 

Climate Change — Climate is not the weather—it is the prevailing or general long-term weather 

conditions for an area, or for the entire planet. Weather is the state of the atmosphere at a particular 

place and time and is influenced by climate and many local factors. Climate change refers to our 

long-term weather patterns and, in the environment, is caused by increasing levels of carbon dioxide 

and other greenhouse gases released into the atmosphere. Greenhouse gases trap heat in the earth’s 

atmosphere. Over time, more and more heat is retained, leading to an increase in the earth’s average 

surface temperature—global warming. 

Coarse Woody Debris (CWD) — Large woody material (fallen dead trees, as well as the remains of 

larger branches) that are at least 15 inches in diameter and 10 feet long. Ideally, these logs are well 

distributed across the treatment unit or landscape and represent the various decomposition classes. 

Term used for terrestrial species habitat. 

Community Capacity — The collective ability of residents in a community to respond to external 

and internal stresses, to create and take advantage of opportunities, and to meet the needs of residents. 

Physical capital, human capital, and social capital are the primary components of community 

capacity. 

Compaction Hazard — Susceptibility of the soil to compaction based on soil properties such as soil 

texture in the upper 12 inches, percent by volume of cobbles and stones, percent organic carbon in the 

upper 6–12 inches, duff thickness in inches, and soil structure. Compaction susceptibility fluctuates 

with the percent of soil moisture. 

Critical Habitat — Defined in the ESA as (1) the specific areas within the geographical area occupied 

by the species, at the time it is federally listed, on which are found those physical or biological 

features essential to the conservation of the species, and which may require special management 

considerations or protection; and (2) specific areas outside the geographical area occupied by the 

species at the time it is listed, when it is determined by the Secretary of the Interior that such areas are 

essential for the conservation of the species. 

Crown Bulk Density (CBD) — The weight of the canopy per unit volume. A mathematical model 

taken from cruise/forest inventory data using these measurements: tree diameters at breast height, tree 

height, ratio of crown height to tree height, and crown width. Species factors are also used, newer 

inventory methods just use species, basal area, and stand density. 

Crown Fire — A fire that advances through the canopy of a forest, either as a passive, active, or 

independent crown fire. Effective strategies for reducing crown fire occurrence and severity are to 

(1) reduce surface fuels, (2) increase height to live crown, (3) reduce canopy bulk density, and 

(4) reduce continuity or density of the forest canopy. 

Crown Fuel — Expressed as canopy cover or crown bulk density includes living and dead foliage. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Glossary 5-7

Currently Active Landslide — This term is used by the author to denote landslide features 

exhibiting fresh scarps, ground facture, or other evidence the slope movement has occurred very 

recently or is ongoing. 

Cumulative Effects — Those effects resulting from incremental effects of actions, when added to 

other past, present, and reasonably foreseeable future actions, regardless of what agency or person 

undertakes such other actions. 

Cumulative Watershed Effects Model — A model for Cumulative Watershed Effects with three 

components: Equivalent Roaded Acres (ERA), sediment delivery from surface erosion, and sediment 

delivery from mass wasting. The model quantifies disturbances and land sensitivity at the 7th field 

watershed scale and can calculate them at larger scales. The estimated results fall on a continuum. As 

disturbances increase over time and space, at some point the risk of initiating or contributing to 

existing adverse cumulative watershed impacts becomes a cause for concern. Concern thresholds 

have been identified for each component based on field observations in the Forest. 

Cytospora Canker (Cytospora abietis) — A fungus that infects softwood trees. It kills the cambium, 

girdling the limb and causing death of infected branches. A secondary infection to mistletoe. 

Diameter at Breast Height (dbh) — The diameter of a standing tree at a point 41⁄2 feet above ground 

level, measured from the uphill side. 

Debris slides, debris flows, and debris torrents — These are rapid, shallow-seated slope failures, 

usually initiated in headwater basins. They often follow the path of existing drainage channels (debris 

slides can be an exception). Slide debris can travel great distances and often ends up in a receiving 

channel or valley bottom. 

Direct Attack — Any treatment applied directly to burning fuel such as wetting, smothering, or 

chemically quenching the fire or physically separating the burning from unburned fuel. 

Direct Effects — Those effects occurring at the same time and place as the initial cause or action. 

Desired Condition — The ecological, economic, and social attributes toward which management of 

the land and resources in the plan area are directed. Desired conditions are aspirational and are 

usually long-term in nature. A lengthy period of time may be required to achieve them, and during 

that time they may be modified, if necessary, to respond to changing conditions and/or improved 

knowledge. 

Detrimental Disturbance — Changes in soil properties and conditions that would result in 

significant change or impairment of the productivity potential, hydrologic function, or buffering 

capacity of the soil. Generally occurs when threshold values are exceeded. 

Dispersal — The relatively permanent movement of individual animals from one location to another. 

Usually dispersal is the movement of young animals from where they were born to a site where they 

eventually settle to breed. 

Dwarf Mistletoe (Arceuthobium spp.) — A host specific parasitic seed plant found in all the major 

conifer species (red fir, white fire, Douglas-fir, and incense cedar). 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

5-8 Glossary

Earthflow or Slump/Earthflow — These are deep-seated, slow movements that often produce one or 

more scarp-bench-toe slope profile sequence(s). These are often marked by unusually flat areas 

(benches) on an otherwise steep hillside. 

Ecosystem — A dynamic community of biological organisms, including humans, and the physical 

environment with which they interact. 

Ectomycorrhizae — A mycorrhiza (Greek for fungus roots) is a symbiotic (occasionally weakly 

pathogenic) association between a fungus and the roots of a plant. In a mycorrhizal association, the 

fungus may colonize the roots of a host plant either intracellularly or extracellularly. Mycorrhizas are 

commonly divided into ectomycorrhizas and endomycorrhizas. The hyphae (a thread-like part of the 

vegetative portion of a fungus) of ectomycorrhizal fungi do not penetrate individual cells within the 

root. 

Effects — Impacts; physical, biological, economic, and social results (or expected results) from 

implementing an activity. 

Embeddedness — Degree to which large streambed materials such as cobbles and gravel are 

surrounded or covered by fine sediment. 

Endangered Species — Any species that is in danger of extinction throughout all or a significant 

portion of its range. 

Entrenchment ratio — A measure of channel confinement during flood flows. Values greater than 

1.5 indicate presence of a stream terrace or floodplain. 

Environmental Justice — Executive Order 12898 requires an assessment of whether minorities or 

low-income populations would be disproportionately affected by proposed actions. 

Equivalent Road Acres (ERA) — An index of average watershed disturbance expressed in 

road-equivalent acres relative to a “threshold of concern” assigned for the watershed. 

Erosion — A general term for movement of soil particles on the surface of the land initiated by 

rainfall and running water. This includes surface erosion and channel erosion, as opposed to 

landsliding. 

Erosion Hazard Rating (EHR) — Relative risk of accelerated sheet and rill erosion. Factors included 

in this rating are soil erodibility (soil texture and aggregate stability), runoff production (climate, 

water movement in the soil, runoff from adjacent lands, and slope length), and soil cover (quantity 

and quality) and soil cover distribution. 

Filtering Capacity — Ability of a riparian reserve to trap sediment and prevent it from reaching a 

stream. 

Fine Fuels — Fuels that ignite readily and are consumed rapidly by fire (for example, cured grass, 

fallen leaves, needles, small twigs less than 1/4 inch in diameter). 

Fir Engraver Beetle (Scolytus ventralis) — A burrowing beetle that attacks most true fir species in 

the western United States. Attacks can result in bark kill around the tree bole, top kill, and tree 

mortality. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Glossary 5-9

Fire Behavior — The manner in which a fire reacts to fuels, weather, and topography. Flame length, 

fire type, tree mortality, fuel loading, and canopy base height are all measures used in understanding 

fire behavior for current conditions and for evaluating pre- and post-treatment conditions. 

Fire Frequency — The average number of years between fires. 

Fire Intensity — A general term relating to the heat energy released in a fire. 

Fire Regime — The combination of fire frequency, predictability, intensity, seasonality, and 

distinctive characteristics of fire in an ecosystem. Agee (1993) defines three broad categories of fire 

severity “based on the physical characters of fire and the fire adaptations of vegetation:” 

Low-Severity Fire Regime — Effect of typical fire is benign. Fires are frequent (often less 

than 20 years), of low intensity, and the ecosystems have dominant vegetation well-adapted to 

survive fire. 

Mixed-Severity Fire Regime — Fires are of intermediate frequency (25–100 years), range 

from low to high intensity, and have vegetation with a wide range of adaptation. 

High-Severity Fire Regime — Fires are usually infrequent (often more than100 years) but may 

be of high intensity, most vegetation is at least top-killed. 

Fire Return Interval — Number of years between two successive fire events in a given area. 

Fire Risk — The statistical probability of a fire start occurring over a ten-year period for a given 

thousand-acre area. 

Fire Severity — The degree to which a site has been altered or disrupted by fire; severity is affected 

by fire intensity and how long the fire remains at the site. In this document, fire severity is defined as 

tree mortality. A qualitative term used to describe the relative effect of fire on an ecosystem, 

especially the degree of organic matter consumption and soil heating. Thus, fires are commonly 

classed as low, moderate, and high severity. 

Fire Suppression — All work and activities associated with extinguishing a fire. 

Fire Type — Fire type is described in four ways. The first type is a surface fire, which burns only the 

fuels at or near the surface without torching the trees above—this is the desired condition. The second 

type is the passive crown fire, which torches out individual or small groups of trees as the surface 

fuels burning under them provide the convective heat to ignite the above-ground fuels. The third is 

the active crown fire in which fire is spread from tree to tree in conjunction with the convective heat 

of the surface fuels burning under them. The fourth is the Independent or running crown fire—this is 

a very rare occurrence in which the fire is spread from tree to tree independent of the burning surface 

fuels. This type of crown fire requires extreme weather conditions and contiguous heavy tree canopy. 

Fish-bearing Streams — Fish-bearing streams are distinguished from intermittent streams by the 

presence of any species of fish for any duration. Many intermittent streams may be used as spawning 

and rearing streams, refuge areas during flood events in larger rivers and streams, or travel routes for 

fish emigrating from lakes. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

5-10 Glossary

Flame Length — The length of flame measured in feet—it is measured from the base of the flame to 

the tip of the flame. It is an indicator of fire intensity: longer flame lengths increase resistance to 

control and the likelihood of torching events and crown fires. 

Forest Plan (LRMP) — The Klamath National Forest Land and Resource Management Plan, 

approved in 1995. The Forest Plan provides land allocations, Standards and Guidelines, and direction 

for management of the Klamath National Forest. 

Forest Survey Site Class (FSSC) — Estimate of a site’s suitability for commercial conifer 

production. Based on soil and environmental factors such as soil depth, parent material, water holding 

capacity of the soil profile, precipitation, temperature, aspect, pH, compaction, and depth to a 

standing water table. 

Fuel Arrangement — Describes how fuels are distributed in the fuel bed. 

Fuel Bed — The fuels laying on or very near the forest floor, both living and dead, that are available 

to burn. 

Fuel Load / Loading — Refers to the fuel that would be available for consumption by fire. Fuel load 

and depth are significant fuel properties for predicting whether a fire will be ignited, its rate of spread, 

and its intensity. Fuel loading can slow the suppression efforts of firefighters if there are large 

accumulations of dead and down fuel. 

Fuels — Anything within the forest that will burn; usually live and dead woody vegetation. 

Fuel Profile — The term used to describe all available fuel, living and dead, including ground, 

ladder, and crown fuels. 

Fuel Treatment — The process of removal, consumption, or rearrangement of naturally or 

human-created fuels to reduce fire hazard and achieve other resource objectives. 

Full-Bench Skid Trails — For ground-based equipment skid trails, the entire trail surface is cut into 

the hill slope. 

Geographic Information System Coverage — Data layer in a geographic information system. 

Grapple System — A mechanical method of piling fuels using an articulating arm on a low ground 

pressure vehicle that picks up the material and places it on the pile. 

Green Tree Retention — A regeneration cut in an even-aged silvicultural system that maintains a 

portion of the existing stand, creating a two-storied structure with two or more age classes present. 

Ground-based Equipment — This means equipment that runs on the ground, like tractors, 

rubber-tired skidders, and masticators. 

Hawksworth Rating System — A system developed by Hawksworth in 1977 to rate severity of 

infection by dwarf mistletoe in a tree or stand. The rating system forms a basis for defining 

management implications and recommendations. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Glossary 5-11

Hazard — When used in fuels management, refers to the existence of a fuel complex that constitutes 

a threat of unacceptable fire behavior and severity, or suppression difficulty. 

Healthy Stand (for the Project Area) — Exhibits insect and disease levels such that mortality is not 

substantial (snag and coarse woody debris levels are within Forest standard and guidelines); little 

decadence (few dead or dying trees, relatively few large down logs or snags) although the area 

maintains some structural components of older stands; trees per acre (stocking level) within the range 

that can be supported by the land; and conditions such that wildfire would not burn more than 

25 percent of the dominant vegetation at a high intensity. 

Heritage Resources — Heritage resources are archaeological, cultural, and historical legacies from 

our past and are more than 50 years old. Heritage resource information, combined with environmental 

data, can illuminate past relationships between people and the land. 

Historic Resources — Historic-era artifacts occurring in sufficient quantity or complexity, and/or 

groupings of artifacts and historic features/properties that are in excess of 50 years old. 

Hot Deck/Decking — As in “hot-decking” of logs. Basically, hot decking occurs when the running 

surface of the road is not wide enough for both the cable yarder and the logs. The logs have to be 

moved out of the way so another load can be brought to the road, where trucks haul them away—this 

eliminates the need for landing construction because the road prism itself serves as the landing. 

Hydrologic — Dealing with the movement and properties of liquid water in environmental systems. 

Includes the circulation patterns of water in the biosphere from condensation and precipitation to 

movement both on and under the ground surface to evaporation back into the atmosphere. 

Hydrologic Recovery — Harvested timber stand with sufficient canopy closure that snow 

accumulation, melt rates, and soil protection from raindrop impact are comparable to pre-harvest 

levels. This typically is achieved when the average tree size is 8 inches diameter breast height or 

35 feet tall. Recovery is complete by around 30 years after harvest on the westside of the Forest. 

Incorporation by Reference — A technique used to cut down on the bulk in environmental 

documents without impeding agency and public review of the action. The material included as part of 

the document must be cited in the document and its content briefly described. 

Indirect Effects — Those effects occurring later in time or that are spatially removed from the 

activity. 

Inference Point — The midpoint of a zone where disturbances become great enough to cause 

concern about initiating or contributing to adverse cumulative watershed effects. 

Infiltration (Soil) — The movement of water through the soil surface into the soil. 

Interdisciplinary — The utilization of individuals representing two or more areas of knowledge and 

skills focusing on the same subject. 

Intermittent Stream — Intermittent streams are defined as any nonpermanent flowing drainage 

feature having a definable channel and evidence of annual scour or deposition. This includes what are 

sometimes referred to as ephemeral streams if they meet these two physical criteria. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

5-12 Glossary

Irretrievable — An irretrievable commitment of resources entails a loss of production, harvest, or use 

of natural resources. Such decisions are reversible, but the production opportunities foregone are 

irretrievable (50 Federal Register 26082). 

Irreversible — An irreversible commitment of resources entails a loss of future options. This applies 

primarily to the effects of use of non-renewable resources such as minerals or cultural resources, or to 

those factors, such as soil productivity, that are renewable only over a long period of time (50 Federal 

Register 26082). 

Issue — Point of discussion, debate, or dispute about the environmental effects of the proposed 

action. 

Ladder Fuels — A vertical continuity in fuel between the ground and the crowns of a forest stand; 

shrubs or trees that connect fuels at the forest floor to the tree crowns. Ladder fuels are expressed in 

feet. 

Land Allocation — The assignment in the LRMP of a management emphasis to particular land areas 

with the purpose of achieving goals and objectives. 

Large Woody Debris (LWD) — LWD (logs) that are present in the bankfull channel and 

hydraulically significant in altering flow direction and velocity. 

Late-Successional Characteristics — Characteristics of a stand of trees indicative of maturity, 

including mature and overmature trees in the overstory; multi-layered canopy with trees of several 

age classes; and standing dead trees and down material. 

Late-successional Habitat — Older forested stands with moderate to high canopy closure; often 

containing a multilayered, multispecies canopy dominated by large overstory trees; large trees with 

broken tops or other indications of old and decaying wood; numerous large snags; and moderate to 

heavy accumulations of large logs on the ground. 

Late-successional Forest — Forest stands consisting of trees, structural attributes, supporting 

biological communities, and processes associated with old-growth and/or mature forests. Forest seral 

stages include mature and old-growth age classes (identified in the Northwest Forest Plan). Age is not 

necessarily a defining characteristic, but it has been used as a proxy or indicator in some usages. The 

minimum ages are typically 80 to 130 years, more or less, depending on the site quality, species, rate 

of stand development, and other factors. 

Late-successional Stands — Late-successional stands in the Assessment Area are defined as stands 

with an average diameter at breast height greater than 24 inches. On the north-and east-facing slopes, 

theses stands contain a mix of conifer species and generally exhibit complex structure and abundant 

down woody debris. Late-successional stands on south-and west-facing slopea are typically more 

open and pine dominated with less down woody debris. True fir late-successional stands are generally 

single storied with little understory. 

Late-Successional Reserves (LSR) — Large blocks of habitat that are distributed across the range 

of the northern spotted owl and spaced closely enough to facilitate dispersal of owls. 

Late-successional reserves are managed to provide habitat for late-successional and “old growth” 

species. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Glossary 5-13

Log Decomposition Classes — 

Class I: Fresh, hard logs or trees with little soil contact. 

Class II: Hard logs in partial contact with the soil. 

Class III: Intact, soft logs in full contact with the soil. 

Class IV: Intact to fractured cubical heartwood and bark, mostly buried in the soil. 

Class V: Totally buried, fractured cubical heartwood (low mound on the forest floor). 

LRMP — The Klamath National Forest Land and Resource Management Plan, approved in 1995. The 

Forest Plan provides land allocations, Standards and Guidelines, and direction for management of the 

Klamath National Forest. 

Management Area — A distinct geographical area with specified objectives and prescriptions. 

Management Direction — A statement of multiple use and other goals and objectives, along with the 

associated management prescriptions and Standards and Guidelines to direct resource management. 

Mass Wasting — Movement of soil material in landslides and debris torrents. 

Mastication — Mastication involves the mechanical chipping, grinding, and scattering of fuels using 

a rotating hydraulic head attached to a tracked excavator or tractor. Wood chips from mastication 

provide physical soil cover to disturbed areas and allows a masticator to operate on the layer of wood 

chips with minimal soil disturbance. 

Masticator — Equipment that grinds or chews up vegetative material. 

Matrix — Lands outside of reserves and withdrawn areas; lands assigned a regulated timber yield. 

Monitoring — Process of collecting information to evaluate if objective and anticipated or assumed 

results of a management plan are being realized or if implementation is proceeding as planned. 

Montane — Pertaining to mountain conditions. 

Multilayered — A stand with three or more distinct foliage layers (canopies). Trees in the different 

layers may or may not be in the same age class. 

Mycorrhizae — A beneficial association between a fungus and roots of a plant. 

National Environmental Policy Act (NEPA) — The act that governs how federal agencies assess 

impacts of management actions on public lands. The process is interdisciplinary and requires 

consideration of the environmental effects of alternatives and disclosure of those effects. 

National Forest System Road — A classified Forest road under the jurisdiction of the Forest 

Service. The term “National Forest System Roads” is synonymous with the term “forest development 

roads” as used in 23 U.S.C. 205. 

Northern Spotted Owl (NSO) Core Area — An area defined by a 0.5-mile radius around a NSO 

activity center that owls use most often, especially during the nesting season. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

5-14 Glossary

NSO Home Range — An area defined by a 1.3-mile radius around a NSO activity center within 

which owls forage, nest, and roost. 

Noxious Weed — Any plant so designated by the Weed Control Regulations and identified on a 

regional district noxious weed control list. They are generally non-native and resistant to control 

efforts. 

Overstory — The portion of trees in a forest which forms the uppermost layer of foliage. 

Particulate Matter (PM) — Particles less than 10 micrometers in diameter (PM10) pose a health 

concern because they can be inhaled into and accumulate in the respiratory system. Particles less than 

2.5 micrometers in diameter (PM2.5) are referred to as "fine" particles and are believed to pose the 

largest health risks. Because of their small size, fine particles can lodge deeply into the lungs. Sources 

of fine particles include all types of combustion (such as motor vehicles, power plants, and wood 

burning) and some industrial processes. Particles with diameters between 2.5 and 10 micrometers are 

referred to as “coarse.” Sources of coarse particles include crushing or grinding operations and dust 

from paved or unpaved roads. 

Passive Crown Fire — A fire that remains on the ground surface but exhibits some individual tree or 

group torching. Fire intensity is still fairly low. 

Peak Flow — The greatest stream or river flow occurring in a year from a single storm event. 

pH (potential of hydrogen) — It is the measure of acidity or alkalinity of a solution or a damp 

substance, such as soil. The pH of pure water is 7, with lower numbers indicating acidity and higher 

numbers indicating alkalinity. 

Rain-on-Snow Event — Rain falling on a snowpack and rapidly melting the snow, causing the melt 

water to be added to the rain, creating flood conditions. 

Rate of Spread — The estimated or observed spread distance of a fire. It is expressed generally in 

chains per hour (ch/hr). 

Record of Decision — A document separate from but associated with an environmental impact 

statement that states the management decision and provides the rationale for that decision. 

Reforestation — The natural or artificial restocking of an area with trees. 

Resilience — An ecosystem’s ability to maintain structure and patterns of behavior in the face of 

disturbance. 

Resistance to Control — The relative difficulty of constructing and holding a control line as 

affected by resistance to line construction and fire behavior; also called “difficulty of control.” 

Rill — Very small streams occurring during or directly after precipitation, especially on bare soil, 

often creating a temporary gully and causing rill erosion. 

Riparian — In general, characterized by being situated on the bank of a river or other body of water. 

In ecology, the term is applied both to species that live near streams and to the area adjacent to 

streams where vegetation and microclimate are influenced by the presence of the stream. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Glossary 5-15

Riparian Reserves — A land allocation in the LRMP that includes an aquatic ecosystem and the 

adjacent upland areas directly affecting it. It also includes unstable and potentially unstable lands that 

are not associated with aquatic areas. Specific Standards and Guidelines provide direction for these 

areas as outlined in Management Area 10 of the LRMP. 

Risk — The chance of loss. 

Risk Ratio (for cumulative watershed effects model) — The amount of the disturbance in the 

watershed relative to the hydrologic or sediment inference point. 

Road — A motor vehicle travelway over 50 inches wide, unless classified and managed as a trail. A 

road may be classified, unclassified, or temporary (36 CFR 212.1). 

Roads (Classified) — Roads wholly or partially within or adjacent to National Forest System lands 

that are determined to be needed for long-term motor vehicle access, including State roads, county 

roads, privately owned roads, National Forest System roads, and other roads authorized by the Forest 

Service (36 CFR 212.1). 

Scenic Attractiveness — The scenic importance of a landscape based upon the intrinsic beauty of 

landforms, geology, water bodies, and vegetation. 

Scenic Character — The combination of physical, biological, and cultural images that give an area 

its positive scenic identity and sense of place. 

Scenic Integrity — The degree to which a landscape is free from visible disturbances that detract 

from the natural or socially valued appearance, including any visible disturbances due to human 

activities or extreme natural events. The Klamath LRMP uses VQOs to measure visual disturbance. 

Scenic Quality — The degree to which the appearance of a place, landscape or feature can elicit 

psychological and physiological benefits to individuals and, therefore, to society in general. 

Scenic Stability — The degree to which the valued scenic character can be sustained through time 

and ecological progression. 

Soil Cover — Amount of surface area covered by low growing vegetation (grasses, forbs, and 

prostrate shrubs), plant litter and debris, and surface rock fragments larger than 3⁄4 inches. 

Soil Displacement Hazard — Susceptibility of the soil to mechanical displacement. This assessment 

is based on soil properties such as surface texture, organic carbon in the surface 6 inches, thickness of 

the duff layer, percent coarse fragment content by volume, soil structure, bulk density, and cohesion. 

Generally defined as a loss of either 2 inches or 0.5 inch of the humus enriched topsoil, whichever is 

less, from a 1-meter square or larger area. 

Soil Quality Assessment Standards (SQAS) — Established in June of 1995 (FSH R5 Supplement 

No. 2509.18-95-1), these standards focus on protection and improvement of National Forest System 

Lands for continuous forest and rangeland productivity and favorable water flows. Direction for Soil 

Quality found in the handbook supplements describes the standards and thresholds, provides 

information about monitoring, examples of practices and mitigation measures, direction for 

application of the standards, and responsibilities for meeting them. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

5-16 Glossary

The term “unstable slopes” is a generic term used for all classes of slope movement. More specific 

categories include: 

Stand — A recognizable area of the forest (either a community of trees or other vegetation) that can 

be managed as a single unit because it is relatively homogeneous (having uniform composition, 

constitution, age, spatial arrangement or condition) and distinguishable from adjacent communities. 

Stand Characteristics / Attributes — A description of stand characteristics takes into account 

canopy cover, crown bulk density, stand structure, and density. Stand structure is a description of the 

distribution of tree size classes (such as saplings, poles, small trees, etc.) within a stand. Understory 

and overstory are some other terms that are used in referring to stand structure. 

Strata — Similar stands of trees that are combined (stratified) for data collection and stand analysis. 

Stands in the Eddy Gulch LSR Project Assessment Area were stratified by Society of American 

Foresters (SAF) forest type (for example, Douglas-fir or white fir) and successional stage (such as 

mid-successional) based on dominant / co-dominant average tree size. 

Succession — A series of dynamic changes by which one group of organisms succeeds another 

through stages leading to a potential natural community or climax (final stage). An example is 

development of a series of plant communities (called seral stages) following a major disturbance. 

Surface Fire — A fire that burns dead and down woody fuel, and smaller vegetation with little to no 

torching of larger shrubs and conifers. Surface fire activity is described with rate of spread, flame 

length primarily. 

Temporary Roads — Roads authorized by contract, permit, lease, other written authorization, or 

emergency operation, not intended to be a part of the forest transportation system and not necessary 

for long-term resource management (36 CFR 212.1). 

Toe Zones — Accumulations of colluvium (loose rock and soil), usual originating from 

slump/earthflow features. The downslope face of this material is usual oversteepened, often wet, with 

potential for further movement. 

Torching — The envelopment in flame of live or dead branches on a standing tree or group of trees. 

Treatment Unit — The acres proposed for some type of on-the-ground treatment under a particular 

alternative. 

Unclassified Roads — Roads on National Forest System lands that are not managed as part of the 

forest transportation system, such as unplanned roads, abandoned travelways, and off-road vehicle 

tracks that have not been designated and managed as a trail; and those roads that were once under 

permit or other authorization and were not decommissioned upon the termination of the authorization 

(36 CFR 212.1). The regulations at 36 CFR 223.37 require revegetation within 10 years. 

Recreation Opportunity Spectrum (ROS) — A continuum of recreation opportunity settings. A 

recreation opportunity setting is a combination of physical, biological, social, and managerial 

conditions that give value to a place. The ROS assumes that recreationists seek a range or spectrum of 

recreational opportunities from the highly constructed and interactive to the natural and solitude 

oriented. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Glossary 5-17

Road Cut — Soil or rock material removed during road construction, usually from the upslope side 

of the road. 

Road Fill — Soil or rock material placed on the ground as part of the road surface. 

Road Maintenance — The ongoing upkeep of a road necessary to retain or restore the road to the 

approved road management objective. 

Salvage — Removal of recently-dead, dying, or deteriorating trees to minimize the loss of wood 

products. 

Saprophytic — These species obtain nutrients by the decomposition of dead organic matter. 

Scoping — The process used to identify the scope of issues to be addressed and to determine the 

significant issues related to a proposed action. 

Sediment — Soil particles in water. Suspended sediment consists of small soil particles carried along 

by the water’s turbulent flow. 

Silviculture — The art and science of growing and tending forest vegetation. It includes controlling 

the establishment, composition, and growth of forests for specific management goals. 

Silviculture Prescription — A site-specific operational plan that describes the forest management 

objectives for an area. It prescribes the method for harvesting the existing forest stand, and a series of 

silviculture treatments that will be carried out to establish a free-growing stand in a manner that 

accommodates other resource values as identified. 

Site Potential Tree Height — The average maximum height of the tallest dominant trees (200 years 

or older) for a given site class. 

Soil Porosity — State of having pores or holes in the soil that hold air or water; permeability. 

Stability rating — A rating system to gauge a stream's susceptibility to scour. It evaluates physical 

and vegetative conditions on upper and lower stream banks and wetted channels. 

Snag — A standing dead tree. 

Social Analysis — Analysis that uses social science information to determine how proposed actions 

would affect humans. 

Soil Productivity — The capability of a soil to produce a specific crop such as fiber, forage, etc., 

under defined levels of management. 

Stand — A community of trees or other vegetation uniform in composition, constitution, age, spatial 

arrangement, or condition to be distinguishable from adjacent communities. 

Stand Density Index (SDI) — A relative measure of the amount of stocking on a forest area. Often 

described in terms of stems per acre. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

5-18 Glossary

Standard and Guideline — A principle requiring a specific level of attainment, a rule to measure 

against. The Klamath National Forest Land and Resource Management Plan contains the Standards 

and Guidelines for managing the forest. 

Stocking — The degree to which trees occupy the land, measured by basal area (BA) and/or number 

of trees by size and spacing, compared with a stocking standard; that is, the BA and/or number of 

trees required to fully utilize the land's growth potential. Where tree growth is inhibited due to 

competition from too many trees, the site is said to be overstocked. 

Substrate fines — The percentage of substrate particles less than 2 mm in diameter as determined by 

an extractive core sampling method. 

Suppression Forces — Resources used to fight a fire, consisting of firefighters with hand tools at a 

minimum. May also include fire engines and bulldozers, helicopters and tanker planes. 

Suppressed Trees — Smaller trees in the lower canopy layer. 

Surface fines — The percentage of substrate particles less than 2 mm in diameter as determined by a 

grid tally on the surface of pool tail outs. 

Surface Fire — Fire that remains on the forest floor because the combination of fire intensity and 

ladder fuels is not sufficient to move it into the tree crowns. Only surface fuels and small vegetation 

are burned. 

Surface Fuels — Loose combustible material on the soil surface, consisting of fallen leaves, twigs, 

bark, and small branches, as well as grasses, small plants, seedlings trees, dead branches, and logs. 

Sympatrically — Species that occupy the same area without interbreeding. 

Thinning — Removing trees from a stand to redistribute the growth potential or to benefit the quality 

of the residual stand. 

Threatened Species — Any species that is likely to become an endangered species within the 

foreseeable future throughout all or a significant portion of its range. 

Torching — Ignition and subsequent flare-up of a fire, usually burning from the bottom to the top of 

a tree or small group of trees. 

Tree Crown — Leafy portion. 

Turbidity — Deposition of substrate material suspended in water. 

Unclassified Road — Roads on National Forest System lands that are not managed as part of the 

Forest transportation system, such as unplanned roads, abandoned travelways, and off-road vehicle 

tracks that have not been designated and managed as a trail; and those roads that were once under 

permit or other authorizations and were not decommissioned upon the termination of the 

authorization. 

Understory — Vegetation (trees or shrubs) growing under the canopy formed by taller trees. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Glossary 5-19

V* — The percentage of residual pool volume occupied by fine sediment. Another measure of stream 

sedimentation (Hilton and Lisle 1993). 

Values at Risk — Any or all natural resources, improvements, or other values that may be 

jeopardized if a fire occurs. 

Vertical Fuels — Standing vegetation, either live or dead. 

Visual absorption Class — The relative ability of a landscape to absorb alterations without loss or 

degradation of scenic quality. 

Visual Quality Objectives (VQOs) — Measurable standards for visual resource management based 

on the acceptable degree of alteration of the characteristic landscape. Levels used in the VQOs are as 

follows: 

VQO Des cription 

Preservation Unaltered — Ecological changes only. 

Retention Unnoticeably Altered — Activities are not evident to casual forest visitor. 

Partial Retention Slightly Altered – Activities may be evident but must be subordinate to characteristic landscape. 

Modification Moderately Altered — Activities may dominate, but must utilize naturally-established form and 

texture. Areas should appear natural when viewed in foreground and middleground. 

Maximum 

Modification 

Heavily Altered — Activities may dominate, but must utilize naturally-established form and texture. 

Areas should appear natural when viewed in background. 

Water Repellency (for soils) — Loss of soil porosity, preventing water from infiltrating and causing 

water to run off. 

Watershed — The entire land area that drains to a specific point. 

5th-field Watershed — A watershed that ranges from about 40,000 to 250,000 acres in size. 

6th-field Watershed — A watershed that ranges from about 10,000 to 40,000 acres in size. 

7th-field Watershed — A watershed or drainage that ranges from about 2,500 to 10,000 acres in size. 

Watershed Analysis — Watershed analysis is a systematic procedure for characterizing watershed 

and ecological processes to meet specific management and social objectives. 

Wet Weather Operations Standards — Specific information used to help determine when activities 

are at risk of not meeting BMPs. The guidelines are used to determine if conditions are favorable for 

wet weather or winter operations, and to provide guidance as to when conditions warrant suspension 

of operations, when operations may begin or resume, or when and what remedies may be appropriate. 

Width / Depth Ratio — An index of channel form. Values greater than approximately 12–15 are 

indicative of wider, shallower streams. 

Wildland-Urban Interface — Commonly referred to as the WUI (woo-ee). This is an area, or zone, 

where structures and other human development meet or intermingle with undeveloped wildland or 

vegetative fuels. It generally extends out for 1.5 miles from the edge of developed private land into 

the wildland. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

5-20 Literature Cited

Literature Cited 

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Chapter 1 

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Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

5-36 Index

Index 

Aquatic Conservation Strategy, 1-12, 3-134, 3-225, 

5-1, 5-4 

Best Management Practices (BMP), 2-22, 2-26, 2-33, 

3-93, 3-94, 3-104, 3-105, 3-129, 3-134, 3-135, 

3-137, 3-138, 3-140–3-142, 3-202, 3-229, 3-230, 

5-1, 5-5, 5-19 

Collaboration, xi, xxi, 1-13, 1-15–1-19, 2-1, 2-3, 4-1, 

4-3, 4-5 

Community Wildfire Protection Plan (CWPP), v, vi, 

ix, 1-4, 1-8, 1-12, 1-13, 1-16–1-18, 2-1–2-6, 2-17, 

3-3, 3-18, 3-29, 3-31–3-33, 3-42, 3-45, 3-50, 

3-119, 3-221, 3-232, 4-1, 5-1 

Crown fire, iii, v–viii, x, xii, 1-4, 1-7, 1-9, 1-10, 

1-11, 2-2, 2-5, 2-7–2-10, 2-19–2-22, 3-5, 3-16, 

3-17, 3-24, 3-27, 3-28, 3-32, 3-34–3-36, 

3-39–3-43, 3-45, 3-49–3-52, 3-73–3-75, 

3-89–3-91, 3-96, 3-99, 3-101, 3-107, 3-109, 

3-156, 3-182–3-195, 3-208, 3-213, 3-222, 3-227, 

3-229, 3-231, 5-4, 5-6, 5-9, 5-10, 5-14 

Cumulative Watershed Effects (CWE), 2-25, 3-111, 

3-112, 3-119, 3-129, 3-152, 5-4, 5-7, 5-11, 5-15 

Desired condition, xxi, 1-5–1-9, 1-12, 1-13, 1-20, 

3-2, 3-16–3-18, 3-21, 3-26, 3-40–3-42, 3-46, 3-71, 

3-72, 3-119, 3-122, 3-124, 3-155, 3-195, 3-204, 

5-7, 5-9 

Emergency access route, iii, v–vii, ix, xii, 1-4, 1-8, 

1-10–1-12, 1-18, 2-5–2-8, 2-10, 2-16, 2-17, 

2-20–2-22, 3-4, 3-5, 3-14, 3-18, 3-32, 3-33, 3-42, 

3-45, 3-49, 3-52, 3-58, 3-87, 3-88, 3-96, 3-107, 

3-135, 3-200, 3-221 

Fuel reduction zone (FRZ), iii, vii, 1-11, 2-5–2-7, 

3-4, 3-133, 3-163, 3-176, 5-1 

HFRA (Healthy Forests Restoration Act), v, 1-13, 

1-15, 1-16, 1-18, 1-20, 2-1, 4-9, 5-2 

Klamath National Forest Land and Resource 

Management Plan (LRMP), viii, ix, 1-2, 1-12, 

1-14, 2-3, 2-7, 2-15, 2-22, 2-25, 

Klamath National Forest Land and Resource 

Management Plan (LRMP), 3-4, 3-29, 3-57, 3-70, 

3-71, 3-88, 3-93–3-95, 3-98, 3-99, 3-106, 3-111, 

3-118, 3-120, 3-129, 3-133–3-135, 3-137, 

3-138–3-142, 3-147, 3-149, 3-150, 3-153, 3-154, 

3-156, 3-160, 3-181, 3-196, 3-204, 3-218, 3-222, 

3-224, 3-225, 3-230, 3-232, 4-4, 5-2, 5-4, 5-10, 

5-12, 5-13, 5-15, 5-18 

Landing, ix, x, 1-19, 2-13–2-15, 2-20, 2-26–2-28, 

2-33, 3-87, 3-91, 3-121, 3-123–3-125, 

3-133–3-138, 3-140, 3-142–3-146, 3-149, 

3-151–3-153, 3-156, 3-158, 3-160, 3-161, 3-164, 

3-166–3-168, 3-171, 5-5, 5-11 

Late-Successional Reserve (LSR), iii, v–viii, x–xii, 

xxi, 1-1–1-9, 1-11–1-18, 1-20, 1-21, 2-1–2-4, 2-6, 

2-7, 2-15, 2-17–2-22, 2-25, 2-32, 2-33, 3-1, 

3-3–3-6, 3-8, 3-9, 3-12–3-19, 3-21, 3-22, 3-26, 

3-27, 3-29, 3-31–3-33, 3-35, 3-36, 3-38–3-43, 

3-46, 3-49–3-75, 3-87–3-92, 3-106, 3-111–3-113, 

3-117–3-121, 3-127, 3-133, 3-139, 3-141, 

3-147–3-149, 3-153, 3-155–3-158, 3-168, 

3-173–3-176, 3-181, 3-208, 3-210, 3-211, 3-218, 

3-219, 3-221–3-226, 3-228, 3-230–3-232, 4-1, 

4-3–4-9, 5-2, 5-4, 5-5, 5-12, 5-16 

Municipal, v, vi, xii, 1-4, 1-6, 1-8, 1-10, 1-13, 2-1, 

2-2, 2-5, 2-8–2-10, 2-16, 2-20, 2-21, 3-31, 3-45, 

3-50–3-52, 3-111, 3-119, 3-122, 3-123, 3-128, 

3-129, 3-140, 3-141, 3-146, 3-229, 5-5 

Northern spotted owls (NSO), iii, v, vi, viii, xii, 1-2, 

1-4, 1-7, 1-9, 1-11, 2-2, 2-4, 2-6, 2-7, 2-15, 2-18, 

2-20–2-23, 2-32, 2-33, 3-31, 3-32, 3-35, 3-45, 

3-57–3-59, 3-64–3-69, 3-72–3-75, 3-84–3-92, 

3-95, 3-98–3-101, 3-103, 3-106–3-110, 3-230, 

3-32, 4-5, 4-6, 5-2, 5-12–5-14 

Protection target, 2-2, 2-3, 2-6, 3-29, 3-31, 3-45, 

3-50, 3-52 

Public, iii, vi, vii, x–xiii, xxi, 1-3, 1-6, 1-8, 1-13, 

1-15–1-18, 1-21, 2-1–2-5, 2-17, 2-19–2-21, 2-32, 

3-16, 3-31, 3-32, 3-42, 3-56, 3-58, 4-1, 5-4, 5-11, 

5-13 

Resource protection measures, xi, xxi, 1-15, 2-20, 

2-22, 2-29, 2-31, 2-32, 3-88, 3-93, 3-96, 3-100, 

3-104, 3-133, 3-138, 3-147, 3-149, 3-175, 3-181, 

3-195, 3-196, 3-202, 3-204–3-206, 3-209, 

3-228–3-230, 5-3 

Riparian Reserve, ix, 1-12, 1-13, 2-6, 2-8, 2-10, 

2-16–2-18, 2-24–2-26, 2-29, 2-30, 3-14, 3-60, 

3-79, 3-82, 3-93, 3-94, 3-97, 3-99–3-101, 

3-103–3-105, 3-111, 3-112, 3-115–3-118, 3-120, 

3-122, 3-124–3-127, 3-129, 3-132–3-141, 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

5-37 Index

3-143–3-147, 3-149, 3-152, 3-166–3-168, 3-180, 

3-195, 3-196, 3-198, 3-202, 3-203, 3-205, 4-6, 

5-8, 5-15 

Scoping, xi, xxi, 1-15, 1-17–1-20, 2-1, 2-20, 3-3, 

4-10, 5-17 

Sensitive Species, 3-57, 3-62, 3-70, 3-75, 3-92, 

3-108, 3-147, 3-173, 3-174, 3-183, 4-6 

Surface fire, vii, 1-9–1-11, 2-2, 2-5, 3-40–3-43, 3-46, 

3-49–3-52, 3-90, 3-126, 3-181–3-195, 3-208, 

3-212, 3-213, 3-227, 3-231, 5-9, 5-16, 5-18 

Temporary road, iii, x, xi, 1-18, 1-19, 2-1, 2-13, 

2-19, 2-20, 2-23, 2-26–2-28, 2-32, 2-33, 3-6, 3-24, 

3-87, 3-91–3-95, 3-97, 3-98, 3-101–3-109, 3-129, 

3-132, 3-134, 3-137, 3-138, 3-140–3-142, 

3-144–3-146, 3-152, 3-153, 3-160, 3-165, 

3-167–3-172, 3-207, 3-208, 3-215–3-217, 3-223, 

3-226, 3-228, 3-229, 3-232, 4-7 

Thinning, iii, vii, viii, x, 1-3, 1-7, 1-9, 1-11, 1-18, 

1-20, 2-5, 2-7, 2-11, 2-13, 2-14, 2-18, 2-23, 2-28, 

2-29, 2-31, 3-4–3-7, 3-13, 3-16–3-19, 3-21–3-28, 

3-42, 3-45–3-47, 3-51, 3-84, 3-86, 3-87, 

3-89–3-107, 3-111, 3-121, 3-123–3-125, 3-129, 

3-132–3-138, 3-140–3-146, 3-152, 3-156, 

3-164–3-169, 3-171, 3-172, 3-197, 3-198, 3-200, 

3-201, 3-203, 3-205, 3-214, 3-216, 3-219, 3-220, 

3-223, 3-229, 3-231, 3-232, 4-7, 5-18 
Appendix A 

Maps 
Eddy Gulch LSR Project 

Final Environmental Impact Statement 

Klamath National Forest

Appendix A: Maps A-1

Map A-1. Vicinity of the Eddy Gulch LSR Project. 
Eddy Gulch LSR Project 

Final Environmental Impact Statement 

Klamath National Forest

Appendix A: Maps A-2

Map A-2. Protection areas identified in the Salmon River CWPP.
Eddy Gulch LSR Project 

Final Environmental Impact Statement 

Klamath National Forest

Appendix A: Maps A-3

Map A-3. USFWS priority protection areas. 
Klamath National Forest

A-4

 LSR Project Assessment Area.
Eddy Gulch LSR Project 

Final Environmental Impact Statement 

Klamath National Forest

Appendix A: Maps A-5

Map A-4b. Proposed treatment units in the north portion of the Eddy Gulch LSR Project Assessment Area. 
Eddy Gulch LSR Project 

Final Environmental Impact Statement 

Klamath National Forest

Appendix A: Maps A-6

Map A-4c. Roadside treatments along emergency access routes that do not pass through an FRZ or Rx Unit. 
Klamath National Forest

A-7

 to proposed treatment units—south portion of Assessment Area.
Eddy Gulch LSR Project 

Final Environmental Impact Statement 

Klamath National Forest

Appendix A: Maps A-8

Map A-5b. NSO activity centers, core areas, and home ranges in relation to proposed treatment units—north portion of Assessment Area. 

portion of Assessment Area. 
Eddy Gulch LSR Project 

Final Environmental Impact Statement 

Klamath National Forest

Appendix A: Maps A-9

Map A-6a. View 1: Alternative B–configuration of treatment units with construction of 1.03 miles of new temporary roads and 

Alternative C–configuration of treatment units without construction of 1.03 miles of new temporary roads. 
Eddy Gulch LSR Project 

Final Environmental Impact Statement 

Klamath National Forest

Appendix A: Maps A-10

Map A-6b. View 2: Alternative B–configuration of treatment units with construction of 1.03 miles of new temporary roads and 

Alternative C–configuration of treatment units without construction of 1.03 miles of new temporary roads. 
Eddy Gulch LSR Project 

Final Environmental Impact Statement 

Klamath National Forest

Appendix A: Maps A-11

Map A-7. Eddy Gulch LSR successional stages.
Eddy Gulch LSR Project 

Final Environmental Impact Statement 

Klamath National Forest

Appendix A: Maps A-12

Map A-8. Historical ignitions and large fires in the Eddy Gulch LSR. 
Eddy Gulch LSR Project 

Final Environmental Impact Statement 

Klamath National Forest

Appendix A: Maps A-13

Map A-9a. Surface and crown fire activity, eye level 2–3 mph winds. 
Eddy Gulch LSR Project 

Final Environmental Impact Statement 

Klamath National Forest

Appendix A: Maps A-14

Map A-9b. Surface and crown fire activity, eye level 3–6 mph winds. 
Klamath National Forest

A-15

of Assessment Area.
Eddy Gulch LSR Project 

Final Environmental Impact Statement 

Klamath National Forest

Appendix A: Maps A-16

Map A-10b. Alternative B: Distribution of Fuels Treatments, North Portion of Assessment Area. 
Klamath National Forest

A-17

of Assessment Area.
Eddy Gulch LSR Project 

Final Environmental Impact Statement 

Klamath National Forest

Appendix A: Maps A-18

Map A-11b. Alternative C: Distribution of Fuels Treatments, North Portion of Assessment Area. 
Klamath National Forest

A-19

portion of the Eddy Gulch LSR Project Assessment Area.
Eddy Gulch LSR Project 

Final Environmental Impact Statement 

Klamath National Forest

Appendix A: Maps A-20

Map A-12b. Locations of Riparian Reserves and plantations in the north portion of the Eddy Gulch LSR Project Assessment Area. 
Klamath National Forest

A-21

ves, south portion of Assessment Area.
Eddy Gulch LSR Project 

Final Environmental Impact Statement 

Klamath National Forest

Appendix A: Maps A-22

Map A-13b. Fish Distribution, HUC 7 Watersheds, and Riparian Reserves, north portion of Assessment Area. 
Appendix B 

RESPONSES TO COMMENTS ON THE EDDY GULCH LATE-SUCCESSIONAL 

RESERVE FUELS / HABITAT PROTECTION PROJECT 

DRAFT ENVIRONMENTAL IMPACT STATEMENT
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-1

Appendix B 

Responses to Comments on the Eddy Gulch 

Late-Successional Reserve Fuels / Habitat Protection Project 

Draft Environmental Impact Statement 

This appendix summarizes public and agency comments received on the Eddy Gulch LateSuccessional Reserve Fuels / Habitat Protection Project Draft Environmental Impact Statement (draft 

EIS). The Notice of Availability for the draft EIS was published in the Federal Register on July 24, 

2009. All comments on the draft EIS were received within the 45-day comment period, which ended 

on September 8, 2009. 

B.1 Comment Summary 

Seven comment documents were received, and most comment documents identified individual 

concerns. Responses were developed for 68 individual comments. The exact words of each 

respondent were used rather than summaries of the person’s words to ensure accuracy and objectivity. 

All letters were read once, coded, and then read again by another coder to ensure all issues were 

highlighted. The actual comment documents can be found in Section B.3. Each of the individual 

comments has been bracketed (on the comment document), and each bracket corresponds to the 

numbers assigned to each comment shown in Section B.2. 

Of the seven comment documents, 

 1 was from industry (American Forest Resource Council); 

 1 was from a professional resource manager (Dr. John Menke); 

 2 were from environmental groups (Klamath Siskiyou Wildlands Center, Klamath Forest 

Alliance, and Environmental Protection Information Center; and Klamath Forest Alliance 

and Environmental Protection Information Center); and 

 3 were from regulatory agencies (United States Department of the Interior, Office of 

Environmental Policy and Compliance; United States Environmental Protection Agency; 

and California Water Quality Control Board, North Coast Region). 

The focus during the review of public and agency comments was to identify if there was a need to 

 modify alternatives, including the proposed action; 

 develop and evaluate alternatives not previously given serious consideration; 

 supplement, improve, or modify analysis; 

 make factual corrections; and 

 explain why comments do not warrant further agency response, including reasons that 

support the agency’s position (40 CFR 1503). 

Comments that require substantial changes to the Proposed Action, identify significant new 

circumstances, or that require significant new information will require preparation and recirculation 

of a supplemental EIS (40 CFR 1502.9). The analysis of comments indicates there are no comments 

that would trigger preparation of a supplemental draft EIS. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

B-2 Appendix B: Responses to Comments

B.2 Individual Comments 

Comment Document 1—American Forest Resource Council 

Comment 1.1: Insure landing size is adequate to support the proposed harvest systems. “If whole 

tree yarding is proposed make sure landings can accommodate the merchantable 

and unmerchantable material.” 

Response 1.1: Chapter 2 of the draft EIS, page 2-14, third bullet states: “Existing 

landings would be used. The interdisciplinary (ID) team considered using wholetree yarding to reduce slash treatments, but it would require larger landings and 

additional clearing and was therefore not considered further.” 

Comment 1.2: Following a review of the DEIS and all the associated environmental impacts we 

see no reason to not decide on Alternative B as the alternative to implement. It 

appears to be the most logical alternative and the one that most closely meets 

expectations from the LRMP and project purpose and need. 

Response 1.2: Thank you for your comment. 

Comment 1.3: We recommend Alternative B and ask you as the decision maker to base your 

decision on fact, rather than other commenter’s lack of understanding of the Forest 

ecosystem, personal and group agendas and personal biases. 

Response 1.3: Thank you for your comment. 

Comment Document 2—Dr. John W. Menke 

Comment 2.1: I reviewed with interest and joy this potentially outstanding project to reintroduce 

fire effects on a nearby forest ecosystem of a significant size. The quantity of 

knowledge presently available to assess potential benefits, positive and negative 

effects is remarkable. 

Response 2.1: Thank you for your comment. 

Comment 2.2: In reviewing the draft EIS the only missing analysis I noted was no water yield 

assessment. With the expected temporal reduction in competitive effects among 

plants, this implies some increased watershed output albeit probably small. Given 

the importance of even a small stream flow enhancement, I feel some assessment of 

water flow is called for. 

Response 2.2: The draft EIS, Fisheries BA/BE, and Aquatic Resources Report 

present the effects of treatments on erosion potential, water drafting on stream flow, 

and on the flood regime indicator resulting from creation or presence of impervious 

surfaces such as roads and landings. The possibility of water yield increase from 

temporal reduction in competitive effects among plants (that is, reducing vegetation 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-3

density) was not discussed in the draft EIS because any potential water yield 

increase would most likely be very small and extremely transient. 

A large body of literature exists concerning water yield augmentation through 

vegetation management (for example, Bosch, J.M. and J.D. Hewlett 1982. A review 

of catchment experiments to determine the effect of vegetation changes on water 

yield and evapotranspiration . . . changes on water yield and evapotranspiration. 

J. Hydrol. 55, pp. 3–23). A number of broadly accepted research conclusions (listed 

below) argue against any expectation of measurable water yield increase. 

 A large amount of regeneration cutting (50 percent or more of small watersheds) 

is required to achieve measurable water yield increase—no regeneration cutting 

is proposed in this project. 

 In California’s Mediterranean climate, most precipitation falls in winter when 

vegetation is dormant and not transpiring soil water. 

 Small increases in soil moisture that result from reducing vegetation density are 

most likely used by nearby residual vegetation. That is one of the objectives of 

thinning stands—to improve tree vigor by reducing competition for soil 

moisture and allowing it to be consumed by fewer, healthier trees. (Please note 

that for the Eddy Gulch LSR Project, the proposed thinning is to address the 

need for fuels reduction; however, a beneficial effect of the thinning is a 

reduction in inter-tree competition levels for resources [nutrients, water, and 

sunlight]. This was analyzed in the draft EIS (Section 3.2) and presented in the 

Silviculture Report.) 

 Water yield increase in the mountain west is most effectively achieved by 

changing patterns of snow redistribution into openings created by regeneration 

cutting—no regeneration cutting is proposed in this project. 

 Extrinsic factors (other than vegetation density), such as climate variability, 

fires, and other unforeseeable disturbances, add so much variability to runoff 

data that many years (even decades) of paired-watershed studies under 

controlled conditions are required to validate water yield increases, if any. 

 Rapid regrowth of vegetation makes any yield increases transitory unless 

reductions in vegetation density (usually in the form of maintaining openings 

clear of forest cover) are maintained over time. 

Comment 2.3: Thanks for the opportunity to review the Eddy Gulch Late-Successional Reserve 

Fuels/Habitat Protection Project. The document was very professionally prepared 

and clear in is [its] presentation and findings. 

Response 2.3: Thank you for your comment. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

B-4 Appendix B: Responses to Comments

Comment Document 3—Klamath Siskiyou Wildlands Center, Klamath Forest 

Alliance, and Environmental Protection Information Center 

Comment 3.1: Please note that our organizations support the vast majority of the proposed actions 

in this project. We are encouraged and supportive of the agency’s efforts to conduct 

small diameter thinning and prescribed fire activities in this fire-suppressed project 

area. 

Response 3.1: Thank you for your comment. 

Comment 3.2: Our largest remaining concern involves the logging of “M units” down to 32%-

50% canopy. . . We are particularly concerned with the proposed M unit that would 

remove many of the large trees and snags of an old-growth Shasta Red Fir stand 

(see the DEIS page 25). [not correct page number] 

Response 3.2: Please refer to page 3-26 in the draft EIS and page 29 in the 

Silviculture Report—crown closure in FRZs is expected to vary and to be lower 

than crown closure in stands located outside of the FRZs. As stated on page 2-7 of 

the draft EIS: “The construction of the FRZs would generally be consistent with 

“Activity Design Criterion 9: Shaded Fuelbreak,” as described in the forestwide 

LSR assessment (USFS 1999). The exception to Criterion 9 is that forest canopy 

cover may be less than 40 percent in FRZs” (Criterion 9c). 

The one red fir unit (M Unit 60 – 17 acres) with a predicted 32 percent crown 

closure is the result of existing vegetative conditions. The upper portion of the 

stand is a very old, decadent stand of red fir with a high level of tree mortality. This 

portion of the stand is currently very open. The lower portion of the stand is 

younger and denser with more white fir present. Most of the thinning will occur in 

the lower portion of the stand. 

Comment 3.3: We are also very concerned with the intention to meet snag and coarse woody 

debris requirements on the “landscape level” within this LSR, rather than on the 

unit level. The standards and guidelines of both the Northwest Forest Plan and the 

Klamath National Forest LRMP apply to retention of these features at the unit 

level, rather than the landscape level . . . Page 4-25 of the KNF Forest-wide 

Standards and Guidelines clearly directs the agency to “maintain 5 to 20 pieces of 

CWD [coarse woody debris] per acre in various states of decay.” C-42 of the 

Northwest Forest Plan requires that “snags are to be retained within the harvest 

units at levels sufficient to support species of cavity-nesting birds at 40 percent of 

potential population levels.” Further, the soil mitigation measures identified in the 

DEIS (page 2-27) call for retaining CWD at the level identified in the KNF LRMP 

on a “per acre” basis. 

Response 3.3: Since the Klamath National Forest Land and Resource 

Management Plan (Klamath LRMP) was adopted in 1995, the Klamath National 

Forest has managed snag numbers on a landscape, rather than a unit level, 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-5

according to the Standards and Guidelines (S&Gs). The following are from the 

Klamath LRMP: 

 S&G 6-16: “At a minimum . . . consider the amount of materials existing on site, 

the amount of material needed to provide for nutrient cycling and site 

productivity, the denning needs of wildlife species, and the fire risk as a result of 

fuel material on site. (emphasis added) 

 S&G 8-22: “Assess the availability of snags within each landscape” and 

“Provide an average of 5 snags per acre.....within each landscape. These snags 

need not be equally distributed.” (emphasis added) 

 S&G 8-25: “The number of snags on a given acre will vary, depending on site 

and on the number of snags within the landscape.” 

Please refer to page 2-7 in the draft EIS regarding the Eddy Gulch LSR Project’s 

compliance with the S&Gs contained in the Klamath LRMP. Additionally, on 

page 3-46 of the draft EIS, there are prescriptions aimed at ensuring Klamath 

LRMP S&Gs are met for snags and CWD for the project across the Rx Units. 

As stated on page 2-7 of the draft EIS: “The construction of the FRZs would 

generally be consistent with “Activity Design Criterion 9: Shaded Fuelbreak,” as 

described in the forestwide LSR assessment (USFS 1999). The exception to 

Criterion 9 is that, “Densities of snags and downed logs should be kept relatively 

low and compensated by higher densities outside Shaded Fuelbreaks. Shaded 

Fuelbreaks should be maintained in low-fuel conditions with periodic re-treatments, 

targeting especially accumulated surface fuels and new growth of understory 

vegetation. Dead (snags) or dying trees need to be removed to reduce the safety 

hazards to firefighters and reduce the prolific fire brands that snags produce 

(Criterion 9e). 

Comment 3.4: We are concerned that the 3,184 acres of proposed machine mastication may inhibit 

attainment of the purpose and need for the Project. 

Response 3.4: The two primary objectives (purposes) of the Eddy Gulch LSR 

Project are to (1) protect existing and future late-successional habitat from threats 

of wildfire that occur inside and outside the Eddy Gulch LSR, and (2) reduce 

wildfire threat to communities and municipal water supplies and ensure public and 

firefighter safety. 

Mastication is used in lieu of prescribed burning and is an effective tool for 

reducing the standing biomass of shrubs and small trees that contribute to ground 

and ladder fuels in the project Assessment Area. 

Please review Section 3.3 (“Fire, Fuels, and Air Quality”) in the draft EIS, which 

clearly supports the fact that mastication will serve to meet the purpose and need 

for the Eddy Gulch LSR Project. Chapters 1 and 2 discuss concerns for the LSR 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

B-6 Appendix B: Responses to Comments

and project objectives, Chapter 2 explains why treatments were proposed and the 

specific protection targets, and Chapter 3 describes the effects of mastication. 

On page 3-51, lines 11–24, the analysis states that “Mastication would rearrange 

ground fuels and reduce ladder fuels up to 10 inches dbh. Treatments in M Units 

and masticated areas would maintain their effectiveness longer than the prescribed 

burn treatments because more fuels would be treated. 

Comment 3.5: The last “bright line” issue for our organizations is the agency’s refusal to 

implement sub-part (a) of the travel rule at either the Forest or the Watershed scale. 

During the travel management planning process we have repeatedly been told by 

the Supervisor’s Office that the Klamath National Forest will identify the 

“minimum road system” and propose needed road decommissioning to bring its 

road system in line with its maintenance budget during watershed level projects. 

Yet here, where we have a watershed level project in an LSR planning area that has 

been severely degraded by roads, the Forest Service states that road management is 

“outside the purpose and need for the project.” 

Response 3.5: This project does not analyze the impacts of the current 

transportation system. That analysis, and decisions on closing and 

decommissioning existing roads, are outside the scope of this project. The Pacific 

Southwest Regional Forester has committed to begin addressing Subpart A of the 

Travel Management Rule within the next 18 months; that process will provide 

information needed to identify the minimum road system required for management 

of the Klamath National Forest. 

Comment 3.6: The impacts of removing large trees across the LSR (within the harvest units and 

along 60 miles of roads) has not been adequately analyzed . . . In fact, loss of 

numerous snags and large trees could have a significant impact on the overall 

environment, including canopy, shade, and wildlife. The late successional 

characteristic components in the LSR must be retained. Loss of these old growth 

features may result in a significant harm of an array of species. 

Response 3.6: Please refer to the effects analyses in Section 3.2.5 of the “Forest 

Vegetation” section and Section 3.4 5 of the “Wildlife and Habitat” section of the 

draft EIS. See also the Silviculture Report, the Wildlife and Habitat Report, and the 

Wildlife BA/BE. 

Comment 3.7: Where the risk of major disturbance is very high, management activities should still 

focus on young stands, but activities are permitted in late-successional habitat if 

they: (1) would clearly result in greater assurance of long-term maintenance of 

habitat, (2) would clearly reduce risks of major disturbance, and (3) would not 

prevent the LSR from meeting its intended purpose. Therefore, any action in latesuccessional habitat must be justified with demonstrated benefits to such habitat in 

order to comply with the NFP [Northwest Forest Plan]. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-7

Response 3.7: The modeled wildfires displayed in the draft EIS indicate that there 

would be a significant reduction in crown fire following proposed treatments. 

Because crown fire can result in a high degree of tree mortality, reducing the 

amount of crown fire would likely result in a greater assurance of long-term 

maintenance of habitat within the LSR. This is based on the assumption that 

changing crown fire to surface fire would result in less tree mortality. While 

thinning in late-successional habitat may not enhance habitat quality, it will help 

protect existing late-successional habitat. Additionally, the proposed underburning 

will likely protect and enhance existing late-successional habitat by making these 

stands more resilient to wildfire. Therefore, proposed actions in late-successional 

habitat would not prevent the LSR from meeting its intended purpose. 

Please refer to Alternative A (page 2-2 of the draft EIS) and the 7,200-acre modeled 

wildfire, as well as the effects of the modeled wildfire, which begin on page 3-43. 

An escaped wildfire could adversely affect protection targets (private property, 

municipal watersheds, infrastructure, and northern spotted owl [NSO] core areas). 

The high percentage of crown fire (81 percent) could result in . . . long-term losses 

of late-successional habitat, including NSO core areas. 

The long-term benefits of the treatments are of greater conservation value to 

species (and their habitat) than the short- and long-term adverse effects. The 

demonstrated benefits to LSR habitat from implementation of the Proposed Action 

include longevity through a reduction in fuel loads and reduction in the likelihood 

of stand-replacing fires. Treating significantly fewer acres would not achieve the 

purpose and need for the project (see Chapter 2 of the draft EIS, which explains the 

purpose of each FRZ and Rx Unit). Please also refer to the effects analyses 

contained in Section 3.4 (Wildlife and Habitat) in the draft EIS, the Wildlife and 

Habitat Report, and the Wildlife BA/BE. 

Comment 3.8: We have concerns about the increasing use of the Slashbuster masticator . . . 

Broadly, we are concerned that there has been little monitoring of the affects of the 

Slashbuster. 

Response 3.8: The project design does not require the use of a Slashbuster for 

mastication. Soil monitoring on the Klamath National Forest has shown that, 

overall, masticated units met or exceeded Klamath LRMP S&Gs (Laurent 2007). 

This soil monitoring report is part of the project record. 

Comment 3.9: Attachment number one . . . “Ponderosa pine plantation forests cover nearly 

400,000 acres of California’s National Forests. Fire hazard is extreme both within 

and adjacent to many of these areas which has led to extensive fuel reduction plans 

for plantations and other forests on federal public lands. Although fuels treatments 

have been implemented on a limited basis in California’s plantations, the 

effectiveness of varying methods has only recently received scientific attention. 

This project analyzed the effectiveness of individual and combination treatments to 

provide science-based guidance for fire hazard reduction in these areas. Prescribed 

understory fire, both alone and combined with pre-burn mastication, was most 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

B-8 Appendix B: Responses to Comments

effective for reducing surface fuels and potential fire behavior. Likelihood of active 

crown fire was reduced in masticated stands because bulk density was decreased. 

Predicted torching, tree mortality and flame length were higher in masticated units 

than in prescribed burn units and controls.” 

Given these findings our organizations suggest the use of prescribed fire rather than 

mastication for the reduction of fire hazard in plantations . . . The purpose and need 

for this project could be met via a combination of prescribed burning, understory 

thinning, and road decommissioning. 

Response 3.9: Mastication was included in the alternatives because treatments 

should last longer than prescribed burning, it provides more flexibility to 

implement the project because treatments are not constrained by the air district, and 

it reduces emissions compared to prescribed burning. 

Comment 3.10: Attachment number two . . . “The potential for soil damage during burning of 

masticated fuels is substantial.” 

Response 3.10: Mastication is proposed in lieu of prescribed burning. Thus, 

burning will not occur where vegetation has been masticated. 

Comment 3.11: The third attachment . . . “Treated stands had less shrub cover than untreated 

stands. Three bird species were consistently more abundant on untreated stands. 

Species that were more abundant on untreated stands were associated with shrub 

cover, while those that tended to be more abundant on treated stands were 

associated with open areas, providing further evidence that the treatments were 

responsible for the observed differences in bird community composition.” 

Response 3.11: Reducing tree canopy cover increases shrubs and other groundassociated resources, which increases species richness of wildlife. For more 

information on birds, please see response to Comment 3.17. Please also refer to 

Section 3.4 (Wildlife and Habitat) in the draft EIS, the Wildlife and Habitat Report, 

and the Wildlife BA/BE. 

Comment 3.12: The widespread use of the Slashbuster may in fact alter soil nutrient cycling . . . 

Soil biota is another important element of site level conditions that could be 

impaired by the Slashbuster. Lastly, the Slashbuster could harm mychorizal 

[mycorrhizal] communities that are known to be important symbiots of many 

species. This concern is heightened by the proposal to conduct 69.5 acres of 

mastication within riparian reserves (DEIS page 2-17). 

Response 3.12: Chapter 2, page 2-17, line 15 of the draft EIS, states: 

 RS [Roadside] 3 treatments are in Riparian Reserves and would only consist of 

mastication, hand thin, and pile burn (69.5 acres). 

The 69.5 acres is the total amount of acres that would be treated in this Roadside 

treatment unit (RS 3)—not all 69.5 acres would be masticated because a masticator 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-9

can only be used on slopes less than 45 percent. Please also refer to the Resource 

Protection Measures (RPMs) in the draft EIS Chapter 2, Section 2.9.2.3 

Mastication. Please also refer to the Soils RPMs in Section 2.9.4 

There are numerous types of equipment available to achieve the desired condition 

for masticated units. The draft EIS did not specifically mention the Slashbuster as 

the equipment of choice (see also response to Comment 3.8). 

Section 3.6 of the draft EIS and the Soils Report both discuss the effects on soils 

from implementation of the proposed treatment methods, including mastication. 

Also, in a literature synthesis of over 30 research papers, Sigrid Resh et al. 

(Colorado State and Rocky Mountain Research Station) found the following results 

of research regarding the effects of mastication: 

[Research] Expectations 

 Reduced nutrient availability initially as microbes begin to decompose wood, 

with a net release in the longer term with population turnover and advanced 

decomposition. 

 Changes in soil physical properties through compaction and disturbance. Also, 

changes brought by the effect of increased wood debris, such as soil moisture, 

decreased variability in soil temperature, and changes in soil chemistry. . 

 Large additions of carbon will most likely lead to an increase in soil biota, 

especially fungal species that are the primary wood decomposers. 

[Research] Summary of the Findings 

 Nutrient immobilization, particularly nitrogen, may occur in the short term, but 

after a year or two, net mineralization will predominate. 

 Soil carbon sequestration is possible, especially where mixing with mineral soil 

takes place. 

 Soil physical properties are likely to be altered but the relative impacts (+ or -) 

will be site dependent (for example, extent of compaction, soil temperature, and 

moisture). 

Comment 3.13: Native plants could be harmed . . . the amount of masticated material left on the site 

years after a treatment it is likely that some native understory will be lost. 

Response 3.13: Sensitive plant population boundaries will be flagged, and 

mastication treatments will not occur inside those boundaries. 

Mastication is not synonymous with chipping. The slash material produced by a 

masticator is of a non-uniform particle size and an uneven distribution; thus, water 

and air are exchanged with the soil. Loose fuels, for instance, are ground up very 

little and “thrown out.” Therefore, significant adverse effects on native understory 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

B-10 Appendix B: Responses to Comments

vegetation are not anticipated. Please refer to Section 3.7.4.3 in the draft EIS for 

effects on botanical resources from the proposed treatments. Please also note that 

the RPMs (refer to Chapter 2, Section 2.9.6 in the draft EIS) are intended to protect 

individual plants and maintain habitat characteristics that are critical to the 

maintenance of long-term viable plant populations, in accordance with the desired 

conditions of the S&Gs contained in the Klamath LRMP. 

Comment 3.14: The rampant spread of noxious weeds is a growing problem . . . How does the 

Forest Service anticipate the response of species such as manzanita and ceanothus 

to slashbuser treatment? 

Response 3.14: Regarding the anticipated response of manzanita (Arctostaphylos) 

and Ceanothus to mastication treatments: (i) it is anticipated that mastication 

treatments [of manzanita and Ceanothus] will effectively reduce coverage of those 

species in the short term because re-sprouting of those species after mastication 

treatments is anticipated to be less than after fire (both prescribed fire treatments 

and natural fire). This is due to (1) the “mulching effect” of post-mastication 

treatments upon re-sprouting brush and upon new seedlings, and (2) postmastication treatments, unlike post-fire conditions, do not provide a “clean seed 

bed” that encourages the germination of seed in the soil seed bank. 

Regarding the spread of noxious weeds from mastication treatments: mastication 

treatments are not expected to spread or introduce noxious weed sites in the 

Assessment Area because (i) noxious weed sites will be flagged on the ground prior 

to mastication treatments, and mastication treatments will not occur within the 

noxious weed population boundaries; (ii) mastication treatment areas will be 

surveyed for new noxious weed populations after mastication treatments occur; and 

(iii) mastication equipment will be brought in clean (debris free), and not be staged 

in areas known to have noxious weed infestations. New noxious weed populations, 

resulting from project implementation, will be treated and monitored. 

Please refer to the RPMs in Chapter 2, “Section 2.9.6.3 Noxious Weeds.” 

Comment 3.15: Is there currently a way for the public or the decision maker to anticipate the 

amount of treatment [Slashbuster use] that is likely to take place across the 

landscape? We are curious how the Forest Service chooses the sites on which to 

implement the Slashbuster treatment. Is there currently a prioritization of vegetation 

density, proximity to the community protection zone, vegetation type, or any other 

parameters or vectors? What criteria are currently being used to determine the 

location of proposed slashbuster treatments? 

Response 3.15: The project has not limited mastication treatments to the 

Slashbuster, as there are other types of machinery that can be used (see response to 

Comments 3.8, 3.9, and 3.12). 

Sections 2.5.1 and 2.5.2 in Chapter 2 of the draft EIS provide detail on where and 

why the treatment units were designed. Regarding mastication, where there is a 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-11

need to reduce fuels, mastication is proposed in those areas where the slope is less 

than 45 percent. In areas with slopes greater than 45 percent, prescribed fire is 

proposed for fuels reduction. Please also review tables 2-1 and 2-5 in Chapter 2 of 

the draft EIS—these two tables describe what protection target (emergency access 

route, municipal watershed, NSO activity center, United States Fish and Wildlife 

Service [FWS] Priority Areas) each treatment unit was designed to protect. 

Comment 3.16: Our organizations are very interested in learning about the impacts of slashbuster 

treatment on such “fire variables” as residence time, short-term fuel loading, longterm vegetative response, and microclimatic conditions on the site. This 

information is relevant to whether an EA, or EIS, should be prepared for this 

project. 

Response 3.16: The project has not limited mastication treatments to the 

Slashbuster, as there are other types of machinery that can be used. The effects of 

mastication on fire behavior and fuel loading were described on page 3-47 and in 

Figure 3-8. The vegetation response was addressed in the responses to 

Comments 3-13 and 3-14. The draft EIS presents the effects of mastication. 

Comment 3.17: Refugia for many species could be impaired by the widespread and ubiquitous use 

of the Slashbuster. Please disclose all literature or scientific studies relied upon in 

the analysis of impacts on Neotropical birds in the EIS. 

Response 3.17: The project has not limited treatments to the “Slashbuster,” as 

there are other types of machinery that can be used. 

On December 12, 2008, a Memorandum of Understanding (MOU) was signed by 

the U.S. Department of Agriculture Forest Service and the FWS to promote the 

conservation of migratory birds. For the Klamath National Forest, the migratory 

bird species of management concern are those bird species listed under the 

Endangered Species Act as Threatened or Endangered, those species designated by 

the Regional Forester as Sensitive Species, and those species listed under S&Gs 8-

21 through 8-34 of the Klamath LRMP (USFS 1995) as Management Indicator 

Species (MIS) for project level assessment (see Table 1 in the Wildlife and Habitat 

Report). Please refer to page 5 of the Wildlife and Habitat Report, Section 1.4.4 

Migratory Bird Treaty Act (16 USC Sec. 703, Supp. I, 1989) and the Migratory 

Bird Conservation Memorandum of Understanding. The Eddy Gulch LSR Project 

was not designed around individual bird species; however, impacts on specific 

species were analyzed. The draft EIS (Section 3.4.5), the Wildlife BA/BE, and the 

Wildlife and Habitat Report discuss potential effects on species listed under the 

Endangered Species Act, Forest Service Sensitive, and MIS species. Please refer to 

the literature cited sections in the draft EIS, Wildlife and Habitat Report, and the 

Wildlife BA/BE. See also the response to Comment 3.11. 

Comment 3.18: It is reasonable to develop and consider an alternative that would reduce the road 

density in the planning area . . . Please also note that implementation of an 
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Klamath National Forest Eddy Gulch LSR Project

B-12 Appendix B: Responses to Comments

alternative that does not require new road construction would still allow for 

treatment of 24,894 of the 25,815 acres in the project. 

Response 3.18: Reducing road density in the Assessment Area is not within the 

scope of the Eddy Gulch LSR Project. Alternative C eliminates 1.03 miles of 

temporary roads—this alternative was developed in response to comments received 

during collaboration meetings and the scoping process. 

Comment 3.19: Please note that page 3-116 of the DEIS states that “Mathews Creek, Shadow 

Creek, and Whites Creek are all rated as ‘at risk’ for road density, and Eddy Gulch 

is rated as ‘not properly functioning for road density (road density is 4.44 

miles/mile) . . . It is extremely troubling that all of the proposed “temporary” road 

construction is located in drainages that currently exceed 2.0 miles of road per 

square mile of forest. (draft DEIS page 3-133) . . . As stated in our scoping 

comments, rather than decrease road density as recommended in the WA and the 

LSRA, the DEIS calls for increasing the equivalent roaded area (ERA) through 

road and landing construction . . . Hence the purpose and need (and the proposed 

action) arbitrarily limited the action alternatives so as to include road and landing 

construction while precluding needed road density reductions . . . We urge the 

Forest Service to follow the findings and recommendations contained in the Was 

[watershed analyses] and the LSRA [late-successional reserve assessment] by 

avoiding new road construction and seeking to actively reduce road density in lands 

designated as LSRs and CHUs. 

Response 3.19: The Proposed Action does not add permanent roads to the 

transportation system. The proposed temporary roads were placed so that no 

adverse effects on aquatic systems would occur. Although road decommissioning 

is not part of this Proposed Action for the Eddy Gulch LSR Project, the Forest has 

an active watershed restoration program that uses information from watershed 

analyses, as well as the 2002 Salmon River Subbasin Restoration Strategy to 

implement watershed restoration throughout the Forest to meet multiple objectives, 

including fish passage, TMDL requirements, and securing Key Watersheds. That 

2002 assessment is titled “Salmon River Subbasin Restoration Strategy: Steps to 

Recovery and Conservation of Aquatic Resources”—it can be accessed at 

http://www.fs.fed.us/r5/klamath/publications/pdfs/watershed/salmonriver/Salmon_

River_subbasin_main.doc 

Some of the Forest’s watershed restoration efforts can be found on the Klamath 

National Forest public website at 

http://www.fs.fed.us/r5/klamath/projects/restoration/riparian.shtml. The Forest 

worked with the state of California to implement the Yoakumville and Summerville 

watershed restoration projects in the Salmon River drainage. The Forest held a 

public meeting at Sawyers Bar, California, on September 3, 2007, to review road 

decommissioning options in the North Fork Salmon River watershed and just 

received funds from the state of California to implement part of the North Fork 

Roads improvement project. Over the last two years, three fish passage barriers 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-13

have been removed in Whites Gulch near the Eddy Gulch LSR Project. Throughout 

the Forest, approximately 192 miles of road have been permanently 

decommissioned and removed from the National Forest Transportation Systems 

(2009 DEIS Motorized Travel Management.) 

Chapter 2 of the draft EIS, page 2-14, third bullet states: “Existing landings would 

be used.” Alternative C does not propose the 1.03 miles of temporary roads—this 

alternative was developed in response to comments received during collaboration 

meetings and the scoping process. 

Comment 3.20: It is important to note that the Klamath National Forest’s ongoing Travel 

Management Planning process states that needed road decommissioning will be 

addressed during site specific planning. The Eddy Gulch project is just such a sitespecific opportunity . . . The Forest Service cannot simultaneously refuse to 

implement Sub-part (a) of the travel rule at both the Forest and the Watershed scale. 

Response 3.20: Decommissioning opportunities will be considered and have been 

considered through other National Environmental Policy Act (NEPA) decisions. 

Consideration of decommissioning in the Salmon River watershed is as described 

in Salmon River Subbasin Restoration Strategy: Steps to Recovery and 

Conservation of Aquatic Resources. September 25, 2002, by Don Elder, Brenda 

Olson, and Alan Olson, Klamath National Forest, 1312 Fairlane Road, Yreka, 

California 96097. Jim Villeponteaux and Peter Brucker, Salmon River Restoration 

Council, P.O. Box 1089, Sawyers Bar, California 96027 available at 

http://www.fs.fed.us/r5/klamath/publications). Not every project will propose road 

decommissioning, while some projects will focus on watershed restoration, such as 

the Whites Gulch Dam Removal, Klamath National Forest Fish Passage, the 2002 

Yoakumville roads project that reconditioned and decommissioned roads in the 

Salmon River watershed, and the recent North Fork Roads Stormproofing Project. 

Approximately 192 miles of road have been permanently decommissioned and 

removed from the Klamath National Forest Transportation System (2009 Draft EIS 

for Motorized Travel Management, available at 

http://www.fs.fed.us/r5/klamath/projects/ohv/09-docs/KNF-MTM-DEIS-Chap1-

4.pdf ). 

Comment 3.21: Finally, we were very concerned to read that the project may authorize “alternate” 

road construction locations post-NEPA and post-decision. DEIS page 2-28. NEPA 

does not allow this. 

Response 3.21: The RPM referred to by the commenter has been removed. Any 

alternative road location would require ID team evaluation and a subsequent NEPA 

decision. 

Comment 3.22: The Etna Summit fuel break is not a good idea. This unit is mostly a Northwest 

facing slope down to the creek. It does not meet the intent to target southerly slopes 

with prescribed fire that has been expressed by the Forest Service. It also has three 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

B-14 Appendix B: Responses to Comments

NSO home territories. This area should be dropped as a FRZ. The Sawyers Bar 

Road should have the road-side, escape route prescription. 

Response 3.22: FRZ 20 (the “Etna Summit fuel break”) is an important FRZ 

because it supports both primary objectives (purposes) of the Eddy Gulch LSR 

Project; that is, to (1) protect existing and future late-successional habitat from 

threats of wildfire that occur in the Eddy Gulch LSR, and (2) reduce wildfire threat 

to communities and municipal water supplies and ensure public and firefighter 

safety. 

As shown on Table 2-1 in Chapter 2 of the draft EIS, the intent of FRZ 20 is to 

1. reduce hazardous fuels on steep western aspect along emergency ingress-egress 

route along county road, protect Rainbow Ranch, Taylor Hole, and Russian 

Wilderness; 

2. protect County Road 1C01 from Etna Summit to Idlewild and NFS (National 

Forest System) Roads 40N54 and 41N18; and 

3. protect Music Creek Municipal Watershed. 

The design and purpose of FRZ 20 also supports the statement found on page 2-5, 

lines 28–31 in Chapter 2 of the draft EIS: “The FRZs would provide safe locations 

for fire-suppression personnel to conduct fire-suppression actions during 90th 

percentile weather conditions, and they would serve as anchor points for additional 

landscape-level fuel treatments, such as underburning.” 

Fuel reduction treatments in FRZ 20 would serve to protect NSO activity center KL 

1047, and the fuel reduction treatments in Rx Unit 9, which is south of FRZ 20, 

would protect NSO activity center KL 1046 (refer to Table 2-5 and Map A-5b). 

Also, please note that the only thinning that would occur in FRZ 20 would be in the 

saddle to reduce stand density, but most would be an underburn. Table 2-1 

(Chapter 2 of the draft EIS) shows only 20 acres (M Unit 31) in FRZ 20 would be 

thinned, while 131 acres would be mastication, and 869 acres are proposed for 

prescribed burning. 

Comment 3.23: Please retain all large (>20” dbh) hazard trees that you fell as hazard trees. 

Response 3.23: Please refer to Section 2.5.2.3, page 2-16, and lines 7–26 on page 

2-18 in Chapter 2 of the draft EIS. This section discusses treatments along 

emergency access routes wherein the cutting and removal of trees along the 44 

miles of road within the FRZs and Prescribed Burn Units (Rx Units) will meet the 

fuel objectives for those areas. The vegetation prescriptions for the 16 miles of road 

(emergency routes) outside of the FRZs and Rx Units do not prescribe the removal 

of larger trees. Lines 11–16 describe the Roadside (RS) treatments for fuels 

reduction and safety along the 16 miles of emergency access routes. Lines 24–26 

on page 2-18 state, “All hazard trees would be identified and removed in 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-15

accordance with Klamath National Forest Hazard Tree Policy (USFS 2005). To 

maintain the canopy cover requirements listed in the Salmon River CWPP, only 

small fuels within 50 feet of the road would be removed.” 

The prescriptions do include, by reference, direction contained in the Klamath 

National Forest Hazard Tree Policy—Safety Provisions on National Forest System 

Roads, dated May 23, 2005—this Policy has been added to the final EIS as 

Appendix C. 

Comment 3.24: The FEIS/ROD should address the findings contained in Chappell and Agee, 1996, 

Fire Severity and Tree Seedling Establishments in Abies Magniffica Forests, 

Southern Cascades, Oregon. Ecological Applications, Vol. 6, No. 2 (May, 1996), 

628. A copy of this study accompanies these DEIS comments. 

Response 3.24: This topic was not addressed in the draft EIS because establishing 

conifer regeneration is not an objective of the Eddy Gulch LSR Project. The 

purpose of the stand treatments in the FRZs is to reduce fuel continuity (fuel ladder 

and crown contact). 

Comment 3.25: Please further note that the Scott and Salmon Mountains NSO Critical Habitat 

Unit 25 is designed to “maintain habitat that provides the Primary Constituent 

Elements (PCEs)” of NSO habitat. Snags, CWD and large trees are elements of the 

CHU PCEs. Removing large tree canopy will result in degradation of the habitat 

functions of the CHU and the LSR. 

Response 3.25: On page 3-74 of the draft EIS, the PCEs are considered under the 

modeled wildfire and reviewed in terms of loss of elements due to the modeled 

wildfire. Effects on PCEs were described in the draft EIS on pages 3-88 and 3-89. 

The proposed removal of snags and CWD is consistent the Klamath LRMP S&Gs 

(see response to Comment 3.3) and with the treatment objectives because it would 

effectively reduce the existing fuel loads and, at the same time, retain (through the 

S&Gs) these components at an adequate amount and distribution. Additionally, the 

M Units are located along ridgetops, a physiographic feature not often used for 

nesting by NSOs (please refer to Section 3.4.5.2 in the draft EIS and then to page 

3-64, lines 4 through 14). 

The proposed removal of snags and CWD should have minimal impacts on NSOs 

when these effects are considered at the scale of an NSO home range. Please refer 

to the effects analysis contained in Section 3.4.5 of the draft EIS. 

Regarding larger trees, the density of trees greater than 20 inches in a couple of 

M Units requires removal of some of these larger trees to meet the FRZ objectives 

in reducing crown fuels. As noted on page 3-49 (lines 12–17 and Table 3-24) of the 

draft EIS, “Treatments in the FRZs and Rx Units would shift the fire types in the 

Assessment Area from being primarily crown fires to primarily surface fires.” 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

B-16 Appendix B: Responses to Comments

This project retains as much high-quality habitat throughout home ranges as 

possible, while also considering the reduction of fuels as a major fire hazard. The 

RPMs, as well as the FWS concurrence with its determination in the Wildlife 

BA/BE, indicate that the project will maintain PCEs across the project Assessment 

Area. In summary, spotted owl critical habitat was designated based on the 

identification of large blocks of suitable habitat that are well distributed across the 

range of the NSO. Critical habitat units were intended to identify a network of 

habitats that provided the functions considered important to maintaining a stable, 

self-sustaining, and interconnected populations over the range of the NSO, with 

each CHU having a local, provincial, and a range-wide role in spotted owl 

conservation. Specifically, Subunit 35 of the Scott and Salmon Mountains CHU, 

combined with contiguous habitat in the Marble Mountain Wilderness, is expected 

to support 22 NSO pairs overtime and provide inter- and intra-provincial 

connectivity (extrapolated from 1991 the FWS’s critical habitat narrative for CA 

25) (see also the discussion under “Critical Habitat and Critical Habitat Units” on 

page 3-68 of the draft EIS and also the discussion contained in the Wildlife BA/BE 

and Wildlife and Habitat Report). While it is true that the proposed treatments may 

degrade habitat function within individual, discrete stands, these treatments are not 

expected to impact the function of CHU 25 subunit 35. For example, the M Units, 

in which the removal of large tree canopy is expected to be most prevalent, occur 

along ridgetops or the upper one-third of slopes, areas typically avoided by nesting 

and roosting NSOs and rarely used by foraging owls. Additionally, canopy cover 

retention estimates in the M Units would not result in barriers to dispersal. Thus, 

proposed treatments in the M Units are not likely to reduce the quantity or quality 

of existing NSO nesting, roosting, foraging, or dispersal habitat at the stand level to 

an extent that it would be likely to adversely affect the breeding, feeding, or 

sheltering behavior of an individual NSO. Other proposed actions (roadside 

treatments, proposed burn areas) may remove discrete components of NSO critical 

habitat (such as snags or CWD), but they are not expected to change the existing 

habitat function. 

Comment 3.26: Our organizations are very concerned by the proposal to conduct 69.5 acres of 

mechanical slashbusting mastication within riparian reserves (see DEIS 2-17). Why 

not manually treat these acres? . . . We are also perplexed by the statement on 

page 2-26 of the DEIS indicating that some trees greater than 20” dbh may be felled 

in “perennial stream channels or inner gorges.”. . . We believe that slashbusting, 

and large tree felling, within designated riparian reserves violates both the intent 

and the letter of the Aquatic Conservation Strategy. 

Response 3.26: Fuel reduction treatments within Riparian Reserves are important 

tools that are used to mimic the effects of fire through reducing ladder fuels, 

thinning over-stocked stands, and accelerating growth of trees in Riparian 

Reserves. The Klamath National Forest has previously consulted with the National 

Marine Fisheries Service on these fuel reduction methods, which can be used to 

attain Aquatic Conservation Strategy objectives, while minimizing adverse effects 

on fish and their habitat. Specifically, the Klamath National Forest has completed 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-17

Section 7 (of the Endangered Species Act) consultation on fuel reduction actions. 

This consultation included formulating specific RPMs for Riparian Reserves and 

resulted in actions (hand work, underburning, and machine mastication) that can be 

implemented without adversely affecting fish and their habitat (please refer to the 

Fisheries BA/BE). 

Comment 3.27: Future, present and the past management actions were not fully disclosed and 

analyzed in a comprehensive cumulative effects analysis. 

Response 3.27: Please see Sections 3.1.3 and 3.1.4 in Chapter 3 of the draft EIS. 

Section 3.1.4 fully discloses present and future management actions. Each resource 

section presents a cumulative effects analysis. 

Comment 3.28: “M units 21 and 24 (tractor) both currently exceed the 15% disturbance threshold.” 

-Eddy Gulch DEIS, page 3-149 . . . “Presently M units 19, 21, 24, 35 and 36 fall 

well below the 70% desired ground cover standard and would likely see further 

reductions.” Eddy Gulch DEIS, page 3-153. 

Response 3.28: From Chapter 3 (page 3-152, at line 37) of the draft EIS, “Present 

percent soil cover average for all treatment units evaluated in the Eddy Gulch LSR 

Project Assessment Area is 72 percent. Comparing this value to the 66.4 percent 

average for previously monitored units on the Klamath National Forest, one could 

reasonably expect a decrease in soil cover of at least 5.6 percent on average for the 

mechanically treated units that will also be underburned . . . Presently, M Units 19 

(cable), 21 (cable and tractor), 24 (cable), 35, and 36 fall well below the 70 percent 

desired ground cover standard and would likely see further reductions. 

Additionally, M Units 3, 4 (cable and tractor), 15 (cable and tractor), 17 (cable), 23, 

38 (cable), 52, 54, and 65 are border-line and would likely fall below the 70–80 

percent standard after treatment. For the FRZs, especially those areas that are to be 

masticated, percent ground cover would likely increase.” 

Please refer to the Soil RPMs in Section 2.9, Chapter 2 of the draft EIS. The RPMs 

are general guidelines meant to protect resources while achieving the objectives of 

the project (that is, reducing the threat of stand-replacing fire). It is common for 

RPMs to be more refined when treatment units are physically delineated on the 

ground prior to implementation. Issues such as skid trail and landing use and cable 

corridor placement are routinely refined in the field with input from various 

resource professionals. Therefore, the following RPM has been added to Chapter 2, 

Section 2.9 in the final EIS and to the Soils Report: “Coordination. During 

implementation of this project, the project leader will coordinate with personnel 

from earth science and fire/fuels regarding protection of soils and unstable areas.” 

Further, M Units 15, 17, 21, 22, 30, and 80 will be monitored for detrimental 

disturbance and/or compaction and will be subsoiled if detrimental disturbance 

exceeds 15 percent in each unit. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

B-18 Appendix B: Responses to Comments

Comment 3.29: The DEIS at page [2-]26 indicates that some skid trails may be located on slopes 

greater than 35%. Clearly this type of fudging does not allow the public or the 

decision maker to assess the cumulative impacts of the project. 

Response 3.29: There may be short sections of skid trails that could be over 

35 percent slope and that use the scarps (the steeper slope) to connect one flat 

bench to another flat bench. Please refer to the Soil RPMs in Section 2.9.4 of 

Chapter 2 of the EIS. 

The consideration of resource protection in the design of yarding systems was fully 

addressed in the draft EIS, specifically in the list of RMPs in Section 2.9. 

Comment 3.30: As acknowledged in the DEIS, roadside thinning of hazard trees is known to 

degrade NSO habitat. 

Response 3.30: All hazard trees along emergency access routes will be identified 

and removed according to the Klamath National Forest Hazard Tree Policy—Safety 

Provisions on National Forest System Roads (from page 2-7 of the draft EIS). 

Because this policy effectively limits the number and distribution of trees that can 

be removed, it is anticipated that removal of hazard trees will not change the 

function of existing habitat. 

Comment 3.31: We are extremely concerned that units M-19 and M-69 are located in NSO cores 

within the LSR and CHU. Please note these units will substantially reduce forest 

canopy within the core areas. 

Response 3.31: Please refer to Table 3-36 on page 3-84 of the draft EIS (or 

Table 4 on page 24 of the Wildlife BA/BE; also see Table 3 in the Wildlife 

BA/BE). M Unit 19 is within core area KL 1032 (refer to Table 3-37 on page 3-85 

of the draft EIS). There are zero acres of nesting/roosting habitat within M Unit 19 

and 5.7 acres of foraging habitat in that unit; however, zero acres of classified owl 

habitat will be modified. 

M-69 was eliminated from treatment (refer to Table 2.2 on page 2-11 of the draft 

EIS). 

Comment 3.32: It is essential that surveys be conducted for Pacific Fishers and that the Forest 

Service disclose the impacts of the proposed project on Fisher populations and 

habitat. 

Response 3.32: The draft EIS acknowledges the presence of potential habitat and 

evaluates impacts on fishers from Alternatives A, B, and C (refer to Chapter 3, 

pages 3-69 to 3-70, 3-79, 3-98 to 3-100, 3-106 and 3-107, ). Also refer to the 

Wildlife BA/BE, pages 56–60. 

The Klamath National Forest has independently surveyed and is working with the 

FWS to survey fisher and fisher habitat. For example, 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-19

 Camera station surveys were conducted on the Happy Camp, Scott River, 

and Salmon River Ranger Districts in the early 1990s. There has been a resurvey of areas surveyed in the 1990s in the vicinity of the Collins Baldy and 

Mt. Ashland LSRs (in conjunction with Timber Products and the FWS). 

 This is the fourth year of participating in a cooperative fisher genetic survey 

to determine preliminary population estimates for an area in northern 

Siskiyou County (in conjunction with Timber Products, California 

Department of Fish and Game, and the FWS). 

 A project to develop a habitat model is called the “Distribution and Habitat 

Suitability for Fishers in the Eastern Klamath and South Cascades Bioregions 

in Northern California Study Area.” The study area covers approximately 

9,800 square kilometers (approximately 6,089 square miles) and includes 

portions of Siskiyou, Shasta, and Trinity counties in northern California. 

Public forest lands include wilderness, late successional reserve, and general 

forest lands of the Klamath, Shasta-Trinity, and Rogue River National 

Forests. Private holdings vary from large contiguous industrial timberlands 

to checkerboard patterns and smaller private individual holdings. According 

to the FWS, the survey protocol is consistent with previous sampling and 

modeling efforts and ongoing development of landscape habitat models 

being conducted at USDA Pacific Southwest Research Station. The project 

used a robust Primary Survey Unit design associated with Forest Inventory 

and Analysis grid cells. For the project, the current model for the Klamath 

Region (Carroll et al. 2005) will be used as a launching point in development 

of a model for the eastern Klamath and southern Cascades bioregion. 

Information from previous survey efforts, which used other protocols, will be 

used to evaluate the final FWS model. Jeffrey Dunk, from Humboldt State 

University, is currently under agreement with the FWS to conduct the habitat 

modeling and analysis in cooperation with Bill Zielinski, at Pacific 

Southwest Research Station. 

 Another project, which began in October 2009 in the vicinity of the Mt. 

Ashland Fuels Reduction Project on the Klamath National Forest, is part of a 

regional study to assess changes in fisher movement patterns and habitat 

selection between pre- and post-treatment monitoring, at both individual and 

local population scales and to evaluate the short-term impact of treatments. 

According to the FWS, this study will be combined with other replicates of 

the study into a regional analysis on the impacts of treatment alternatives on 

fishers. The study will be used to generate recommendations on how 

managers can achieve fuel reduction objectives while minimizing impacts on 

fishers. 

Comment 3.33: We, therefore, believe that the existing regulatory mechanisms are not sufficient to 

protect the [Pacific fisher] DPS [distinct population segment] as a whole from 

habitat pressures.” Id. at 18792. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

B-20 Appendix B: Responses to Comments

Response 3.33: The sufficiency of existing regulatory mechanisms is outside the 

scope of this project. 

Comment 3.34: Please be advised that should this project rely on the Bush Administration’s illegal 

2007 ROD eliminating the survey and mange program that it is highly likely that 

implementation of your project will be enjoined by a federal court. We would 

prefer that the agency take the necessary survey and manage steps to ensure that 

this project is not halted by the foreseeable injunction of the Bush Administration’s 

2007 ROD. 

Response 3.34: The planning for this project began in 2007. For species formerly 

designated under the “Survey and Manage” program, an assessment of effects was 

conducted through the Forest Service Sensitive Species procedures or a separate 

evaluation, depending on the species. 

Comment 3.35: Yet disclosure of the impacts of the proposed logging of large diameter trees to 

address mistletoe infection is completely lacking. Indeed the DEIS downplays the 

structure and function provided by dwarf mistletoe. This can be contrasted with the 

analysis provided by your colleagues in the Rogue River National Forest who 

initially proposed sanitation logging in the Big Butte Springs DEIS and decided to 

drop that ill-conceived proposal . . . The DEIS does not analyze or disclose these 

habitat benefits . . . Large snags are in severe deficit in this planning area. Please 

allow for snag recruitment by maintaining large mistletoe infected trees in the 

project area. 

Response 3.35: The draft EIS does not address in detail the presence of dwarf 

mistletoe in the stands to be treated because it is not a factor to be used in selecting 

trees for removal. Trees to be retained are selected based on tree size and spacing to 

meet fire behavior objectives. In some cases selection is influenced by tree species, 

but disease factors are not considered. 

Comment 3.36: We believe that the intent of the Northwest Forest Plan, the Klamath LRMP, and 

the Healthy Forest Restoration Act, is to maintain and increase the amount of late 

successional forest habitat located within Late Successional Reserves and NSO 

Critical Habitat. Hence we are concerned by proposals to log large diameter 

overstory trees within the LSR and CHU. 

Response 3.36: The Eddy Gulch LSR Project is designed to protect and maintain 

late-successional habitat in the event of a wildfire and to mimic the effects of the 

pre-settlement/historic fire regime. The project design does not compromise the 

functionality of the LSR (please refer to Section 3.4.5 in the draft EIS and the 

Wildlife BA/BE; see also response to Comment 3.25). Please note too that the 

Klamath LRMP incorporates guidance from the Northwest Forest Plan; therefore, it 

is the Klamath LRMP that provides land management direction for the Forest. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-21

Comment 3.37: Despite the concerns noted above, we think that on balance this project is headed in 

the right direction. We want to see the effects of Forest Service fire suppression on 

tree density and seral conditions addressed. 

Response 3.37: Section 3.2 in the draft EIS and the Silviculture Report for the 

Eddy Gulch LSR Project both describe current (existing) conditions that are a result 

of past fire suppression practices. These two documents then present the effects of 

each of the three alternatives and how current conditions would be changed by each 

alternative. 

Comment Document 4—Klamath Forest Alliance and Environmental Protection 

Information Center 

Comment 4.1: The DEIS models predict that a total of 7200 acres will burn in the assessment area 

in the next 20 years, with 720 acres of active crown fire—potentially destroying 

NSO habitat. However the project proposes to treat 8,291 acres of Fuel Reduction 

Zones . . . Both outcomes have the potential to substantially affect NSO, but 

considering another alternative that more seriously weighs disturbance to the owls 

may protect these owls in one of their last refuges . . . Again, considering the 

undisputed importance of the Eddy Gulch LSR as a refuge for NSO, every effort 

should be made to maintain the highest possible quality of habitat in the NSO home 

ranges. 

Response 4.1: The draft EIS states that a 7,200-acre wildfire could occur, given 

the assumptions used in the model. The draft EIS does not state that a 7,200-acre 

fire is the only event that would occur during the next 20 years. 

The Eddy Gulch LSR Project was designed to both protect and retain as much highquality habitat throughout home ranges as possible, while also considering the 

reduction of fuels as the major fire hazard and threat to the Eddy Gulch LSR and 

the consequences of a stand-replacing fire. The identification and design of 

treatment units and proposed treatment methods occurred over months of field 

visits, interdisciplinary team meetings, and collaboration with the FWS. During that 

time, some preliminary treatment units were dropped from the Proposed Action, 

and some treatment unit boundaries were modified to ensure that adequate habitat 

within home ranges and activity centers would be maintained. 

The silviculture prescriptions and fuel reduction treatments designed for the project 

focus on protecting and retaining primary constituent elements (PCEs) at the stand 

scale. For nesting and roosting habitat, the primary constituent elements include 

large (greater than 30 inches dbh) trees in stands with 60–90 percent canopy cover, 

multistoried canopy that allow birds to fly under the canopy, and with abundant 

large snags and CWD. In foraging habitat, tree height diversity, canopy closure, 

snag volume, and density of snags are important. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

B-22 Appendix B: Responses to Comments

In addition, the FWS-approved RPMs, as well as the FWS concurrence with the 

determinations in the Wildlife BA/BE, demonstrate that PCEs will be maintained 

across the project Assessment Area. 

From the draft EIS, page 3-66: “The FWS (Johnson et al. 2006) also used a 

landscape-level analysis to examine eight abiotic factors to help distinguish 

36 activity centers from unused sites in three Klamath National Forest LSRs. The 

FWS found that activity centers were associated with basin-like topography, the 

lower half of slopes, and streams. Additionally, numerous published articles have 

demonstrated that NSOs prefer use of lower-slope or mid-slope sites for foraging, 

roosting, and nesting, especially as sites are related to drainages or surface water 

(see Solis and Gutiérrez 1990; Blakesley et al. 1992; and Lahaye and Gutiérrez 

1999). As might be expected, these abiotic habitat selection features coincide with 

conditions that favor forest growth and historically were relatively resistant to fire. 

Most of the activity centers in the Assessment Area are located in areas with similar 

topographic characteristics; that is, core areas are found no higher than mid-slope 

and are typically centered on prominent drainages.” 

From page 3-82 of the draft EIS: “Treatments in M Units would have little effect 

on individual NSO or their Critical Habitat because 

 the M Units are along ridges, and the physiographic features associated 

with most of the M Units indicate a low probability of use by foraging or 

nesting/roosting individuals; 

 the M Units avoid all but one NSO core area, part of which occurs along a 

ridgeline; and 

 all NSO home ranges in which M Units occur will retain habitat sufficient 

to support NSOs following treatment.” 

Please refer to the NSO effects analysis in Section 3.4.3.2 of the draft EIS and the 

NSO discussions in the Wildlife BA/BE. 

Comment 4.2: We have several concerns with the adequacy of the Resource Protection Measures 

discussed on pages 10 and 11 of the BE/BA . . . 1) The first measure prohibits 

activity occurring [occurring] from February 1st to September 15 within an active 

NSO 70-acre nest core. Have all the nest cores been located for all the active 

activity centers? The Forest should expand this first measure to prohibit activities 

within the NSO core area in addition to the nest area for these dates in order to 

protect any unknown nesting locations. 

Response 4.2: Please refer to Section 2.9.1 (in Chapter 2 of the draft EIS) for all 

RPMs for the NSO. All nest cores have been located for known activity centers, 

and all RPMs for the NSO span biologically significant time frame and distance. 

Surveys will continue throughout the life of the project; therefore, NSO nest cores 

will be known and protected within the project Assessment Area. The surveys 

cover existing suitable habitat, not just historic nest sites, so all active nest sites 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-23

within or adjacent to proposed actions will be identified prior to the implementation 

of the treatments. 

Comment 4.3: No NSO habitat should be removed or downgraded at anytime. 

Response 4.3: Thinning in the M Units in FRZs and construction of temporary 

roads will not remove or downgrade nesting/roosting or foraging habitat from the 

estimated core area (0.5-mile-radius circle around an activity center) of any NSO 

activity centers. However, thinning in FRZs would downgrade approximately 36 

acres of nesting/roosting habitat to foraging habitat in the estimated home range 

(1.3-mile-radius circle around an activity center) of six activity centers (KL1028, 

KL1031, KL1033, KL1034, KL1035, and KL4026). Despite these reductions, 

nesting/roosting habitat within these home ranges would remain abundant. 

Additionally, these acres are situated on the upper one-third of slopes—a topographic 

feature typically avoided by nesting NSOs (Blakesley et al. 1992; LaHaye and 

Gutiérrez 1999; Folliard et al. 2000). Construction of temporary roads would remove 

nesting/roosting or foraging habitat from five NSO home ranges. Because the 

habitat to be removed (a total of 0.62 acre) occurs on the outer edges of these 

estimated home ranges and is distributed across five discrete road segments, effects 

are insignificant at the scale of an NSO home range. Therefore, the proposed 

treatments would not result in significant impacts on nesting, roosting, or foraging 

opportunities for NSOs in the project Assessment Area. For the full discussion of 

project effects on NSOs, please refer to Section 3.4.5.2 in the draft EIS, particularly 

pages 3-82 through 3-86 and Tables 3-36 and 3-37. This same information is in the 

Wildlife BA/BE and the Wildlife and Habitat Report. 

Comment 4.4: There should be no new roads constructed in the LSR. 

Response 4.4: All new roads required for treatment are temporary and will not 

remain open after the treatments are completed. Alternative C (No New Temporary 

Roads Constructed) responds to public comments received during collaboration 

meetings and the scoping process. 

Comment 4.5: Studies have shown significantly higher stress levels were found in male NSOs 

centered on logging roads as compared to owls beyond 0.41 km from a logging 

road. The costs to the owls of disturbance such as this include energetic demands of 

avoidance flight and time lost that would be allocated to other activities, as well as 

increased heat production and heat-related stress due to avoidance flight. If an owl 

flushes the site due to disturbance, it may also be exposed to predation of diurnal 

predators. Roads affect not just owls, but dozens of other wildlife species in many 

different ways, including habitat fragmentation, collision with vehicles, increased 

human disturbance, etc. The costs of building the 1.03 miles of new temporary 

roads far outweigh the meager benefits to treat a relatively small amount of area for 

fire prevention. 

Response 4.5: Please refer to the location of the proposed temporary roads on 

Maps A-4a and A-4b in Appendix A of the EIS. The 1.03 miles of proposed 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

B-24 Appendix B: Responses to Comments

temporary roads are found along ridgetops (where NSOs do not typically occur) 

and are thus greater than 0.41 km (0.25 mile) from any activity center. The 

temporary roads are not intended to be opened permanently but only for the 

treatments required for the project. 

Wasser et al. 1997 did detect higher fecal corticosterone (a 21 carbon steroid 

hormone of the corticosteroid type produced in the cortex of the adrenal glands) 

levels in male NSOs that were centered within 0.41 km (0.25 mile) of a major 

logging road versus males that were centered at greater distances from the same 

logging road. For the Eddy Gulch LSR Project, all proposed temporary spur roads 

are greater than 0.5 mile from any historical activity centers. Additionally, because 

all proposed temporary spur roads will be closed after thinning operations, and they 

occur along prominent ridges, it is highly unlikely that new activity centers will be 

established adjacent to these roads during the time in which they are open. 

The effects from implementation of Alternative C (No new Temporary Roads 

Constructed) are analyzed for each resource topic in the draft EIS. In particular, 

please refer to the effects analysis for Alternative C in Section 3.3.5.3 of the Fire, 

Fuels, and Air Quality (Section 3.3) in the draft EIS and the effects from 

Alternative C (Section 3.4.5.3) in the Wildlife and Habitat section of the draft EIS. 

This information can also be found in the Fuels Report and the Wildlife BA/BE and 

Wildlife and Habitat Report 

Comment 4.6: Finally, we fully support re-introducing fire back into the landscape, and support 

the effort to burn in a mosaic like pattern as discussed in the BA/BE (pg 27). We 

agree a heterogeneous landscape will provide cover for various wildlife species as 

well as food for NSO prey species. The prescription burning units should explicitly 

describe how this mosaic pattern will be created, and what the finally outcome 

should resemble. 

Response 4.6: Please refer to Chapter 2, “Section 2.5.2.1 Fuel Reduction Zones” 

and “Section 2.5.2.2 Rx Units.” Both sections describe how the prescribed burns 

would be implemented and the targeted vegetative components. Additional 

descriptions are provided on pages 3-46 and 3-47 and Table 3-23 in the draft EIS. 

Comment 4.7: We disagree that the prescription burning will create many new snags suitable for 

NSO use (BA/BE pg.27). Most prescription burning is cool enough to kill only 

small understory trees and NSO utilize large diameter snags. We believe it is 

feasible that the Forest add an additional mitigation measure to design fire 

treatments to maintain as many large (greater than 21 dbh) snags as possible. This 

could be accomplished by directing fire in a way to avoid these snags, or by raking 

flammable fuels away from the base of them. 

Response 4.7: For effects from Alternative B (Proposed Action), page 3-46 in the 

draft EIS currently states: “Scorching could also result in post-treatment mortality 

in residual trees greater than 20 inches dbh (Stephens and Moghaddas 2005), which 

would provide future snags and coarse woody debris (CWD).” 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-25

That statement on page 3-46 has been edited in the final EIS to read: In the study 

conducted by Stephens and Moghaddas (2005a), prescribed burning was effective 

in reducing tree density in trees 1 inch–10 inches dbh, but further states that 

prescribed fire treatment did not substantially remove dominant or co-dominant 

trees because fire behavior was not severe enough to kill many trees over 11 inches 

dbh. It is important to note that indirect mortality from increased insect activity, 

periods of drought, and pathogens may increase mortality in larger trees in 

prescribed fire and mechanical treatments followed by fire treatments. Thus, there 

is the potential that (depending on different site characteristics) scorching could 

result in post-treatment mortality in residual trees greater than 20 inches dbh, which 

would provide future snags and CWD (Stephens and Moghaddas 2005a). However, 

large trees and snags are typically not lost during prescribed fire. The burn plan 

(developed prior to implementing any treatments for the Eddy Gulch LSR Project) 

will design a prescribed fire that consumes smaller-diameter trees. 

The effects of prescribed burns in Rx Units, as described in the “Wildlife and 

Habitat section of Chapter 3 (Section 3.4), page 3-87 has been edited in the final 

EIS to read: Treatments could potentially consume existing snags but may also 

create new snags. Typically, large trees and snags are not lost during prescribed 

fire. The burn plan (developed prior to implementing any treatments for the Eddy 

Gulch LSR Project) will design a prescribed fire that consumes smaller-diameter 

trees. Prescribed fire would consume most of the smaller down woody debris and 

some of the CWD, but much of the CWD would likely remain when burning in 

spring prescriptions. A study by Stephens and Moghaddas (2005b) noted that the 

reduction in volume of existing snags and CWD following prescribed fire 

treatments depended on both tree diameter and decay class (decay classes 1–3 for 

snags and CWD denote sound structural integrity of the heartwood, wherein decay 

class 4 denotes rotten heartwood and decay class 5 denotes no structural integrity). 

For example, total sound CWD (decay classes 1 and 2) was not significantly 

reduced by treatments. The most dramatic change of CWD in this study was the 

reduction of rotten CWD, especially in decay class 4, as a result of prescribed fire 

treatments. 

Comment 4.8: Our organizations believe that the Klamath National Forest Land Managers should 

follow the Salmon River CWPP that calls for 70-100% canopy. Decreasing canopy 

as is proposed may cause an increased fuels risk and eliminate habitat for fishers. 

Response 4.8: The Salmon River Community Wildfire Protection Plan (CWPP) 

recommendations were used for roads outside the FRZs, and the forestwide LSR 

assessment recommendations were used for treatments inside the FRZs. 

The Salmon River CWPP recommendations for canopy cover were considered 

during development of the action alternatives, and the rationale for treatments is 

explained in Chapter 2 of the draft EIS. The majority of treatments would only 

affect small trees (less than 10 inches dbh) and would have little, if any, effect on 

canopy cover. Some larger trees may be removed; however, selection of those trees 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

B-26 Appendix B: Responses to Comments

is consistent with approved guidelines. Thus, these treatments would have little or 

no effect on fisher habitat (please refer to response to Comment 3.32). Fisher 

habitat is typically characterized as mature, structurally diverse, closed canopy 

stands. However, fisher will occupy managed or burned stands if remnant 

structures are maintained (Jones 1991; Yaeger 2005). While thinning may 

significantly reduce canopy cover in some of the structurally complex stands, other 

structurally complex stands will retain canopies of 50 percent or more. 

Additionally, all of the structurally complex stands will retain basal areas in the 

range of 130-230 square feet per acre and a large tree component. Therefore, 

impacts to fisher habitat are not expected to be significant. Finally, some of the 

mature and mid-mature stands in the FRZs are to be treated by underburn only, and 

thus are not expected to have their canopy cover reduced. These areas should 

provide habitat connectivity for fisher between the sub basins within the project 

area. 

Comment 4.9: The Etna Summit fuel break is mostly all Northwest facing. It does not meet the 

intent to target southerly slopes with prescribed fire. It also has three NSO home 

territories. In our opinion: this area should be dropped as a FRZ. The Sawyers Bar 

Rd should have the road side, escape route prescription. 

Response 4.9: See response to Comment 3.22.

Comment 4.10: There are three units, which the geologists have identified as having “indications of 

elevated landslide potential.” These are M23, M61 and M73 . . . We would suggest 

looking at these units on the ground and likely get them to reconfigure away from 

unstable features. 

Response 4.10: These units were indeed examined in the field, which lead to their 

identification. The risk of project actions destabilizing these areas is minimal and 

warrants no further analysis. The indicators found in these units are mostly based 

hillslope form and are not in the unstable land component of Riparian Reserves. In 

each instance, indicators of past slope movement suggest that the events are at least 

“hundreds” of years old. This is especially true of M Units 23 and 73. For M Unit 

61, the RPMs (Section 2.9 in Chapter 2 of the draft EIS) are based on reviews with 

the earth science staff during unit layout. Conservative thinning guidelines are also 

recommended to retain sufficient rooting density of large vigorous trees (thinning 

will target less vigorous, more crowded trees in the stand). 

Comment 4.11: In addition to the temporary roads, we are concerned about all the roads they are 

reopening and all the landings. How many of these landings exist now and how 

many are new? How does creating new landings in LSRs maintain or restore old 

growth characteristics? What is the risk of the roads they propose to reopen? If the 

proposed roads and landings cross/are located on earthflow terrain they should not 

be constructed or reopened because of the landslide/sediment delivery risk. 

Response 4.11: Other than the 1.03 miles of proposed temporary roads, 0.98 mile 

of former logging access routes would be reopened to treat specific units. No new 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-27

landings are proposed (see page 2-14 in the draft EIS). The issue of temporary 

roads was the basis for developing Alternative C (No New Temporary Roads 

Constructed). The issue has been thoroughly analyzed, and all relevant facts are 

presented in the draft EIS and relevant resource reports. All temporary road 

alignments (both new and reopened former logging access routes) were examined 

in the field. All roads in question are on ridgetops or in near-ridge locations and far 

from streams or any mapped Riparian Reserve. The draft EIS makes it clear that 

none of the new roads or reopened former logging access routes cross unstable 

terrain or Riparian Reserves. Please note the following text from page 3-161 of the 

draft EIS: 

Construction of New Temporary Roads / Closure—1.03 miles. The 

new temporary roads would be closed upon project completion. There 

would be a reduction in root support and local evapotranspiration 

associated with clearing. Road segments are short, cross no major 

drainages or wet areas, and are generally located near ridgetops. All new 

temporary road alignments were inspected for landslide potential in the 

field and landslide potential evaluated. 

Use of Former Logging Access Routes / Closure—0.98 mile. Former 

logging access routes in varying states of revegetation would be reused. 

There would be a reduction in root support and local evapotranspiration, 

particularly where older vegetation is removed. All of these routes were 

inspected for landslide potential in the field and landslide potential 

evaluated. Potential for road-related landsliding is considered to be very 

low. Closure following use would eliminate any pre-existing drainage 

problems and remove fill placed in draws, thereby restoring hydrologic 

conditions and reducing landslide risk. 

Please note that logs will be skidded to existing landings (which will be bladed and 

cleared of brush) or “hot-decked” along roads. Basically, hot decking occurs when 

the running surface of the road is not wide enough for both the cable yarder and the 

logs. The logs have to be moved out of the way so another load can be brought to 

the road, where trucks haul them away—this eliminates the need for landing 

construction because the road prism itself serves as the landing. The use of existing 

landings will be subject to current best management practices for erosion control 

(refer to Section 2.9 in the EIS). 

Comment 4.12: During the travel management planning process we have repeatedly been told by 

the Supervisor’s Office that the Forest Service will identify the “minimum road 

system.” 

Response 4.12: This project does not analyze the impacts of the current 

transportation system. That analysis and decisions on closing and decommissioning 

existing roads are outside the scope of the Eddy Gulch LSR Project. The Pacific 

Southwest Regional Forester has committed to begin addressing Subpart A of the 

Travel Management Rule within the next 18 months; that process will provide 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

B-28 Appendix B: Responses to Comments

information needed to identify the minimum road system required for management 

of the Klamath National Forest. 

For additional information, please visit 

http://www.fs.fed.us/r5/klamath/projects/ohv/index.shtml. 

Comment 4.13: We would like to express our interest in collaborating with the District and other 

interested parties in effectiveness monitoring and restoration for the Eddy LSR 

project. 

Response 4.13: The Klamath National Forest is currently coordinating with the 

California Regional Water Quality Control Board regarding water quality 

monitoring. Your interest in collaborating with other monitoring efforts is noted. 

Comment Document 5— Patricia Sanderson Port, Regional Environmental Officer, 

Office of Environmental Policy and Compliance. U.S. Department of the Interior, 

Region IX 

Comment 5.1: The Department of the Interior has received and reviewed the subject document and 

has no comments to offer. 

Response 5.1: Thank you for your letter. 

Comment Document 6—Kathleen M. Goforth, Manager, Environmental Review 

Office, United States Environmental Protection Agency, Region IX 

Comment 6.1: EPA acknowledges the importance of project goals to improve forest health, reduce 

fuel loading, and protect communities and watersheds from wildfire threats. We 

support the best management practices described in the DEIS, such as minimizing 

new road construction and decommissioning roads after project activities have taken 

place to help reduce adverse environmental effects. 

Response 6.1: Thank you for your input. 

Comment 6.2: We have rated the DEIS as Environmental Concerns – Insufficient Information 

(EC-2) (see enclosed “Summary of Rating Definitions”). We recommend that the Final 

Environmental Impact Statement (FEIS) provide additional information concerning 

a smoke management plan, worker exposure to naturally occurring asbestos, the 

wildland-urban interface (WUI), and noxious weeds. Please see the enclosed 

Detailed Comments for a description of these concerns and our recommendations. 

Response 6.2: See responses to Comments 6.3, 6.4, 6.5, and 6.6. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-29

Comment 6.3: Air Quality

Provide a detailed smoke management plan describing the Siskiyou County 

Air Pollution Control District (SCAPCD) Smoke Management Program. The 

U.S. Environmental Protection Agency (EPA) acknowledges the need to reduce 

fuel, which may lead to a reduction of emissions from wildfires. Emissions from 

wildfires can be a major contributor of PM10, PM25, and CO (page 3-54, lines 5-6). 

The DEIS states that the Forest Service would coordinate with the appropriate air 

quality regulatory agencies during the planning and implementation of its resource 

management activities that affect air quality (page 1-21, lines 7-16). 

Recommendation: 

The FEIS should include a detailed smoke management plan describing the 

SCAPCD's regulations for pile burning and smoke management, an implementation 

schedule, the responsible parties, and monitoring and reporting requirements. 

Response 6.3: Burning will comply with the policy and regulations of the 

Siskiyou County Air Pollution Control District and Northeast Plateau Air Basin. 

Burn plans, which include smoke management plans, will be written and submitted 

to the County Air Pollution Control District for their approval prior to 

implementation of prescribed burn treatments. The draft EIS states on pages 1-21, 

under “Section 1.10 Permits, Licenses, and Other Consultation Requirements,” that 

“Smoke permits are required from the Siskiyou County Air Pollution Control 

District.” Also refer to the RPM (“Section 2.9.8 Air Quality” on page 2-31 of the 

draft EIS), which states, “Burn plans will identify and comply with policies and 

regulations of the Siskiyou County Air Pollution Control District and Northeast 

Plateau Air Basin.” This statement has been edited as follows: “Burn plans, which 

include smoke management plans, will be written prior to implementation of 

prescribe burn treatments. The burn plans will identify and comply with policies 

and regulations of the Siskiyou County Air Pollution Control District and Northeast 

Plateau Air Basin.” 

Please note that page 3-55 in Section 3.3 (Subsection 3.3.8.2) of the draft EIS 

states, “Effects from project implementation would be short term, and use of RPMs 

would reduce those effects. The California Air Resources Board has promulgated 

changes to Title 17 Smoke Management Guidelines for Agricultural Burning and 

Prescribed Fires. The new regulations require submission of smoke management 

plans to the local air district for each burn plan and require permitting and increased 

coordination between burners and the local air district. The Forest Service, 

Region 5 has also signed a Memorandum of Understanding on Prescribed Burning 

on July 13, 1999, with the California Air Resources Board.” This statement will be 

clarified in the final EIS by inserting the statement, “prior to on-the-ground 

implementation of burning” preceding the word “submission.” 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

B-30 Appendix B: Responses to Comments

Comment 6.4: Naturally Occurring Asbestos

Limit exposure to Naturally Occurring Asbestos. The DEIS states that asbestos can be 

introduced into the air by activities that include road construction, reconstruction, 

or maintenance on roads underlain by ultramafic rock (3-159, lines 5-6). The DEIS 

also states that ultramafic rock is concentrated in the southwest corner of the 

Assessment Area, and acknowledges the presence of serpentine geology in the 

project area (page 3-159, lines 7-9). Although serpentine soils may be limited, it is 

important to protect human health by limiting the exposure of workers to serpentine 

soils that may introduce airborne asbestos during vegetation management activities. 

Very low levels of asbestos in soil can generate airborne asbestos at hazardous levels. 

We are concerned about the potential exposure of workers to naturally occurring 

asbestos. 

Recommendations: 

EPA recommends that the Forest Service determine whether or not naturally 

occurring asbestos is present in treatment units or along project access routes. If 

naturally occurring asbestos is found to be present, the FEIS should provide 

information on exposure mechanisms and assess the potential for exposure to 

elevated levels of airborne asbestos from proposed activities. 

EPA recommends that the Forest Service review the asbestos occurrence 

information on the California Geological Survey website: 

http://www.consrv.ca.gov/cgs/minerals/hazardous minerals/asbestos/index.htm and 

the California Air Resources Board (CARB) regulations and guidance at: 

http://www.arb.ca.gov/toxics/asbestos/asbestos.htm. The CARB website 

addresses California's Asbestos Airborne Toxic Control Measures for Surfacing 

Applications, which apply to unpaved roads. EPA also recommends that the Forest 

Service review the recommendations presented in the Department of Toxic 

Substances Control report, “Study of Airborne Asbestos from a Serpentine Road in 

Garden Valley, California” at 

http://www.dtsc.ca.goviloader.cfm?url=

kommonspotisecurity/getfile.tfm&pageid 

=33546. 

The FEIS should identify and include commitments for measures that can be 

implemented to protect human health from naturally occurring asbestos, if 

appropriate, and include this discussion in the FEIS. 

Response 6.4: Timber harvest activities are specifically exempted from asbestos 

survey requirements under CARB – Final Regulation Order 2002-07-29 Asbestos 

ACTM for Construction, Grading, Quarrying, and Surface Mining, Section 

93105(c)(3). The Klamath National Forest inventoried road segments for naturally 

occurring asbestos (NOA) during spring 2009 (Bell 2009; the report has been 

inserted as “Appendix I” to Geology Report), and in most cases, the levels of NOA 

were below guidelines published by the California Air Resources Board. Although 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-31

detectable levels of NOA were obtained, the project avoids or minimizes impacts 

on worker safety because of the following: 

 No road construction of any type is proposed in areas underlain by ultramafic 

rocks. 

 No quarrying or road surfacing is proposed anywhere in the project. 

 No M Unit occurs on ultramafic bedrock. Therefore, dust from skidding or 

yarding of logs poses no airborne asbestos hazard. 

 The Rx Units will be treated with prescribed fire only and present no 

significant hazard. The FRZs will be treated with a mix of prescribed fire and 

mechanical mastication. In the case of FRZ 10, most of the ultramafic rock 

occurs outside of (but adjacent to) the area where mastication treatment is 

anticipated. The largest area proposed for mastication on ultramafics is in 

FRZ 2, where 125 acres fit that description. In those areas where ultramafic 

rock and mastication occur, an RPM has been added to Chapter 2 (Section 

2.9.5) stating the operators will receive a map clearly identifying those 

locations, a description of the health hazards, and a recommendation that 

masticators have positive-pressure climate-controlled cabs (see next bullet). 

 Section 1.9 of the Geology Report for the Eddy Gulch LSR Project contains 

an RPM for asbestos. That RPM has been edited in the Geology Report and 

has also been added to Section 2.9.5 of the final EIS as follows: 

Asbestos. The Forest Service will provide a description of health 

hazards from asbestos exposure and maps to contractors 

identifying areas that may have asbestos and suggest they may 

consider sealed cabs on their equipment. If timber haul routes 

change during project implementation, any additional roads 

would be checked against the bedrock map to determine if they 

are underlain by ultramafic rock, and the asbestos standards 

applied. Dust abatement is required on all roads underlain by 

ultramafic rocks, and it is recommended that masticators have 

positive-pressure climate-controlled sealed cabs. 

 Portions of the following fuel reduction units do contain areas of ultramafic 

rock: 

– Rx Unit 1 and FRZ 2 in the Upper Black Bear Creek watershed 

– Rx Unit 3 in the Matthews Creek watershed 

– Rx Unit 4 and FRZ 10 in lower Crawford Creek watershed 

The report cited by the commenter (Study of Airborne Asbestos from a Serpentine 

Road in Garden Valley, California) was reviewed. This study pertained to roads 

surfaced with serpentinite with substantial NOA—this action will not occur in the 

Eddy Gulch LSR Project Assessment Area.
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

B-32 Appendix B: Responses to Comments

Comment 6.5: Wildland-Urban Interface 

Describe how the Community Wildfire Protection Plan relates to the proposed 

project. A main component of the purpose and need for this project is to provide 

fire protection for the wildland-urban interface (WIJI) (page 1-11, lines 18-19). The 

Healthy Forest Restoration Act (HFRA) encourages the development of Community 

Wildfire Protection Plans (CWPPs) under which communities designate their 

WUIs and the locations where fuel reduction projects may take place. A 

summary of the Salmon River CWPP is provided in the DEIS (page 2-4, line 31 

through page 2-5, line 10). 

Recommendations: 

The FEIS should further describe actions that will be taken by the Forest Service 

and the communities to ensure fire protection efforts are consistent, 

complementary, and fully integrated with the preferred alternative. For instance, 

describe whether local building and fire safety ordinances are consistent with the 

effort to reduce and minimize excessive fuels. 

Response 6.5: The Forest Service only has jurisdiction on National Forest System 

lands. This project was developed in collaboration with the Salmon River Fire Safe 

Council and include recommendations from their CWPP. The local building and 

fire safety ordinances deal with private lands, and the state of California 

(CALFIRE) has jurisdiction. 

Comment 6.6: The Forest Service identifies several noxious weed resource protection measures 

(RPMs) for each treatment activity. For example, if noxious weeds were found in 

the area during prescribed burn treatments, there would be an omission of 

prescribed burn treatments and fireline construction within weed populations, 

cleaning of all equipment before entering treatment units, post-treatment surveys, 

site-specific surveys, and monitoring of noxious weed sites to ensure that natural 

vegetation has recovered from the disturbance (page 3-211, lines 29-33). While 

these measures are commendable, the DEIS does not specifically state what 

measures the Forest Service would take to manage or eradicate noxious weeds if 

they were found at the project sites. 

Response 6.6: The measures the Klamath National Forest would take to manage 

or eradicate noxious weeds would be patterned after the measures currently being 

taken in the Salmon River watershed; that is, nonchemical methods, predominantly 

hand digging. Currently, the Salmon River Restoration Council provides most of 

the weed control efforts, in partnership with the Forest Service, as volunteers and 

recipients of grant funding. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-33

Comment Document 7—Williams, Thomas Engineering Geologist, Northern Timber 

Unit, California Regional Water Quality Control Board, North Coast Region 

Comment 7.1: All forest projects must comply with all substantive and procedural requirements of 

the Porter-Cologne Act and the Basin Plan. Additionally, the Project must comply 

with the RWB's Categorical Waiver For Discharges Related to Timber Harvest 

Activities On Federal Lands Managed by the United States Department of 

Agriculture, Forest Service in the North Coast Region, Order No. R1-2004-0015 

(Waiver). 

Response 7.1: The proposed project meets all conditions and eligibility 

requirements of the Categorical Waiver. Prior to commencement of timber harvest 

activities, the Forest Service shall, in writing, file with the Regional Board a Notice 

of Intent, in which the USFS certifies they understand and intend to comply with all 

criteria and conditions of the Order and applicable water quality regulations. The 

Notice of Intent shall be signed by the Forest Supervisor or their duly authorized 

USFS representative. 

Comment 7.2: RWB Order No. R1-2004-0015 item C.3 specifies, “The USFS shall submit and 

comply with a monitoring program prior to commencement of timber harvest 

activities when: (1) the USFS’s cumulative watershed effects analysis indicates that 

the Project may cause any watershed or sub-watershed to exceed a threshold of 

concern as determined by various models (i.e., Equivalent Roaded Acres (ERA), 

Surface Erosion (USLE), Mass Wasting (GEO), etc.); or (2) the cumulative 

watershed effects analysis indicates that the Project may increase risk values, as 

determined by various models (Equivalent Roaded Acres (ERA), Surface Erosion 

(USLE), Mass Wasting (GEO), etc.), in any watershed or subwatershed that already 

exceeds a threshold of concern prior to project implementation.” 

The Cumulative Watershed Effects (CWE) modeling done for the Eddy Gulch LSR 

Project and detailed in the Aquatic Resources Report indicates that Eddy Gulch, 

Kanaka-Olsen, and Indian 7th Field Watersheds are over the threshold of concern 

(TOC) of 1.0. The Eddy Gulch 7th Field Watershed had a value of 1.05 for the 

USLE model. The Kanaka-Olsen 7th Field Watershed had a value of 1.53 for the 

GEO model. The Indian 7th Field Watershed had a value of 1.04 for the ERA 

model. In accordance with RWB Order No. R1-2004-0015, a water quality 

monitoring program is required to be approved for this project by the RWB prior to 

commencement of timber harvest activities. 

Response 7.2: Section C.3 of the categorical waiver does not apply because this 

project would not cause a watershed to exceed the threshold of concern, nor would 

it increase the risk value of a watershed currently over the threshold. The CWE 

model values quoted from the Hydrologists report are for the current condition 

(2008) and do not include the effects of future actions. When the effects of the 

North Fork Roads storm proofing project are included in the model, Eddy Gulch 

has a modeled risk of 0.90 and is not over the threshold of concern. The KanakaOlsen and Indian Creek watersheds are over the threshold of concern, but the risk 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project

B-34 Appendix B: Responses to Comments

ratios are decreasing and would fall below the threshold of concern by the time the 

project is fully implemented in 2014 (see Table 3.41 of the final EIS ). 

Comment 7.3: Basin Plan, Page 4-62.00, “The Regional Water Board encourages parties 

responsible for vegetation that provides shade to a water body in the Scott River 

watershed to preserve and restore such vegetation. This may include planting 

riparian trees, minimizing the removal of vegetation that provides shade to a water 

body, and minimizing activities that might suppress the growth of new or existing 

vegetation.” To ensure compliance with the Basin Plan temperature objective and 

the temperature TMDL, the Project should be implemented in a manner that does 

not reduce shading of any streams. 

Response 7.3: The “Aquatic Resources” section in the draft EIS (Section 3.5.4.2), 

the Aquatic Resources Report (Section 1.8.2), and the Fisheries BA/BE (Section V 

[Existing Environment and Effects on Anadromous Fish and Their Habitat 

Indicators]) prepared for this project provide analyses of potential effects on stream 

shade and water temperature. The analyses conclude that there would be no 

effects—this determination is based on (1) the proposed project design, and (2) the 

RPMs that were developed to minimize or avoid adverse effects that could result 

from project implementation. 

Comment 7.4: The potential impact on stream temperature was judged to be very small in the 

DEIS because the mechanical thinning units and the proposed temporary roads are 

not within Riparian Reserves and are located on or near ridgetops. The proposed 

temporary roads would not cross any streams or other Riparian Reserves and are 

dispersed in a number of short segments across several watershed areas. The 

temporary roads would be closed, ripped, and re-contoured after use. The greatest 

potential for adverse stream temperature effects would be related to flare-ups 

associated with prescribed fire within Riparian Reserves. Flare-ups could remove 

canopy and create openings adjacent to streams. Such events are expected to be few 

in number and limited in size by the fact that burn plans will consider retention of 

cover in these areas in conformance with Klamath LRMP guidance. 

Response 7.4: The “Aquatic Resources” section in the draft EIS (Section 3.5.4.2), 

the Aquatic Resources Report (Section 1.8.2), and the Fisheries BA/BE (Section V 

[Existing Environment and Effects on Anadromous Fish and Their Habitat 

Indicators]) prepared for this project provide analyses of potential effects on the 

Stream Temperature Indicator. The analyses conclude that there would be no 

effects on this habitat Indicator—this determination is based on (1) the proposed 

project design, (2) RPMs that were developed to minimize or avoid adverse effects 

that could result from project implementation, and (3) on the assumption that 

underburns will be conducted in accordance with burn plans and protocols to 

minimize escapes and flare ups. Worst-case scenarios are not assumed or analyzed. 

Burn plans contain measures that minimize the potential for flare ups. 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-35

Comment 7.5: Please describe in the Final EIS how the sediment objectives for the Scott River 

TMDL [Total Maximum Daily Load] described above will be achieved for this 

Project. 

Response 7.5: The sediment objectives of the Scott River TMDL will be met by 

implementing the TMDL Action Plan and the Memorandum of Understanding 

(MOU) between the Forest Service and the Regional Water Board. The MOU 

describes 13 specific implementation actions that the Forest Service is taking to 

achieve the TMDLs and meet sediment and temperature water quality standards on 

National Forest System lands. In accordance with section C.5 of the MOU, the 

project will prevent or minimize road-caused sediment by implementing the Best 

Management Practices, LRMP Standards and Guidelines, and the RPMs presented 

in Section 2.9 (chapter 2) of the draft and final EISs. 
Section B.3: Comment Documents 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-39
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-40 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-41
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-42 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-43
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-44 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-45
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-46 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-47
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-48 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-49
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-50 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-51
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-52 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-53
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-54 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-55
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-56 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-57
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-58 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-59
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-60 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-61
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-62 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-63
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-64 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-65
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-66 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-67
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-68 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-69

Attachment 2 Comment Document #3 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-70 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-71
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-72 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-73
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-74 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-75
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-76 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-77
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-78 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-79
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-80 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-81
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-82 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-83
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-84 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-85
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-86 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-87
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-88 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-89
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-90 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-91
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-92 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-93
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-94 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-95
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-96 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-97
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-98 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-99
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-100 Appendix B: Responses to Comments
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-101

7.1 

7.2 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

B-102 Appendix B: Responses to Comments

7.3 

7.4 

7.5 
Final Environmental Impact Statement 

Eddy Gulch LSR Project Klamath National Forest

Appendix B: Responses to Comments B-103
Appendix C 

Klamath National Forest 

Klamath National Forest Hazard Tree Policy 

Safety Provisions On National Forest System Roads
KLAMATH SUPPLEMENT 7700-2005-1 

EFFECTIVE DATE: 05/23/2005 

DURATION: This supplement is effective until superseded or removed. 

7730 

Page 1 of 11 

FSM 7700 – TRANSPORTATION SYSTEM 

CHAPTER 7730 – OPERATION AND MAINTENANCE 

Appendix C: Hazard Tree Policy and Safety Provisions C-1

FOREST SERVICE MANUAL 

KLAMATH NATIONAL FOREST 

YREKA, CA

FSM 7700 – TRANSPORTATION SYSTEM 

CHAPTER 7730 – OPERATION AND MAINTENANCE 

Supplement No.: 7700-2005-1 

Effective Date: May 23, 2005 

Duration: This supplement is effective until superseded or removed. 

/s/Margaret J. Boland 

Approved: MARGARET J. BOLAND

 Forest Supervisor 

Date Approved: 05/23/2005 

Posting Instructions: Supplements are numbered consecutively by title and calendar 

year. Post by document; remove the entire document and replace it with this supplement. 

Retain this transmittal as the first page(s) of this document. The last supplement to this title 

was 

Supplement 11 to 7730 

New Document 7733.03 11 Pages 

Superseded Document(s) by 

Issuance Number and 

Effective Date

None 0 Pages 

Digest: 

This supplement establishes the Klamath National Forest Hazard Tree Policy. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

C-2 Appendix C: Hazard Tree Policy and Safety Provisions

7733 – SAFETY PROVISIONS ON NATIONAL FOREST SYSTEM ROADS 

7733.03 - Policy 

This hazard tree guidance is intended to assist Districts in addressing hazard trees that pose 

an immediate threat to the public. This guidance is developed only for hazard trees and not 

general salvage. Hazard tree removal is considered a road maintenance activity and not a 

salvage activity. This guidance is not intended to discourage the use of general salvage sales 

to address hazard trees where appropriate. 

This guidance is divided into 4 sections: Exhibit 1 assists in identifying appropriate Klamath 

LRMP objectives and requirements, Exhibit 2 addresses NEPA and ESA considerations, 

Exhibit 3 lists processes that identify hazard trees, and Exhibit 4 contains the short term 

mortality definitions that are discussed in the hazard tree matrix in Exhibit 3. 

The hazard tree identification process in Exhibit 3 is for trees along road systems, within 

campgrounds, administrative sites, and other high use recreation areas. The line officer will 

identify the appropriate level of risk based upon the type of public use. 

All trees meeting the hazard criteria in Exhibit 3 should be considered a high priority for 

treatment. There may be some trees deemed to be a hazard that do not meet the enclosed 

criteria. These trees will need to be addressed on a case-by-case basis. 
KLAMATH SUPPLEMENT 7700-2005-1 

EFFECTIVE DATE: 05/23/2005 

DURATION: This supplement is effective until superseded or removed. 

7730 

Page 3 of 11 

FSM 7700 – TRANSPORTATION SYSTEM 

CHAPTER 7730 – OPERATION AND MAINTENANCE 

Appendix C: Hazard Tree Policy and Safety Provisions C-3

EXHIBIT 1 

KLAMATH HAZARD TREE GUIDANCE 

PURPOSE: This document is intended to aid forest personnel and decision makers in 

identifying: 1) Hazard trees, 2) Options available for hazard tree disposition (i.e., retain on 

site, salvage with or without replacement), and 3) Requirements defined by the Klamath 

National Forest Land and Resource Management Plan (Klamath LRMP). 

Hazard Tree Identification and Policy: It is Regional policy to abate public hazards and 

protect public safety. How we choose to treat hazard tree abatement and disposition (i.e., 

felling with or without replacement or topping, and /or sale) is within the line officer’s 

decision space. Once the hazard tree(s) have been identified, a decision must be made on the 

appropriate treatment for the tree. Hazard trees within various land allocations should be 

abated and disposed of differently. 

Watershed analysis and LSR Assessments are not required in order to abate public safety 

hazards. Each activity will need to meet the appropriate NEPA direction, survey and manage 

requirements, and ESA evaluation/consultation requirements prior to undertaking the 

management activities. 

The following offers some guidance for hazard tree abatement and disposition for several of 

the key land allocation areas found on the Forest. 

LSR’s: 

A completed LSR Assessment is not required to abate a public safety hazard. As 

stated in the Klamath LRMP; “Removal of snags and logs may be necessary to reduce 

hazards to humans along road and trails and in or adjacent to campgrounds. Where 

materials must be removed from the site, as in a campground or on a road, a salvage 

sale is appropriate. In other areas, such as along roads, leaving material on site 

should be considered. Also, material will be left where available CWD is 

inadequate.” 

The following contains the CWD guidance for LSR’s that is found in the Klamath 

National Forest Late-Successional Reserve Assessment (pages 3-3 – 3-5): The 

desired amounts of down logs are within the ranges described in the Klamath LRMP. 

The recommended amounts shown here have been adapted for three vegetation types 

and reflect Forest data obtained from the 1992 old growth inventory. Down logs are 

to be in a variety of decay classes; logs 15” in diameter and 10 feet in length count 

towards meeting the guideline for late-successional stands, but larger down logs 

(i.e.>20”) are preferable. The desired figure shown in the following chart represents a 

minimum average for the landscape or treatment area (i.e., 100 acres). Numbers of 

down logs can vary on any particular acre. It is desired to exceed this minimum 

figure, but not at a point that will create the likelihood of a stand replacing event. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

C-4 Appendix C: Hazard Tree Policy and Safety Provisions

Vegetation Type Aspect CWD/acre 

Douglas-fir North and East 12 

Douglas-fir South and West 8 

Mixed Conifer North and East 10 

Mixed Conifer South and West 7 

True Fir All 15 

An assessment of current CWD densities should be done in order to determine 

appropriateness of disposing the hazard by removal. Methods to consider where 

CWD densities are not adequate should include topping or felling and leaving on site. 

Any felled tree should be left in a position where it will not be a potential hazard to 

the road/site from rolling. REO review is not needed for hazard tree abatement. 

NSO Critical Habitat: 

If the hazard tree abatement project is within designated critical habitat, emphasis 

shall be given to maintaining the primary constituent elements (canopy closure, 

snags, and coarse woody debris) while mitigating the hazard. Depending on the 

scope and scale of the project, the USFWS may need to be contacted. Sale of trees is 

appropriate if all Klamath LRMP standards and guides are met for CWD. Methods to 

consider where CWD densities are not adequate should include topping or felling and 

leaving on site. Any felled tree should be left in a position where it will not be a 

potential hazard to the road/site from rolling. 

SONCC (Coho) Critical Habitat: Follow guidelines for Riparian Reserves 

Riparian Reserves: 

Consideration for riparian CWD requirements is key in the Riparian Reserve land 

allocation. Most trees felled will be left on site to help meet CWD requirements for 

riparian areas. Pertinent S&Gs are: 

MA10-56 Maintain 20 pieces of large wood (40 cubic feet or larger) per 1,000 lineal 

feet within 3rd to 5th order channels, or as identified in the ecosystem management 

process at the watershed level. 

MA10-53 Fall roadside safety hazard trees. Allow the removal of these trees where 

woody debris requirements have been met.” 

Page 3-69 of KLRMP EIS describes the amount of large woods per 1,000 for a 

number of streams on the Forest. None of the streams listed in the KLRMP EIS meet 

the S&G for large wood. The greatest number of wood estimated for streams listed is 

Rock Creek at 1.11 pieces per thousand feet. Therefore, it is unlikely that hazard 

trees would be removed based on sufficient large wood levels. Priority must be given 

to meeting the Klamath LRMP standards and guides for CWD, unless public safety 

and integrity of the road drainage system dictates otherwise. Methods to consider 

where CWD densities are not adequate should include topping or felling and 

leaving on site. Any felled tree should be left in a position where it will not be a 

potential hazard to the road/site from rolling. 
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DURATION: This supplement is effective until superseded or removed. 

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The removal of hazard trees in Riparian Reserves is considered a road management 

activity, not a timber management-salvage activity. Therefore S&G MA10-54 

(Salvage trees only when watershed analysis determines that present and future CWD 

needs are met and other Aquatic Conservation Strategy objectives are not adversely 

affected) does not apply to hazard tree removal. 

For other Forest-wide standards and guides refer to 6-16 (page 4-25), Coarse Woody 

Debris, in the Klamath LRMP. 

Administrative Sites (Campgrounds, Special Use Permits, Day Use Areas, Trailheads, 

etc.): 

For these types of areas it is recommended that the sites receive a Forest Pest 

Management evaluation. This should be followed up with the development of a sitespecific vegetation management plan. Recommendations from the Forest Pest 

evaluation and subsequent vegetation management plan should be used to develop 

abatement and disposition strategies for administrative sites. Options to consider for 

disposition in administrative sites can include fell and remove the hazard, remove the 

defective part of the hazard, fell and leave on site, and/or remove the potential target. 

Matrix: 

This land allocation offers the most flexibility for felling and removal. Klamath 

LRMP standards and guides for CWD should be considered during analysis of hazard 

tree safety abatement and disposition. Several factors should be considered during 

the analysis including the potential for future CWD recruitment (within the general 

area and not limited to just the roadside) and the likelihood of any felled tree 

remaining on site due to potential firewood use. 

AMA: 

Hazard tree disposition within the AMA should consider the land allocation that has 

been identified within the AMA designation and treated appropriately using above 

guidance. 

Appropriate NEPA and ESA requirements must be met for hazard tree abatement and 

disposition for all the above land allocations. Follow the standards and guides within the 

Klamath LRMP for each land allocation (Riparian Reserves, LSR’s, Matrix, and AMA). 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

C-6 Appendix C: Hazard Tree Policy and Safety Provisions

EXHIBIT 2 

NEPA AND ESA CONSIDERATIONS: 

1. Determine the Klamath LRMP land allocation(s) in which the project is located. If the 

project will occur in an area where the maintenance of snags is extremely important, consider 

topping the trees to maintain the snag component of the stand. These types of allocations 

may include Research Natural Areas, spotted owl habitat, LSR’s, Riparian Reserve areas, 

Goshawk areas, and Bald Eagle roost areas. 

When hazard tree removal is proposed within an RNA, NSO critical spotted critical owl 

habitat, Managed wildlife area, LSR, riparian area, Goshawk area, or Bald Eagle roost area, it 

is important that the hazard removal activity be consistent with the intent of that land 

designation. 

2. An analysis to determine the level of coarse woody material on the site, consistent with 

the scope of the proposed project should be used to determine if there is adequate coarse 

woody material to meet the Klamath LRMP standards and guidelines. If the guidelines are 

not met, the material should be left on site if it is not a safety hazard. 

3. The project may have to be reviewed by a Level 1 consultation team if the project is 

within 45 miles of the coast and within 1⁄4 mile of suitable MAMU habitat, is within a bald 

eagle roost or nest area, or within a known spotted owl activity center; or is within 1⁄4 mile of 

unsurveyed suitable spotted owl habitat. 

4. NMFS has provided guidelines for the definition of hazard trees. The NMFS definition 

for hazard trees identification is consistent with the KNF definition. NMFS concluded 

informal consultation for hazard tree removal in the July 17, 1997 BO/LOC for the “Road 

and Trail Maintenance, Watershed Restoration, and January 1997 Flood Response Actions 

on the KNF”. NMFS has also provided Project Design Standards and concluded 

programmatic consultation of the removal of hazard trees if the Project Design Standards 

below are met (See August 1, 1997 NMFS letter for more information): 

Removal of hazard trees that have fallen or are felled within interim RRs will generally be 

left on site, as these trees may be needed to maintain and restore coarse woody debris levels 

and function within these areas. 

a. Fallen or felled hazard trees may be removed from interim RRs if 

i. Trees must be removed to provide safe road passage or campground access and 

function; OR 

Those trees would pose a substantial risk to the forest road drainage system integrity; AND 

A fisheries biologist determines through site inspection and written document that removal of 

individual hazard trees within interim RRs is consistent with the Aquatic Conservation 

Strategy Objectives. 

5. Use a categorical exclusion (Decision Memo) when the hazard trees pose a significant 

threat to public safety. Use categories 31.1b.3 (“Repair and maintenance of administrative 

sites”), 31.1b.4 (“Repair and maintenance of roads, trails, and landline boundaries”), or 

31.1b.5 (“Repair and maintenance of recreation sites and facilities”) for trimming, felling, or 

removing individual hazardous trees and other vegetation from around administrative sites, 
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recreation sites, roads, and trails, where the material could be sold. To correctly apply these 

CE’s, the primary reason for the actions must be the hazard, and that the hazard must clearly 

pose an immediate public danger or threat in campgrounds, recreation facilities or other high 

use areas; or public danger or threat along open roads. Refer to the February 9, 2000 memo 

concerning “Clarifying order and Categorical Exclusions for Hazard Trees.” 

6. Where the removal of trees includes more than hazard trees the use of categorical 

exclusions is not warranted. An environmental assessment with supporting decision notice 

needs to be completed. 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

C-8 Appendix C: Hazard Tree Policy and Safety Provisions

EXHIBIT 3 

HAZARD TREE DEFINITION 

A tree is considered a hazard if all or a portion of the tree has a high potential to fall or roll 

onto a roadway or facility and cause personal injury or property damage. Distance to trees 

on the uphill side may exceed one tree height if they are likely to roll or slide onto the 

roadway, site, or facility (i.e., there are insufficient barriers to prevent trees from reaching the 

roadway, trail or facility). 

R.O. Direction – Top priority will be given to the felling and/or the removal of trees that are 

dead or have visible defects and are sufficiently tall to fall on roads or high use areas and 

cause personal injury, death, or significant property damage. 

Areas of Consideration: 

Roads: Level 3, 4, and 5 system roads (required in Federal Highway Safety Act) and level 2 

roads where closure is not an option. The Federal Highway Safety Act includes signed 

snowmobile trails. 

Campgrounds, Administrative Sites, etc.: Developed and undeveloped recreation sites, 

special use areas, Forest Service administrative sites, day use areas, river access areas, 

trailheads, and other areas of high recreation and visitor use. 

Hazard Tree Criteria: 

It must be remembered that these are guidelines for determining definite hazard tree 

situations. These guidelines are based on physical location (target potential) and 

physical characteristics (tree defects) that either present a definite hazard or have high 

potential for tree failure and the potential to reach an area of concern (road, 

campground, administrative site, etc.). There may be other trees and situations that 

may not specifically fall into these categories but may still be determined to be a hazard 

based on local conditions, further site evaluation and the judgment of the inspector. All 

hazard tree evaluations should be documented in writing. A hazard tree inspection 

form is included for use where appropriate, particularly in the recreation or 

administrative sites listed above. 

To be considered a hazard tree, it must meet one or more of the following criteria: 

1. Forest pest management experts (entomologist and/or pathologist) have 

reviewed the trees/snags and have indicated that they are a hazard. 

If Forest Pest Management specialists have not reviewed the proposed project area, 

the following should be used to determine if a tree/snag is a hazard. The following is 

a guideline rating systems to be used for judging hazard trees by tree defect and target 

potential. 

Rating: Tree/snag needs any combination of 3 points or greater to qualify as Hazard Tree 

(more than one category can be used to get a total of 3 or greater). 
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DURATION: This supplement is effective until superseded or removed. 

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2. Tree Defect and Target Potential

Tree Defect and/or Target Potential Points 

Tree is dead (no live crown) 2 

Snags or spike top trees above road that are within the height of the 

snag/spike top tree and are straight or lean toward road 

2 

Snags or spike top trees below road that are within the height of the 

snag/spike top tree and lean toward road 

2 

Snags or spike top trees with potential to reach site/facility 2 

Unnatural lean exceeds 20 degrees from vertical toward area of concern 2 

Green trees above or below road sufficiently tall to reach road (unnatural 

lean only) exceeding 16” DBH and 20 feet tall 

1 

Green trees with potential to reach a site/facility (unnatural lean only). 2 

Soil shows evidence of recent movement (within the last 5 years) 2 

Spike top tree where the dead portion of the tree has the potential to reach 

the area of concern 

1 

Trees showing signs of advanced symptoms of root diseases (trees infected 

with annosus root disease, black stain, Armillaria root disease, etc.) and 

have the potential to reach the area of concern 

3 

Trees expected to die within the next 6 months (see Exhibit 4, Klamath 

“Short-term Mortality Indicators”) and have the potential to reach the area 

of concern 

3 

Mechanical and bole defects (including fire damage). Bole damage 

(cambium) exceeds one-third of the circumference for all species except 

sugar pine and has the potential to reach the area of concern. Bole damage 

(cambium) on sugar pines exceeds 50% of the circumference and has the 

potential to reach the area of concern 

3 

Exposed root wad of tree sufficiently tall to reach the road 3 

Trees showing symptoms of advanced branch, bole or basal decay due to 

root disease or heart rot. Total solid rind thickness is less than one-third of 

the diameter at the point of decay and the tree has the potential to reach the 

area of concern. 

3 
Final Environmental Impact Statement 

Klamath National Forest Eddy Gulch LSR Project 

C-10 Appendix C: Hazard Tree Policy and Safety Provisions

EXHIBIT 4 

SHORT TERM MORTALITY INDICATORS 

The following conditions indicate that the affected trees have a fatal, non-reversible 

condition and are very likely to be dead within 6 months. Some trees under severe droughtstress may show no external sign of being attacked by beetles. Any tree, which has life 

stages or galleries of any species of beetle, except red turpentine beetle, visible when bark is 

removed with an axe, should be expected to die within 6 months. Trees infested with only 

red turpentine beetle must be physically girdled around at least 40 % of the tree 

circumference to be expected to die within 6 months. 

A. Pines. (Ponderosa, Jeffrey, sugar and western white pines). 

(1) Top one third of crown faded down to a stem diameter of at least 6 inches. 

(Crown fading will follow a rapid progression of colors from pea-green to strawyellow to orange to brick-red to brown. The size limitation indicates infestation 

by a species of Dendroctonus bark beetle). 

(2) Fresh, sticky pitch tubes located on the bole between 2 and 20 feet above the 

ground. Pitch tubes must be reddish in color (pink, rosy, red, purplish-red, 

reddish-brown). Number of fresh pitch tubes must be at least equal or greater 

than half of the DBH in inches (i.e. a 12 inch DBH pine must have at least 6 fresh, 

reddish pitch tubes). Crown may be any color. 

(3) Fine, dry red frass (boring dust) accumulated in bark crevices, or cobwebs, or on 

ground around base of pine tree. (This does not include the coarse, crumbly frass 

produced by red turpentine beetle, which is often resinous.) Amount of frass per 

tree must total at least one tablespoon to be considered significant. Crown may be 

any color. 

(4) Conspicuous removal of bark by woodpeckers. Outer bark of ponderosa pines 

usually removed in patches of several square inches to reveal reddish inner bark. 

Woodpecker work on Jeffrey, sugar and western white pines usually a vertical 

series of 3/8 inch diameter holes at about 1 inch spacing on bark plates. Bark 

flakes usually accumulate on ground or snow under tree. Crown may be any 

color. 

(5) Blowdown. 

B. White fir. 

(1) Crown currently faded down to a stem diameter of 4 inches or greater. Crown 

color will rapidly change from pea-green to yellow to orange to brick-red to 

brown. Size limitation indicates the fir engraver, Scolytus ventralis is infesting 

the main stem. 

(2) White frass (boring dust) accumulated in bark crevices, cobwebs or around base 

of fir tree. Amount of frass per tree must total one tablespoon to be significant. 

Crown may be any color. (White frass indicates either no pitch flow in response 

to fir engraver attack, or successful infestation by ambrosia beetles. Either 
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condition indicates a dying fir tree.) 

(3) Ground or snow below white fir tree covered with “green” needles. This does not 

include normal fall shedding of older yellow needles. 

(4) Blowdown. 

C. Red fir. 

(1) No limbs with normal-color green foliage left in crown. 

(2) White frass (boring dust) accumulated in bark crevices, cobwebs or around base 

of fir tree. Amount of frass per tree must total one tablespoon to be significant. 

Crown may be any color. (White frass indicates either no pitch flow in response 

to fir engraver attack, or successful infestation by ambrosia beetles. Either 

condition indicates a dying fir tree.) 

(3) Blowdown. 

D. Douglas-fir. 

(1) At least one accumulation of rusty-orange frass (boring dust) per foot of 

circumference. The piles of frass will be approximately 3⁄4 inch in diameter and 

will be located in bark crevices in the lower 3 feet of the bole. (This indicates 

successful attack by the Douglas-fir beetle.) 

(2) Trees have not broken bud while all adjacent trees have broken bud. 

Buds are drying and are not firm. 

(3) Woodpeckers have removed at least several square inches of bark from the bole 

portion which has bark less than 1.5 inches in thickness. Crown may be any 

color, including green. Ignore single, deep woodpecker holes near the base of 

old, thick-barked trees (the woodpeckers at the base are usually seeking ants in 

the bark, which are not a threat to the tree). 

(4) No limbs with completely normal-color foliage remaining on tree. 

(5) Blowdown. 

E. Incense-cedar. 

(1) No limbs with completely normal-color foliage remaining on tree. 

(2) Blowdown. 
The Eddy Gulch LSR Project